Treasury Opens Public Comment on Cryptocurrency Report

July 21, 2022

The Department of Treasury on July 8 announced it is requesting public input on a report that will cover the pros and cons of digital asset adoption. The request for comment kicks off work following President Joe Biden’s executive order earlier this year.

“For consumers, digital assets may present potential benefits, such as faster payments, as well as potential risks, including risks related to frauds and scams,” Undersecretary of the Treasury for Domestic Finance Nellie Liang said.

The Department of Treasury invites input, data and recommendations pertaining to the implications and development and adoption of digital assets and changes in financial markets and payment infrastructures.

Comments must be received on or before Aug. 8, 2022.

The Treasury encourages commentators to address any or all of the following questions, or to provide any other comments relevant to the development of the report. When responding to one or more of the questions below, please note in your response the number(s) of the questions to which you are responding. In all cases, to the extent possible, please cite any public data related to or that support your responses. If data are available, but non-public, describe such data to the extent permissible.

Adoption to Date and Mass Adoption

What explains the level of current adoption of digital assets? Please identify key trends and reasons why digital assets have gained popularity and increased adoption in recent years. In your responses, please address the following:

  • Who are the users, consumers, and investors that are adopting digital assets? What is the geographic composition and demographic profile of consumers and investors in digital assets?
  • What businesses are adopting digital assets and for what purposes?
  • What are the main use cases for digital assets for consumers, investors, and businesses?
  • What are the implications for equitable economic growth?

Factors that would further facilitate mass adoption

  • Describe a set of conditions or pre-conditions that would facilitate mass adoption of digital assets in the future. To the extent possible, please cite any public data related to the responses above.
  • What developments in technology, products, services, or markets account for the current adoption of digital assets? Are there specific statutory, technology, or infrastructural developments that would facilitate further adoption?
Opportunities for Consumers, Investors, and Businesses

What are the main opportunities for consumers, investors, and businesses from digital assets? For all opportunities described, please provide data and specific use cases to date (if any). In your responses, please consider:

  • Potential benefits of decentralized and disintermediated systems
  • Creation of new types of financial products and contracts
  • Potential for improved access to and greater ease of use of financial products
  • Potential opportunities for building wealth
  • Potential benefits of interacting with counterparties, suppliers, vendors, and customers directly
  • Potential for improved cross-border payments and trade finance
General Risks in Digital Assets Financial Markets

Please identify and describe any risks arising from current market conditions in digital assets and any potential mitigating factors. Identify any such responses that directly relate to:

  • Market transparency, including pre- and post-trade transparency
  • Accuracy and reliability of market data
  • Technological risks, including attacks, bugs, and network congestion
  • Smart contract design and security
  • Settlement and custody
  • Jurisdictional and legal conditions
Risks to Consumers, Investors, and Businesses

Please identify and describe potential risks to consumers, investors, and businesses that may arise through engagement with digital assets. Identify any such responses that directly relate to:

  • Frauds and scams
  • Losses due to theft
  • Losses of private keys
  • Losses from the failure/insolvency of wallets, custodians, or other intermediaries
  • Potential losses associated with interacting with counterparties directly
  • Disclosures and amount of fees
  • Disclosures of other relevant terms
  • Authenticity of digital assets, including NFTs
  • Ability of consumers, investors, and businesses to understand contracts, coding, protocols
Impact on the Most Vulnerable

According to the FDIC's 2019 “How America Banks” survey, approximately 94.6 percent (124 million) of U.S. households had at least one bank or credit union account in 2019, while 5.4 percent (7.1 million) of households did not. And roughly 25 percent of U.S. households have a checking or savings account while also using alternative financial services. Can digital assets play a role in increasing these and other underserved Americans' access to safe, affordable, and reliable financial services, and if so, how?


Contact ALTA at 202-296-3671 or [email protected].