A Stakeholder is a party with an interest in a Central Bank Digital Currency (CBDC) effort and can either affect or be affected by the CBDC effort. The primary stakeholders in the CBDC effort are U.S. Federal Government Oversight Authorities, non-U.S. Federal Government Oversight Authorities, customers, and suppliers of goods and services.
However, with the increasing attention on social responsibility, the Stakeholder concept now includes: communities, governments, trade associations, and Communities of Interest (CoIs).
There are two “Desirements”1) specified in the White Paper that specifies the need to establish a comprehensive list of Stakeholders:
Statement No. | Page No. | Desirement Statement |
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B0006 | 2 | Provide broad support from key stakeholders |
P0006 | 2 | Garner broad support from key stakeholders |
B = Benefit Considerations |
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P = Policy Considerations |
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R = Risk Considerations |
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D = Design Considerations |
Potential Oversight Authorities | No. of Stakeholders |
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U.S. Federal Government Oversight Authorities | 14 |
non-U.S. Federal Government Oversight Authorities | 19 |
Total | 33 |
Table 3 provides a list of authorities within the U.S. having oversight over financial services. Some authorities listed are Agencies of the U.S. such as the Securities and Exchange Commission (SEC) or the Consumer Financial Protection Bureau (CFPB). Others are independent non-governmental organizations, such as the Financial Industry Regulatory Authority (FINRA).
There are roughly 14 U.S. Federal Government Authorities with financial oversight.
Authority | Description |
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U.S. Treasury | The U.S. Treasury is the government department responsible for issuing all Treasury bonds, notes, and bills. Among the government departments operating under the U.S. Treasury umbrella are the:
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U.S. Securities and Exchange Commission (SEC) | The SEC is the U.S. government agency in charge of the nation's securities industry. It monitors transactions, as well as the activities of financial professionals. Its mission is to promote fairness, integrity, and transparency; prevent fraud and other deceptive acts, and ensure orderly and efficient markets. |
Financial Industry Regulatory Authority (FINRA) | FINRA is an independent, nongovernmental organization that writes and enforces the rules governing registered brokers and broker-dealer firms in the United States. Its stated mission is “to safeguard the investing public against fraud and bad practices.” It is considered a self-regulatory organization. |
Consumer Financial Protection Bureau (CFPB) | The CFPB is a regulatory agency charged with overseeing financial products and services that are offered to consumers. |
Commodity Futures Trading Commission (CFTC) | The CFTC regulates the derivatives markets, including futures contracts, options, and swaps. Its goals include the promotion of competitive and efficient markets and the protection of investors against manipulation, abusive trade practices, and fraud. |
Federal Reserve System (The Fed) | The Fed is the central banking system of the United States and oversees the 12 regional Federal Reserve Banks. Its primary goals are to regulate the nation's private banks and manage the overall money supply. The Fed ensures lenders and borrowers have access to credit and loans. |
Federal Deposit Insurance Corporation (FDIC) | The FDIC maintains stability and public confidence in the nation’s financial system by insuring deposits; examining and supervising financial institutions for safety, soundness, and consumer protection; making large and complex financial institutions resolvable; and managing receivership. |
Office of the Comptroller of the Currency (OCC) | The OCC is an organization that acts as both the issuer and guarantor for options and futures contracts and is the largest equity derivatives clearing organization in the world. |
National Association of Insurance Commissioners (NAIC) | NAIC is a nonprofit, nonpartisan organization that sets standards and establishes best practices for the U.S. insurance industry, and provides support to insurance regulators. It also provides information and resources to consumers. Note: Insurance products sold in the U.S. are largely regulated by the states, rather than the federal government. |
National Credit Union Administration (NCUA) | The NCUA monitors federal credit unions across the country and provides the National Credit Union Share Insurance Fund (NCUSIF) which uses tax dollars to insure the deposits at all federal credit unions. |
Federal Emergency Management Agency (FEMA) | FEMA is a United States government agency with the purpose to coordinate aid and respond to disasters around the nation when local resources are insufficient. Commanding a budget of approximately $14 billion annually, the agency is headquartered in Washington, D.C. |
Department of Justice (DoJ) | The U.S. DOJ enforces U.S. law through its agencies and protects the public from foreign and domestic threats such as terrorism and criminal activities. The department also investigates financial fraud and manages the federal prison system. The DOJ also represents the country in legal affairs, such as in cases before the Supreme Court. The DOJ shares security responsibilities with the U.S. Department of Homeland Security (DHS) and the U.S. Department of Health and Human Services (HHS). |
Federal Bureau of Investigation (FBI) | The FBI is the principal law enforcement agency and national security service of the federal government. The FBI is housed under the Department of Justice and additionally reports to the Director of National Intelligence. As a law enforcement agency, the FBI investigates an array of federal crimes, including public corruption, terrorism, cybercrime, civil rights violations, drug trafficking, sex trafficking, and white-collar crime. As a national security service, the FBI conducts counterintelligence to prevent espionage. |
Drug Enforcement Administration (DEA) | DEA enforces the provisions of the controlled substances and chemical diversion and trafficking laws and regulations of the United States, and operates on a worldwide basis. It presents cases to the criminal and civil justice systems of the United States–or any other competent jurisdiction–on those significant organizations and their members involved in the cultivation, production, smuggling, distribution, laundering of proceeds, or diversion of controlled substances appearing in or destined for illegal traffic in the United States. |
Table 4 provides a list of authorities that are not within the U.S. and have oversight over financial services. Each of the Countries that the organization is associated with is provided in the first column. A few organizations are umbrella organizations covering several countries and are declared international
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There are at least 18 non-U.S. Federal Government Authorities with financial oversight.
Country | Authority | Description |
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United Kingdom | Bank of England (BoE) | The BoE is the central bank for the United Kingdom. It acts as the government's bank and the lender of last resort. The BoE issues currency and, most importantly, oversees monetary policy. |
Prudential Regulation Authority (PRA) | The PRA is a part of the Bank of England and is responsible for the prudent regulation and supervision of banks, building societies, credit unions, insurers, and major investment firms. It sets standards and supervises financial institutions at the level of the individual firm. |
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Financial Conduct Authority (FCA) | The FCA works alongside the Prudential Regulation Authority (PRA) in regulating the financial services industry in the UK and is responsible for the prudential regulation of those financial services firms not supervised by the PRA such as asset managers and independent financial advisers. The FCA has “rule-making, investigative and enforcement powers” to regulate the financial services industry. |
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Japan | Financial Services Agency (FSA) | The FSA is the chief regulator of Japan’s financial services industry, responsible for maintaining its stability and integrity, and is mandated to oversee the banking, insurance and securities, and exchange industries. It’s also charged with protecting market participants from fraud and money laundering. |
Germany | Federal Financial Supervisory Authority (BaFin) | BaFin integrates the regulatory functions of those agencies with authority over Germany’s banks, financial services companies, insurance companies, stock exchanges, and other obligated institutions. An important part of BaFin’s role as regulator is to identify and eliminate financial crime – a function that includes promoting anti-money laundering in Germany, and counter-terrorist financing. |
France | Autorité des marchés financiers (AMF) | AMF is an independent body that supervises financial companies operating in France with three core responsibilities:
It is also charged with keeping the nation’s markets and financial services industry free of fraud and money laundering. Additionally, France’s AMF is a rules-setter and is responsible for implementing the EU’s 2018 Markets in Financial Instruments Directive II (MiFID II) directive as well as its own General Regulation. |
Singapore | Monetary Authority of Singapore (MAS) | The MAS is empowered by the Monetary Authority of Singapore Act to set regulations and supervise the city’s banking, capital markets, insurance, and payments sectors. The organization enforces its regulations and government laws through legally binding instructions called Directions. They may take the form of Directives, which are issued to specific entities or individuals, and Notices, which cover a class of asset, institution, or person, such as loans or loan issuers. |
Switzerland | Financial Market Supervisory Authority (FINMA) | FINMA is Switzerland’s independent financial-markets regulator. Its mandate is to supervise banks, insurance companies, financial institutions, collective investment schemes, and their asset managers and fund management companies. It also regulates insurance intermediaries. It is charged with protecting creditors, investors, and policyholders. FINMA is responsible for ensuring that Switzerland’s financial markets function effectively. |
People's Republic of China | China Banking Regulatory Commission (CBRC) | The CBRC is authorized by the State Council to regulate the banking sector of the PRC except for the territories of Hong Kong and Macau, both of which are special administrative regions. |
China Insurance Regulatory Commission (CIRC) | CIRC is used to regulate the Chinese insurance products and services market and maintain legal and stable operations of the insurance industry. In 2018, it was merged with the banking regulator China Banking Regulatory Commission (CBRC) to create the China Banking and Insurance Regulatory Commission (CBIRC). |
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China Securities Regulatory Commission (CSRC) | The CSRC is the national regulatory body that oversees the securities and futures industry of the country. The CSRC is the functional equivalent of the Securities and Exchange Commission (SEC) of the U.S., charged with maintaining orderly and fair markets. |
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India | Reserve Bank of India (RBI) | The RBI is the central bank of India, whose primary function is to manage and govern the financial system of the country, and it regulates the issue and supply of the Indian rupee. Additionally, it looks after the central government’s money and is the of the bankers’ bank and regulates the banking sector. The RBI is important in India’s development by supporting the government in its developmental projects and policies. |
Securities and Exchange Board of India (SEBI) | The SEBI is the most important regulator of securities markets in India and is the counterpart of the Securities and Exchange Commission (SEC) in the U.S. The stated objective of the SEBI is “to protect the interests of investors in securities and to promote the development of, and to regulate the securities market and for matters connected therewith or incidental thereto.” |
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Insolvency and Bankruptcy Board of India (IBBI) | IBBI is a key pillar of the ecosystem responsible for the implementation of the Code that consolidates and amends the laws relating to reorganization and insolvency resolution of corporate persons, partnership firms, and individuals in a time-bound manner for maximization of the value of assets of such persons, to promote entrepreneurship, availability of credit and balance the interests of all the stakeholders. |
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Insurance Regulatory and Development Authority of India (IRDAI) | The IRDAI has overall responsibility for the supervision and development of the Insurance sector in India. The key objectives of the IRDAI include the promotion of competition to enhance customer satisfaction through increased consumer choice and fair premiums and ensuring the financial security of the Insurance market. Additionally, the IRDAI frames regulations laying down the regulatory framework for the supervision of the entities operating in the sector. |
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Pension Fund Regulatory and Development Authority (PFRDA) | PFRDA regulates the National Pension System (NPS), subscribed by employees of the Government of India, Indian State Governments, and by employees of private institutions, organizations, and unorganized sectors. PFRDA ensures the orderly growth and development of the pension market. |
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International | Financial Action Task Force (FATF) | The FATF is an intergovernmental organization that develops standards around Anti Money Laundering (AML) to promotes policies and standards to combat the financial crime of money laundering and terrorism funding. Additionally, FATF produces two lists of uncooperative jurisdictions in efforts against money laundering (and terrorism financing). |
International | Markets in Financial Instruments Directive II (MiFID II) | The EU's MiFID II is a 2018 update to the original Markets in Financial Instruments Directive (MiFID) and is a legislative framework instituted by the European Union (EU) to regulate financial markets in the bloc and improve protections for investors. Its aim is to standardize practices across the EU and restore confidence in the industry |
International | The World Bank Group | The World Bank Group (also known as World Bank) is one of the world’s largest sources of funding and knowledge for developing countries. Its five institutions share a commitment to reducing poverty, increasing shared prosperity, and promoting sustainable development. |
Some of the “desirements” in the Money and Payments: The U.S. Dollar in the Age of Digital Transformation White Paper relating to Central Bank Digital Currency (CBDC) Stakeholders are summarized in the White Paper Analysis done by the Object Management Group's CBDC WG and listed in Table 5.
Category | Desirements |
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Benefits | B0006, B0009, B0015, B0020, B0026, B0029, B0035, B0038, B0041, B0043, B0045, B0046, B0052, B0053 |
Policy Considerations | P0006, P0011, P0017, P0020, P0021, P0023, P0025, P0028, P0031 |
Risks | R0001, R0005, R0018, R0020, R0021, R0023 |
Design | D0010, D0011, D0012, D0013, D0014, D0015, D0016, D0017 |
Table 6 provides a comment for those “desirements” identified by the in White Paper and identified by the OMG's White Paper Analysis relating to Central Bank Digital Currency (CBDC) Stakeholders. See: Table 5.
Desirement No. | Desirement Text | Comment |
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B0006 | Provide broad support from key stakeholders | This is the reason to include this section in a CBDC effort. |
B0009 | Provide faster and cheaper payments (including cross-border payments) | This requires the CBDC to have interaction with Authorities from U.S. Federal Government Oversight Authorities and non-U.S. Federal Government Oversight Authorities, making them Stakeholders. |
B0015 | Reduce cross-border costs to benefit:
|
See |
B0020 | Maintain public confidence by not requiring mechanisms, such as deposit insurance | In order to instill public confidence in a CBDC, the public needs to be included as Stakeholders. |
B0026 | Provide a bridge between legacy and new payment services | In order to successfully bridge between the legacy and new payment services, the CBDC needs to work with existing U.S. Federal Government Oversight Authorities as Stakeholders. |
B0029 | Support basic purchases of:
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B0035 | Streamline cross-border payments by using:
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B0037 | Support private-sector innovation | Requires the inclusion of the new and emerging technology business areas (i.e., Stablecoins, Blockchains, DIDOs, etc. ) as Stakeholders |
B0038 | Allow private-sector innovators to focus on:
| Requires all the private-sector innovators to participate as Stakeholders |
B0041 | Support streamlining cross-border payments |
See |
B0043 | Promoting financial inclusion—particularly for economically vulnerable households and communities | This would require U.S. Government Departments and Agencies with a Charter to help the economically vulnerable be considered Stakeholders. For Example, see: U.S. Gov.
It might also require the inclusion of Social Security and Medicare.
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B0045 | Enable rapid and cost-effective payment of taxes | This should require the inclusion of the U.S. Treasuries Internal Revenue Service (IRS) as a Stakeholder. |
B0046 | Enable rapid and cost-effective delivery of:
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B0051 | Generate data about users’ financial transactions similarly to current Commercial Bank2) and Nonbank Money | |
B0052 | Prevent Financial money laundering crimes | This would require U.S. Federal Government Oversight Authorities as Stakeholders. |
B0053 | Provide resiliency to threats to existing payment services—including:
| Federal Emergency Management Agency (FEMA) is the agency that provides most of the relief and coordination during Natural Disasters making them a Shareholder in a CBDC. |
P0006 | Garner broad support from key stakeholders | This is the reason to include this section in a CBDC effort. |
P0011 | The Federal Reserve does not intend to proceed with the issuance of a CBDC without clear support from the Executive Branch and Legislative Branch, ideally in the form of a specific authorizing law. | This makes the Executive Branch and the Legislative Branch Stakeholders in the CBDC. |
P0017 | The PWG report recommends CBDC complement existing authorities regarding:
| This would require U.S. Federal Government Oversight Authorities as Stakeholders |
P0020 | The private sector would offer accounts or digital wallets to facilitate the management of CBDC holdings and payments | This includes both the current Intermediaries and Entrepreneurs to be included as Stakeholders. |
P0021 | The intermediaries would operate in an open market for CBDC services | To create an open market, the intermediaries would have to publish and adhere to standards. This would mean one or more Standards Developing Organization (SDO) need to be included as Stakeholders. |
P0023 | CBDC would need to be readily transferable between customers of different intermediaries |
See: |
P0025 | CBDC intermediary would need to verify the identity of a person accessing CBDC | This includes the current Intermediaries as Stakeholders |
P0028 | Require significant international coordination to address issues such as:
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P0031 | The Federal Reserve would only pursue a CBDC in the context of broad public and cross-governmental support | This requires a broad Stakeholder Base to participate in a transparent CBDC consortium that has policies and procedures that are well documented, fair and equitable. |
R0001 | Risk of affecting financial-sector market structure | This includes the current Intermediaries as Stakeholders. |
R0005 | New payment services could pose Risks to:
| This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
R0018 | Risk a CBDC could fundamentally change the structure of the U.S. financial system, altering private sector and central bank:
| This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
R0020 | Risk that interest-bearing CBDC could result in a shift away from other low-risk assets, such as shares in money market mutual funds, Treasury bills, and other short-term instruments. | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
R0021 | Risk of reducing credit availability or raise credit costs for businesses and governments | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
R0023 | Risk of financial panic causing outflows from Commercial Banks to CBDC without prudential supervision, government deposit insurance, and access to central bank liquidity | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0001 | Design should be for a non-interest-bearing CBDC, for example, would be less attractive as a substitute for commercial bank money | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0004 | Design should influence how the Federal Reserve might affect monetary policy | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0005 | Design could affect monetary policy implementation and interest rate control by altering the supply of reserves in the banking system | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0009 | Design should allow for significant foreign demand for CBDC, furthering complicate monetary policy implementation |
See: |
D0010 | Design should consider the potential for interest-bearing CBDC as a new policy tool on the channels of influence in monetary policy | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0011 | Design should generate data about users’ financial transactions in the same ways that commercial bank and nonbank money generates data today | |
D0012 | Design should address privacy concerns by leveraging existing tools already in use by intermediaries | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0013 | Design should facilitate compliance with a robust set of rules already intended to combat
| This requires the continued coordinated efforts of the U.S. Federal Government Oversight Authorities as Stakeholders. |
D0014 | Design should involve private-sector partners with established programs to help ensure compliance with existing rules | This includes the current Intermediaries as Stakeholders. |
D0015 | Design should include any dedicated infrastructure required to provide a resilience to threats such as operational disruptions and cybersecurity risks | This includes the current Intermediaries and U.S. Federal Government Oversight Authorities as Stakeholders. |
D0016 | Design should include offline capabilities to help with operational resilience of the payment system | Federal Emergency Management Agency (FEMA) is the agency that provides most of the relief and coordination during Natural Disasters making them a Shareholder in a CBDC. |
D0017 | Design should include digital payments in areas suffering from large disruption, such as natural disasters | Federal Emergency Management Agency (FEMA) is the agency that provides most of the relief and coordination during Natural Disasters making them a Shareholder in a CBDC. |