September 20, 2021

Secretariat of the Basel Committee on Banking Supervision
Bank for International Settlements
Centralbahnplatz 2
CH-4002 Basel
Switzerland

Re: Comments in Response to the Consultative Document on the Prudential Treatment of Cryptoasset Exposures

Ladies and Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”) 1 appreciates the opportunity to respond to the Basel Committee on Banking Supervision’s (“Basel Committee”) consultative document on the “Prudential treatment of cryptoasset exposures” (the “consultation”). As the U.S. regional member of the Global Financial Markets Association, we have joined with the Chamber of Digital Commerce, the Financial Services Forum, the Futures Industry Association, the Institute of International Finance and the International Swaps and Derivatives Association in a more detailed joint letter (the “Joint Trade Letter”).

We fully agree with and support all of the comments in that letter. We write separately to underscore the need and urgency for regulators to develop in the near term a clear regulatory framework for cryptoasset markets that strikes the right balance among innovation, growth and regulatory conservatism. We believe regulatory coordination—not only among prudential regulators but also between prudential and market regulators—is necessary to achieve this balance, to minimize market fragmentation and to help ensure bank uptake and competitive equity across the financial services marketplace. Ultimately, a properly balanced framework will help to ensure the capital markets will be able to continue to serve the needs of businesses and households as efficiently and comprehensively as possible.

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry
coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).