How might a U.S. CBDC affect the Federal Reserve’s ability to effectively implement monetary policy in the pursuit of its maximum employment and price stability goals?
In order to answer this question, it is important to have some definitions that relate to Federal Reserve’s ability to effectively implement monetary policy. Based on these definitions explore “What is the Federal Reserves Monetary Policy”, and finally focus on non-Cash payments and how they relate to CBDC.
The Federal Reserve has defined the following terms:1)
Discount Rate | The Discount Rate is the interest rate charged by Federal Reserve Banks to depository institutions on short-term loans. |
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Federal Open Market Committee (FOMC) | The Federal Open Market Committee (FOMC) formulates the nation’s Monetary Policy. The voting members of the FOMC consist of the seven members of the Board of Governors (BOG), the president of the Federal Reserve Bank of New York, and presidents of four other Reserve Banks who serve on a one-year rotating basis. All Reserve Bank presidents participate in FOMC policy discussions whether or not they are voting members. The chairman of the Board of Governors chairs the FOMC meeting. The FOMC typically meets eight times a year in Washington, D.C. At each meeting, the committee discusses the outlook for the U.S. economy and monetary policy options. |
Federal Reserve Funds | Federal Reserve Funds are the overnight lending rate at which banks borrow reserves from each other. The Federal Funds Rate is sensitive to changes in the demand for and supply of reserves in the banking system and thus provides a good indication of the availability of credit in the economy. |
Monetary Policy Instruments | The Federal Reserve’s three Monetary Policy Instruments are Open Market Operations, the Discount Rate, and Reserve Requirements. |
Inflation | Inflation is a sustained increase in the general level of prices, which is equivalent to a decline in the value or purchasing power of money. If the supply of money and credit increases too rapidly over time, the result could be inflation. |
Monetary Policy | Monetary Policy refers to what the Federal Reserve, the nation's central bank, does to influence the amount of money and credit in the U.S. economy. What happens to money and credit affects interest rates (the cost of credit) and the performance of the U.S. economy. |
Open Market | Open Market means that the Fed doesn’t decide on its own which securities dealers it will do business with on a particular day. Rather, the choice emerges from an “open market” in which the various securities dealers that the Fed does business with – the primary dealers – compete on the basis of price. |
Open Market Operations | Open Market Operations involve the buying and selling of government securities. The term Open Market means that the Fed doesn’t decide on its own which securities dealers it will do business with on a particular day. Rather, the choice emerges from an “open market” in which the various securities dealers the Fed does business with – the primary dealers – compete on the basis of price. Open Market Operations are flexible, and thus, the most frequently used tool of monetary policy. |
Reserve Balances | Reserve Balances with Federal Reserve Banks is the amount of money that depository institutions maintain in their accounts at their regional Federal Reserve Banks. |
Figure 1 illustrates the transmission of monetary policy. In the broadest terms, monetary policy works by spurring or restraining the growth of overall demand for goods and services in the economy. When overall demand slows relative to the economy's capacity to produce goods and services, unemployment tends to rise and inflation tends to decline. The FOMC helps stabilize the economy in the face of these developments through the stimulation of the overall demand using an easing of monetary policy that lowers interest rates. Conversely, when overall demand for goods and services is too strong, unemployment can fall to unsustainably low levels and inflation can rise. In these situations, the Federal Reserve guides economic activity back to more sustainable levels and keeps inflation in check by tightening monetary policy to raise interest rates. This process of the FOMC eases and tightens monetary policy to achieve its goals. 2)
On average, each day, U.S. consumers and businesses make noncash payments worth roughly \$1/2 trillion currently using payments through:
Note: There is currently no tally for cryptocurrency payments.
To facilitate non-cash payments, intermediary banks hold Reserve Balances at the Federal Reserve. Payments are generally settled by transferring Reserve Balances between banks. Banks can also hold these balances to meet unexpected liquidity needs and to satisfy a number of regulatory requirements aimed at ensuring that banks are sound and that their customers' deposits are safe. Banks depend upon this borrowed money to a considerable extent in order to meet strict compliance requirements and pass stress tests used as the measurement of their financial stability. 4)
Banks may borrow and lend reserves to each other depending on their needs and market conditions; as such, banks can use Reserve Balances both as a means of funding and as an investment. The federal funds rate is the interest rate that banks pay to borrow Reserve Balances overnight.
When a CBDC is created and goes public, CBDC payments will have to be added as a new way of making noncash payments. This means in order to obtain a better understanding of the banks' reserve currency requirements, all the CBDC payments in the bank need to be accounted for. In other words, these CBDC payments need to be added to the total tally of U.S. consumers' and businesses' noncash payments. This requires the CBDC to adopt a Digital Account Model leading to concerns about End User Privacy.
To facilitate such payments, banks hold Reserve Balances at the Fed; payments can be settled by transferring Reserve Balances between banks. Banks also hold these balances to meet unexpected liquidity needs and to satisfy a number of regulatory requirements aimed at ensuring that banks are sound and that their customers' deposits are safe. Banks may borrow and lend reserves to each other depending on their needs and market conditions; as such, banks can use Reserve Balances both as a means of funding and as an investment. The federal funds rate is the interest rate that banks pay to borrow Reserve Balances overnight.
The following “desirements” are from the White Paper as identified by the Object Management Group's CBDC WG report called White Paper Analysis:
Benefits | B0003, B0004, B0007, B0011, B0018, B0020, B0024, B0025,B0026, B0029, B0034, B0038, B0040, B0044, B0045, B0046, B0047, B0049, B0051 |
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Policies | P0003, P0004, P0012, P0018, P0019, P0020, P0021, P0023, P0024, P0025, P0026 |
Risks | R0001, R0004 |
Design | D0004, D0005, D0009, P0010, P0018 |
Statement No. | Statement | Comment |
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B0003 | Complement, rather than replace, current forms of money and methods for providing financial services | The Cryptocurrencies and the CBDC need to be added to the tally of payments made by the intermediary banks in order for the Federal Reserve to calculate a correct Reserve Balance each bank needs to maintain overnight. So far, the Cryptocurrency payments have not had much of an impact on this calculation, but it is a matter of time before it does start having an impact. The adoption of a U.S. CBDC will definitely have an impact. |
B0004 | Protect consumer privacy | There is a fine line between collecting information about consumer transactions used to calculate the Reserve Balance for each bank and transgressing the required privacy requirements. See section 4.4 National Privacy Considerations. |
B0007 | Provide households and businesses a convenient and electronic form of central bank money with:
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See |
B0011 | Make payments:
| CBDC payments would be similar to the current non-cash payments done with debit cards, credit cards, electronic transfers, and checks. This has to be reported in order for the banks to calculate the Reserve Balance required by the Federal Reserve to banks. There is no reason that U.S. CBDC could not be treated similarly. |
B0018 | Allow the general public to make digital payments | The general public can already make digital payments using non-cash mechanisms such as debit cards, credit cards, electronic transfers, and checks |
B0020 | Maintain public confidence by not requiring mechanisms, such as deposit insurance | If the CBDC is treated like other non-cash mechanisms such as debit cards, credit cards, electronic transfers, and checks, there should be no reason to have an extra layer of protective insurance for CBDC. |
B0024 | Provide transactions finalized and completed in real-time |
Thes transactions should be treated similarly to non-cash mechanisms such as debit cards, credit cards, electronic transfers, and checks. However, if a Stablecoin is used, then the transactions might be settled within minutes depending on the Consensus Algorithm used in the Stablecoin. See OMG DIDO-RA Consensus Algorithms), answer to |
B0025 | Serve as a new foundation for the payment system | The CBDC could offer another mechanism to the existing non-cash mechanisms such as debit cards, credit cards, electronic transfers, and checks. However, in order to offer real-time settlements, it may need to use a different mechanism than the existing Automated Clearing House (ACH) Network currently in use to electronically move money between banks accounts across the U.S. The current ACH network is run by an organization called Nacha, formerly the National Automated Clearing House Association (NACHA). |
B0026 | Provide a bridge between legacy and new payment services | There definitely would need to be a bridge between the existing ACH-NACHA payment network and a U.S. CBDC, its associated Consensus Algorithms, and the network of nodes. However, in addition to the bridge between the two, there probably needs to exist a new consolidated frontend ( Application Programming Interface (API)?) that abstracts the type of payment from the participants in the transactions. In other words, the transaction should be agnostic to non-cash mechanisms such as debit cards, credit cards, electronic transfers, checks, and CBDC. |
B0029 | Support basic purchases of:
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See the answer to |
B0034 | Generate new capabilities to meet the speed and efficiency requirements of the digital economy |
See answers to |
B0038 | Allow private-sector innovators to focus on:
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By defining a new standardized Application Programming Interface (API) as in |
B0040 | Provide micropayment support | This is currently almost impossible with Credit and Debit cards because the cost of a transaction is so high that a vendor might lose money supporting small payments, let alone micropayments. A parallel network used by the CBDC might alleviate this problem depending on the Consensus Algorithm used by the U.S. CBDC. As an example:
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 permits businesses to impose a minimum purchase amount of up to \$10 for credit card use, but the minimum must be the same for all credit card issuers and payment card networks. Part of this legislation, the Durbin Amendment, contains the following provision:
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B0044 | Facilitate access to digital payments |
See answers to |
B0045 | Enable rapid and cost-effective payment of taxes | Sales taxes are already collected by the merchant at the point of sale. The Internal Revenue Service (IRS) uses third-party payment processors for payments by debit and credit card. It's safe and secure; your information is used solely to process your payment. 6)
Each state and local jurisdiction has different rules. |
B0046 | Enable rapid and cost-effective delivery of:
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See answer |
B0047 | Lower transaction costs |
See answer |
B0049 | Promote access to credit |
See answer |
B0051 | Generate data about users’ financial transactions similar to the current Commercial Bank7) and Nonbank Money | |
P0003 | Complement current forms of money and methods for providing financial services |
See answer |
P0004 | Protect consumer privacy |
See answer |
P0012 | The firms that operate interbank payment services are subject to federal supervision | Regardless of how the U.S. CBDC is implemented, for example Stablecoin, the Consensus Algorithms need to include all the rules outlined in sections 4.4 National Privacy Considerations, 4.5 National Security Considerations, and 4.6 International Considerations. In other words, consensus includes the enforcement of the laws and regulations concerning Monetary Policy. |
P0018 | The Federal Reserve Act does not authorize direct Federal Reserve accounts for individuals | The easiest solution is to allow current intermediaries to process CBDC transactions using an upgraded payment system.
See answer |
P0019 | Federal Reserve accounts for individuals represent a significant expansion of the Federal Reserve’s role in the financial system and the economy | The easiest solution is to allow current intermediaries to process CBDC transactions using an upgraded payment system.
See answer |
P0020 | The private sector would offer accounts or digital wallets to facilitate the management of CBDC holdings and payments |
See answer |
P0021 | The intermediaries would operate in an open market for CBDC services |
See answer |
P0023 | CBDC would need to be readily transferable between customers of different intermediaries | This would require standardization ( Application Programming Interface (API)?) that each intermediary would use to transfer money. The interface could be in the form of Web Services, Remote Procedure Calls (RPC), Common Object Request Broker Architecture (CORBA), Data Distribution Service (DDS) or other interprocess communication mechanisms defined using ISO/OMG Interface Definition Language (IDL), Web Services Interface Language (WSDL), etc. |
P0024 | CBDC would need to comply with the U.S. robust rules |
See answer to |
P0025 | CBDC intermediary would need to verify the identity of a person accessing CBDC | The Federal Open Market Committee (FOMC) is interested in the Reserve Balances of financial institutions within the U.S. There, if the transaction has one end of the transaction as a U.S. institution, then the ID of the individuals in the transaction is required. |
P0026 | CBDC transactions would need to be final and completed in real-time |
See answers to |
B0013 | Provide immediate access to transferred funds |
See answers to |
R0001 | Risk of affecting financial-sector market structure |
See answers to |
R0004 | Risk to the efficacy of monetary policy |
See answer to |
D0004 | Design should influence how the Federal Reserve might affect monetary policy |
See answer |
D0005 | Design could affect monetary policy implementation and interest rate control by altering the supply of reserves in the banking system | From a Monetary Policy perspective, only the Reserve Balances is important. As long as the Reserve Balances account for Cryptocurrency and U.S. CBDC balances there should be little impact on the Monetary Policy. |
D0009 | Design should allow for significant foreign demand for CBDC, further complicating monetary policy implementation | The only reason to use the U.S. CBDC Stablecoin over U.S. Dollars is the potential for faster transactions using the CBDC transactions than in traditional ACH transactions. This would mean that before a transaction is to begin, the money in U.S. Dollars (or other currency) would be transferred to U.S. Stablecoins and the transaction would be conducted in Stablecoins. Once the transaction is completed, the Stablecoins could be changed quickly for U.S. Dollars. The only reason to hold onto the Stablecoins is to conduct more transactions using the Stablecoin network. |
D0010 | Design should consider the potential for interest-bearing CBDC as a new policy tool on the channels of influence in monetary policy | This would vary greatly from the current way the Credit Cards, Debit Cards, and Checks currently work. These are backed by accounts that can receive interest. For example, debit cards and checking accounts can pay interest on positive balances. These checking accounts cond maintain separate balances for U.S. Dollars and for Stablecoins. But since Stablecoins would be backed by U.S. Dollars anyway, it seems a bit of a moot point unless the value of the U.S. Dollar and the U.S. Stablecoins are allowed to diverge. |
R0018 | Risk a CBDC could fundamentally change the structure of the U.S. financial system, altering the private sector and central bank:
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See answers to |
B = Benefit Considerations |
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P = Policy Considerations |
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R = Risk Considerations |
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D = Design Considerations |