May 20, 2022

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, D.C. 20551

Submitted via email. Appendix also submitted via: https://www.federalreserve.gov/apps/forms/cbdc

Re: Money and Payments: The U.S. Dollar in the Age of Digital Transformation Discussion Paper on a Potential U.S. Central Bank Digital Currency (CBDC)

Dear Ms. Misback,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to respond to the recent discussion paper published by the Board of Governors of the Federal Reserve System (hereafter “the Board”) entitled “The U.S. Dollar in the Age of Digital Transform,” which discusses issues related to the potential introduction of a U.S. central bank digital currency (“CBDC”).2

We welcome the Board’s decision to publish this document, which is an important “first step in a public discussion” on whether to adopt a U.S. CBDC. We also welcome the President’s recent Executive Order on Digital Assets which, among other things, calls for the U.S. Treasury to produce its own report on this subject3. Both the Board’s discussion paper and the forthcoming reports from the administration will help

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 on 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.

2 Board of Governors of the Federal Reserve System, “Money and Payments: The U.S. Dollar in the Age of Digital Transformation,” January 2022 (hereafter “Federal Reserve discussion paper”). Available at: Money and Payments: The U.S. Dollar in the Age of Digital Transformation (federalreserve.gov).
3 The White House, “Executive Order on Ensuring Responsible Development of Digital Assets,” March 9, 2022 (hereafter “Executive Order on Digital Assets”). Available at: Executive Order on Ensuring Responsible Development of Digital Assets | The White House.