cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy
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cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy [2022/05/17 01:50] nick [Discussion of Examples] |
cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy [2022/06/17 18:28] (current) terrance |
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| | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:start| Return to Question 1]] | <WRAP> | | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:start| Return to Question 1]] | <WRAP> | ||
| <html><b> | <html><b> | ||
| - | <a href="mailto:[email protected]?Subject=OMG CBDC Response: | + | <a href="mailto:[email protected]?Subject=OMG's CBDC WG Response: |
| sub-Q2: Policies | sub-Q2: Policies | ||
| ">Provide Feedback</a></b> | ">Provide Feedback</a></b> | ||
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| * Data | * Data | ||
| - | CBDC Governance is the system that controls the entities and direction of the CBDC effort. Its primary concern is the structure and processes for decision-making, accountability, control and behavior at the top of the CBDC. CBDC governance will set the organization’s objectives, measure how well these objectives are achieved, monitor risks to the CBDC, and set actions in place to mitigate those risks. Governance is a system and a process, not a single activity; therefore successful implementation of a good governance strategy requires a systematic approach that incorporates strategic planning, risk management and performance management. Like culture, it is a core component of the unique characteristics of a successful organization. | + | CBDC Governance is the system that controls the entities and direction of the CBDC effort. Its primary concern is the structure and processes for decision-making, accountability, control and behavior at the top of the CBDC. CBDC governance will set the organization’s objectives, measure how well these objectives are achieved, monitor risks to the CBDC, and set actions in place to mitigate those risks. Governance is a system and a process, not a single activity; therefore successful implementation of a good governance strategy requires a systematic approach that incorporates strategic planning, risk management, and performance management. Like culture, it is a core component of the unique characteristics of a successful organization. |
| ==== Examples ==== | ==== Examples ==== | ||
| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy| Return to Top]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy| Return to Top]] | ||
| - | Some "desirements" in the [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | Money and Payments: The U.S. Dollar in the Age of Digital Transformation]] **White Paper** and summarized in the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| White Paper Analysis]] done by the [[https://www.omg.org/ | Object Management Group ]] allude to the Governance areas shown in the table below: | + | Some "desirements" in the [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | Money and Payments: The U.S. Dollar in the Age of Digital Transformation]] **White Paper** and summarized in the OMG's CBDC WG [[cbdc:public:cbdc_omg:04_doc:12_summary:start| White Paper Analysis]] done by the [[https://www.omg.org/ | Object Management Group's ]] CBDC Working Group allude to the Governance areas shown in the table below: |
| <table mappingTable> | <table mappingTable> | ||
| - | <caption>Example of mapping a subset of "desirements" identified during the White Paper Analysis conducted by OMG.</caption> | + | <caption>Example of mapping a subset of "desirements" identified during the White Paper Analysis conducted by OMG's CBDC WG.</caption> |
| ^ Governance Area | **OMG Identified "desirements"** | | ^ Governance Area | **OMG Identified "desirements"** | | ||
| ^ [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#legislation_laws_and_regulations| Legislation, Laws, and Regulations]] | <WRAP> | ^ [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#legislation_laws_and_regulations| Legislation, Laws, and Regulations]] | <WRAP> | ||
| Line 76: | Line 76: | ||
| : D: D0002, D0003, D0011, D0012, D0013, D0016, D0017 | : D: D0002, D0003, D0011, D0012, D0013, D0016, D0017 | ||
| </WRAP>| | </WRAP>| | ||
| - | | **''B''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#benefits| Benefit Considerations ]] || | + | | **''B''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#benefit_considerations| Benefit Considerations ]] || |
| | **''P''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#policy_considerations| Policy Considerations]] || | | **''P''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#policy_considerations| Policy Considerations]] || | ||
| - | | **''R''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#risks| Risk Considerations ]] || | + | | **''R''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#risk_considerations| Risk Considerations ]] || |
| - | | **''D''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#design| Design Considerations]] || | + | | **''D''** = [[cbdc:public:cbdc_omg:04_doc:12_summary:start#design_considerations | Design Considerations]] || |
| </table> | </table> | ||
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| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] map to Legislation, Laws, and Regulations. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG's White Paper Analysis effort]] map to Legislation, Laws, and Regulations. |
| <table legal> | <table legal> | ||
| Line 108: | Line 108: | ||
| ^ Statement No. ^ Page No. ^ Statement | | ^ Statement No. ^ Page No. ^ Statement | | ||
| - | ^ P0011 ^ 3 | The Federal Reserve does not intend to proceed with issuance of a CBDC without clear support from:<WRAP> | + | ^ P0011 ^ 3 | The Federal Reserve does not intend to proceed with the issuance of a CBDC without clear support from:<WRAP> |
| : 1. the Executive Branch | : 1. the Executive Branch | ||
| : 2. Legislative Branch | : 2. Legislative Branch | ||
| Line 124: | Line 124: | ||
| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] map to US Government organizations external to the Federal Reserve. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG's White Paper Analysis effort]] map to US Government organizations external to the Federal Reserve. |
| <table intern> | <table intern> | ||
| Line 151: | Line 151: | ||
| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] map to External US Government organizations. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG White Paper Analysis effort]] map to External US Government organizations. |
| <table extern> | <table extern> | ||
| Line 175: | Line 175: | ||
| * **''B0005''**, **''B0052''**, **''P0005''**, **''R0014''** are all targeted at preventing criminal activities. Although there is a lot of criminal activity within the US, in this modern age of internationalism, it is important to elicit the help of foreign governments in detecting and tracking down criminal activities. | * **''B0005''**, **''B0052''**, **''P0005''**, **''R0014''** are all targeted at preventing criminal activities. Although there is a lot of criminal activity within the US, in this modern age of internationalism, it is important to elicit the help of foreign governments in detecting and tracking down criminal activities. | ||
| * **''B0009''**, **''B0015''**, **''B0041''** are all targeted at cross-border payments and remittances, which naturally would require the participation of foreign governments and institutions. | * **''B0009''**, **''B0015''**, **''B0041''** are all targeted at cross-border payments and remittances, which naturally would require the participation of foreign governments and institutions. | ||
| - | * **''D0009''** is concerned with foreign demand for CBDC, which again would point to some foreign government and institutions being involved. | + | * **''D0009''** is concerned with foreign demand for CBDC, which again would point to some foreign governments and institutions being involved. |
| === Private Sector Parties === | === Private Sector Parties === | ||
| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] are intended for Private Sector organizations. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG White Paper Analysis effort]] are intended for Private Sector organizations. |
| <table private> | <table private> | ||
| Line 228: | Line 228: | ||
| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] call for Purpose-built Hardware. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG White Paper Analysis effort]] call for Purpose-built Hardware. |
| <table legal> | <table legal> | ||
| - | <caption>**White Paper** "desirements" associated with Hardware that is purpose built for the CBDC.</caption> | + | <caption>**White Paper** "desirements" associated with Hardware that is purpose-built for the CBDC.</caption> |
| : **Note:** The following subset of "desirements" only represents a few that are relevant to Purpose-built Hardware found in the White Paper. They are provided to support further discussions. | : **Note:** The following subset of "desirements" only represents a few that are relevant to Purpose-built Hardware found in the White Paper. They are provided to support further discussions. | ||
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| ^ P0025 ^ 14 | CBDC intermediary would need to verify the identity of a person accessing CBDC | | ^ P0025 ^ 14 | CBDC intermediary would need to verify the identity of a person accessing CBDC | | ||
| ^ D0011 ^ 19 | **Design** should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | | ^ D0011 ^ 19 | **Design** should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | | ||
| - | ^ D0015 ^ 20 | **Design** should include any dedicated infrastructure required to provide a resilience to threats such as operational disruptions and cybersecurity risks | | + | ^ D0015 ^ 20 | **Design** should include any dedicated infrastructure required to provide resilience to threats such as operational disruptions and cybersecurity risks | |
| - | ^ D0016 ^ 20 | **Design** should include offline capabilities to help with operational resilience of the payment system | | + | ^ D0016 ^ 20 | **Design** should include offline capabilities to help with the operational resilience of the payment system | |
| ^ D0017 ^ 20 | **Design** should include digital payments in areas suffering from large disruption, such as natural disasters | | ^ D0017 ^ 20 | **Design** should include digital payments in areas suffering from large disruption, such as natural disasters | | ||
| </table> | </table> | ||
| * **''P0025''** could require hardware for identification such as [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:xapend:xapend.a_glossary:s:smart_card | Smart Cards]] or [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:xapend:xapend.a_glossary:r:rsa_secureid]] which may or may not be Purpose-Built for the CBDC. | * **''P0025''** could require hardware for identification such as [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:xapend:xapend.a_glossary:s:smart_card | Smart Cards]] or [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:xapend:xapend.a_glossary:r:rsa_secureid]] which may or may not be Purpose-Built for the CBDC. | ||
| - | * **''D0011''** could be relevant when there is network monitoring | + | * **''D0011''** could be relevant when there is a network monitoring |
| - | * **''D0015''** if portions of the CBDC are over [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:1.2_views:3_taxonomic:2_network_access_ctrll:start | secure, private networks]] that are purpose built for the operations, then they must be resilient to threats, disruptions and cybersecurity threats. | + | * **''D0015''** if portions of the CBDC are over [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:1.2_views:3_taxonomic:2_network_access_ctrll:start | secure, private networks]] that are purpose-built for the operations, then they must be resilient to threats, disruptions and cybersecurity threats. |
| * **''D0016''**, **''D0017''** mean that payment systems need to be able to work autonomously in isolation from the Internet. This highlights the advantage of a [[cbdc:public:cbdc_omg:04_doc:15_common:08_currency_models:10_cash:start| Digital Coin]] versus a [[cbdc:public:cbdc_omg:04_doc:15_common:30_stablecoins:start| Stablecoin]]. | * **''D0016''**, **''D0017''** mean that payment systems need to be able to work autonomously in isolation from the Internet. This highlights the advantage of a [[cbdc:public:cbdc_omg:04_doc:15_common:08_currency_models:10_cash:start| Digital Coin]] versus a [[cbdc:public:cbdc_omg:04_doc:15_common:30_stablecoins:start| Stablecoin]]. | ||
| Line 250: | Line 250: | ||
| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] call for Purpose-built Software. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG White Paper Analysis effort]] call for Purpose-built Software. |
| <table legal> | <table legal> | ||
| - | <caption>**White Paper** "desirements" associated with Software that is purpose built for the CBDC.</caption> | + | <caption>**White Paper** "desirements" associated with Software that is purpose-built for the CBDC.</caption> |
| : **Note:** The following subset of "desirements" only represents a few that are relevant to Purpose-built Software found in the White Paper. They are provided to support further discussions. | : **Note:** The following subset of "desirements" only represents a few that are relevant to Purpose-built Software found in the White Paper. They are provided to support further discussions. | ||
| Line 259: | Line 259: | ||
| ^ P0025 ^ 14 | CBDC intermediary would need to verify the identity of a person accessing CBDC | | ^ P0025 ^ 14 | CBDC intermediary would need to verify the identity of a person accessing CBDC | | ||
| ^ R0014 ^ 13 | **Risk** of not achieving an appropriate balance between safeguarding the privacy rights of consumers and affording the transparency necessary to deter criminal activity | | ^ R0014 ^ 13 | **Risk** of not achieving an appropriate balance between safeguarding the privacy rights of consumers and affording the transparency necessary to deter criminal activity | | ||
| - | ^ D0002 ^ 17 | **Design** should allow the central bank to limit the amount of CBDC an end user could hold | | + | ^ D0002 ^ 17 | **Design** should allow the central bank to limit the amount of CBDC an end-user could hold | |
| - | ^ D0003 ^ 18 | **Design** should allow a limit on the amount of CBDC an end user could accumulate over short periods | | + | ^ D0003 ^ 18 | **Design** should allow a limit on the amount of CBDC an end-user could accumulate over short periods | |
| ^ D0011 ^ 19 | **Design** should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | | ^ D0011 ^ 19 | **Design** should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | | ||
| ^ D0013 ^ 19 | **Design** should facilitate compliance with a robust set of rules already intended to combat <WRAP> | ^ D0013 ^ 19 | **Design** should facilitate compliance with a robust set of rules already intended to combat <WRAP> | ||
| Line 266: | Line 266: | ||
| : 2. the financing of terrorism | : 2. the financing of terrorism | ||
| : 3. customer due diligence | : 3. customer due diligence | ||
| - | : 4. record keeping | + | : 4. record-keeping |
| : 5. reporting requirements | : 5. reporting requirements | ||
| </WRAP>| | </WRAP>| | ||
| - | ^ D0016 ^ 20 | **Design** should include offline capabilities to help with operational resilience of the payment system | | + | ^ D0016 ^ 20 | **Design** should include offline capabilities to help with the operational resilience of the payment system | |
| ^ D0017 ^ 20 | **Design** should include digital payments in areas suffering from large disruption, such as natural disasters | | ^ D0017 ^ 20 | **Design** should include digital payments in areas suffering from large disruption, such as natural disasters | | ||
| </table> | </table> | ||
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| [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | [[cbdc:public:cbdc_omg:04_doc:20_comments:brp:q01:policy#discussion_of_examples| Return to Discussion of Examples]] | ||
| - | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG White Paper Analysis effort]] for Purpose-defined Data. | + | Some "desirements" identified in [[https://www.federalreserve.gov/publications/files/money-and-payments-20220120.pdf | CBDC White Paper ]] by the [[cbdc:public:cbdc_omg:04_doc:12_summary:start| OMG's CBDC WG White Paper Analysis effort]] for Purpose-defined Data. |
| <table legal> | <table legal> | ||
| Line 289: | Line 289: | ||
| ^ Statement No. ^ Page No. ^ Statement | | ^ Statement No. ^ Page No. ^ Statement | | ||
| - | ^ B0051 ^ 19 | Generate data about users’ financial transactions similarly to current Commercial Bank(( | + | ^ B0051 ^ 19 | Generate data about users’ financial transactions similarly to the current Commercial Bank(( |
| Commercial banks include banks licensed either by federal or state banking agencies, credit unions, and thrifts from the **White Paper&**. | Commercial banks include banks licensed either by federal or state banking agencies, credit unions, and thrifts from the **White Paper&**. | ||
| )) and [[cbdc:public:cbdc_omg:8_append:20_glossary:nonbank_money]] | | )) and [[cbdc:public:cbdc_omg:8_append:20_glossary:nonbank_money]] | | ||
| ^ P0004 ^ 2 | Protect consumer privacy | | ^ P0004 ^ 2 | Protect consumer privacy | | ||
| ^ R0014 ^ 13 | **Risk** of not achieving an appropriate balance between safeguarding the privacy rights of consumers and affording the transparency necessary to deter criminal activity | | ^ R0014 ^ 13 | **Risk** of not achieving an appropriate balance between safeguarding the privacy rights of consumers and affording the transparency necessary to deter criminal activity | | ||
| - | ^ D0002 ^ 17 | **Design** should allow the central bank to limit the amount of CBDC an end user could hold | | + | ^ D0002 ^ 17 | **Design** should allow the central bank to limit the amount of CBDC an end-user could hold | |
| - | ^ D0003 ^ 18 | **Design** should allow a limit on the amount of CBDC an end user could accumulate over short periods | | + | ^ D0003 ^ 18 | **Design** should allow a limit on the amount of CBDC an end-user could accumulate over short periods | |
| ^ D0011 ^ 19 | **Design** should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | | ^ D0011 ^ 19 | **Design** should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | | ||
| ^ D0013 ^ 19 | **Design** should facilitate compliance with a robust set of rules already intended to combat <WRAP> | ^ D0013 ^ 19 | **Design** should facilitate compliance with a robust set of rules already intended to combat <WRAP> | ||
| Line 301: | Line 301: | ||
| : 2. the financing of terrorism | : 2. the financing of terrorism | ||
| : 3. customer due diligence | : 3. customer due diligence | ||
| - | : 4. record keeping | + | : 4. record-keeping |
| : 5. reporting requirements | : 5. reporting requirements | ||
| </WRAP>| | </WRAP>| | ||
| - | ^ D0016 ^ 20 | **Design** should include offline capabilities to help with operational resilience of the payment system | | + | ^ D0016 ^ 20 | **Design** should include offline capabilities to help with the operational resilience of the payment system | |
| ^ D0017 ^ 20 | **Design** should include digital payments in areas suffering from large disruption, such as natural disasters | | ^ D0017 ^ 20 | **Design** should include digital payments in areas suffering from large disruption, such as natural disasters | | ||
| </table> | </table> | ||
| - | * **''B0051''**, **''D0011''**, **''D0011''**, **''D0013''**: most existing blockchain, [[cbdc:public:cbdc_omg:04_doc:15_common:30_stablecoins:start| Stablecoin]] products are "organic", evolving from the bottom up and are centered around the concepts of a ledger. Although this is part of banking, there is so much more that is required by law in the US. Many of these rules are not intended just to be administrative roadblocks (i.e.,administrivia) but were instituted as a result of some previous problems and help to stabilize and instill confidence in the US financial institutions. Adding "rules" to these products will either degrade the quality and performance of the products or have spotty implementations. | + | * **''B0051''**, **''D0011''**, **''D0011''**, **''D0013''**: most existing blockchain, [[cbdc:public:cbdc_omg:04_doc:15_common:30_stablecoins:start| Stablecoin]] products are "organic", evolving from the bottom up and are centered around the concepts of a ledger. Although this is part of banking, there is so much more that is required by law in the US. Many of these rules are not intended just to be administrative roadblocks (i.e., administrivia) but were instituted as a result of some previous problems and help to stabilize and instill confidence in the US financial institutions. Adding "rules" to these products will either degrade the quality and performance of the products or have spotty implementations. |
| * **''P0004''** is intended to protect consumer privacy, not just when the [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:1.2_views:3_taxonomic:4_data_tax:02_state_taxonomy:data_at_rest | Data is at Rest]], but also when the [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:1.2_views:3_taxonomic:4_data_tax:02_state_taxonomy:data_in_motion | Data is in Motion]] and while it is being used (processed). It is only when all the places where data is used are protected, can there be assurances of consumer privacy. While the traditional concepts of Data-At-Rest and Data-In-Motion are well known and understood, the third category, Data-In-Use, has emerged as equally important. In the past, Data-In-Use was physically protected at physically secured mainframes and Data Centers; however, with distributed computers, especially on Public Networks, there can be no such assurances. As the value of the assets on the network increase, the motivation to "hack" the data while in use increases. The CBDC, as part of the critical infrastructure, will be a prime target. | * **''P0004''** is intended to protect consumer privacy, not just when the [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:1.2_views:3_taxonomic:4_data_tax:02_state_taxonomy:data_at_rest | Data is at Rest]], but also when the [[https://www.omgwiki.org/dido/doku.php?id=dido:public:ra:1.2_views:3_taxonomic:4_data_tax:02_state_taxonomy:data_in_motion | Data is in Motion]] and while it is being used (processed). It is only when all the places where data is used are protected, can there be assurances of consumer privacy. While the traditional concepts of Data-At-Rest and Data-In-Motion are well known and understood, the third category, Data-In-Use, has emerged as equally important. In the past, Data-In-Use was physically protected at physically secured mainframes and Data Centers; however, with distributed computers, especially on Public Networks, there can be no such assurances. As the value of the assets on the network increase, the motivation to "hack" the data while in use increases. The CBDC, as part of the critical infrastructure, will be a prime target. | ||
| * **''R0014''** is about achieving a balance between a consumer's privacy and the transparency required to prevent criminal activity. In the real world, these limits are achieved through the difficulty of using physical money. Storing, transferring, and counting it is a problem. Although cash is anonymous, large amounts of cash trigger examination. | * **''R0014''** is about achieving a balance between a consumer's privacy and the transparency required to prevent criminal activity. In the real world, these limits are achieved through the difficulty of using physical money. Storing, transferring, and counting it is a problem. Although cash is anonymous, large amounts of cash trigger examination. | ||
| - | * **''D0002''**, **''D0003''** represent limits on CBDC holdings and the transactions associated with the current system. In many ways these represent limits established to protect against money laundering. | + | * **''D0002''**, **''D0003''** represent limits on CBDC holdings and the transactions associated with the current system. In many ways, these represent limits established to protect against money laundering. |
| * **''D0016''**, **''D0017''** like the financial and banking rules, is something that needs to be considered very early on in the development of the requirements and architecture rather than addressed //post facto// so the correct data can be collected. | * **''D0016''**, **''D0017''** like the financial and banking rules, is something that needs to be considered very early on in the development of the requirements and architecture rather than addressed //post facto// so the correct data can be collected. | ||
cbdc/public/cbdc_omg/04_doc/20_comments/brp/q01/policy.1652766652.txt.gz · Last modified: 2022/05/17 01:50 by nick
