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| Title | Recipient | Date |
|---|---|---|
| Comments on Basel Cryptoasset Standard Amendments | Basel Committee on Banking Supervision | 03/28/24 |
| Freedom of Information Act Request on CBDC Authority | Federal Reserve, Justice Department, Treasury Department | 03/22/24 |
| Joint Trade Statement on ISO 20022 Standards | BIS Committee on Payments and Market Infrastructures | 02/28/24 |
| Disclosure of Cryptoasset Exposures | Letter to Regulators | 01/30/24 |
| ICBA Comment Letter for FinCEN Cryptocurrency Mixer Proposal | FinCEN | 01/23/24 |
| Joint Extension Request on Fed Debit Card Interchange Price Cap | Federal Reserve | 11/27/23 |
| Comments on Proposed Tax Treatment of Digital Assets | IRS | 11/13/23 |
| Joint Trades Letter on Reg II Board Meeting | Federal Reserve | 10/20/23 |
| Response to IOSCO DeFi Policy Recommendations | IOSCO | 10/18/23 |
| Joint Letter on Mortgage Rates | White House, Treasury Department | 10/12/23 |
| Title | Committee | Presenter | Date |
|---|---|---|---|
| Statement for House Hearing on Central Bank Digital Currency Risks | House Subcommittee on Digital Assets, Financial Technology and Inclusion | Written Statement | 09/13/23 |
| Effective Regulation of Crypto Assets | Senate Banking Committee | Written Statement | 02/13/23 |
| Statement for Senate Crypto Hearing | Senate Banking Committee | Written Statement | 07/28/22 |
| Hearing Statement on Central Bank Digital Currency | House Financial Services Committee | Written statement | 05/25/22 |
| Enhanced Regulation of Digital Assets Will Promote Responsible Innovation | Senate Banking Hearing | 02/15/22 | |
| Statement for House Hearing on Stablecoins | House Financial Services Committee | Written statement | 02/08/22 |
| Statement for Senate Stablecoin Hearing | Senate Banking Committee | Written Statement | 12/14/21 |
| Statement for House Hearing on Digital Assets | House Financial Services Committee | Written statement | 12/07/21 |
| ICBA Statement for HFSC Fintech Hearing 9-29-2020 | HSFC | 09/29/20 |
April 04, 2024
The Securities and Exchange Commission’s head of enforcement, Gurbir Grewal, defended his agency’s actions against illicitly traded cryptoassets.
Remarks: Grewal said despite the crypto sector’s claims that it is not subject to securities laws, the SEC has consistently applied the Howey Test, which is the standard for determining what may qualify as a security, to determine whether instruments are investment contracts. He said the crypto sector’s arguments amount to saying, “we want a different set of rules than those that apply to everyone else.”
ICBA View: An ICBA blog post discusses the Howey Test and the policy debate over treating cryptoassets as securities or commodities. In a recent comment letter, ICBA said the Financial Crimes Enforcement Network’s proposal to institute recordkeeping and reporting requirements for financial institutions is insufficient to adequately protect against crypto-related illicit financial activity.