SIFMA: if any CBDC, policymakers should focus on wholesale, not retail

SIFMA Responds to Federal Reserve Paper on Central Bank Digital Currencies

SIFMA believes, if policymakers were to move forward with CBDC adoption at some future point, the primary focus should be on “limited purpose” or “wholesale” CBDC (wCBDC) which would be used for institutional financial transactions rather than a more widely available public “retail” CBDC (rCBDC), at least initially. This would allow further time to consider and evaluate the risks that a more widely available rCBDC may present. A wCBDC would be less disruptive to the financial system and financial stability than a rCBDC; it would provide a testing ground for experimentation of key systems amongst a small group of sophisticated and established financial actors; and has more proven and obvious use cases than a rCBDC. A wCBDC would also be less politically fraught, raising fewer concerns around issues such as consumer privacy than a rCBDC. A wCBDC may also be helpful in preserving the U.S. dollar’s status as a reserve currency and as the predominant currency for international financial transactions in a way that a rCBDC would not.

The full comment letter is available at

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