ARTICLE
20 May 2021

FDIC Seeks Comment On Digital Asset Use By Banks

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The FDIC requested information and comment concerning existing and potential digital asset use by insured depository institutions ("IDIs").
United States Technology

The FDIC requested information and comment concerning existing and potential digital asset use by insured depository institutions ("IDIs").

The FDIC is seeking comment on:

  • the scope of IDIs' engagement with digital assets and whether such involvement extends beyond activities involving (i) technology solutions, such as closed and open payment systems, (ii) assets, such as investments and collateral, (iii) liabilities, such as deposit services and (iv) custody, such as safekeeping services;
  • whether IDIs have risk and compliance management procedures specific to digital assets;
  • the operational benefits IDIs consider when assessing digital asset use cases;
  • how IDIs are integrating digital assets operations with legacy banking systems;
  • possible benefits or specific risks associated with digital asset product offerings or services to customers;
  • how IDIs are including digital asset technologies into their cybersecurity procedures;
  • whether the FDIC should clarify or expand its supervisory guidance to take digital asset activities into consideration; and
  • whether the FDIC should take action to ensure that customers can identify whether a digital asset product is insured or uninsured.

Comments are due by July 16, 2021.

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