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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

Take On Payments

December 12, 2016


Making Sense of Dollars, Part II

The first of this two-part post took us back to the '60s and a BBC clip that assumed we'd be a cashless society by now, given it was the dawn of the digital age. A half-century later, we're hardly closer to being cashless, and those who predicted an end to cash have been replaced by those who argue that going cashless or to less cash is "for the best." This post recaps oft-cited reasons for abandoning cash, amending them with counterpoints. I trust market determinations more than I do the wisdom of the well-intended, and the free market seems to be in complete disagreement with those who assert we'd all be better off without cash.

  • Cash is expensive as a cost of acceptance for merchants.
    I've talked to many retailers—large and small—who prefer cash because they say it saves them money, especially when compared to credit cards. But what do they know? Many studies show that cash is neither universally nor unanimously the most expensive payment method. Indeed, there seems to be more evidence than not that cash is among the least expensive payment alternatives.
  • Cash makes tax evasion pervasive.
    First, tax evaders have options; cash is not their only tool. Second, tax evasion seems correlated to high taxes (see the National Bureau of Economic Research working papers 6903 and 8551; there are others). Reading further, I find tax evasion is less about opportunity (afforded by cash, for instance) and more about bad tax policy. A revolt was ignited and a great country was born amidst the perception that taxes were too high and unjust. Eliminating cash would not likely have stopped that rebellion, and it's unlikely to fix today's problem.
  • Cash complicates monetary policy.
    Cash can only complicate monetary policy when those making the policy want to use negative interest rates to achieve desired ends. To date, there is little to no evidence that this policy path is effective; certainly it's no panacea. That makes it premature if not fully misguided to decry cash. Even if the policy proves useful, eliminating bills may or may not make it more difficult for savers to hoard. I assert they'll find a way.
  • Cash encourages crime because it's too effective (too liquid, too widely used, "too anonymous").
    By that thinking, once cash is eliminated, we'll need to determine what to do about oxygen and water as there is overwhelming evidence that malefactors use these things to good effect as well. The point is, cash works well for the unjust but also for the just. It accounts for 40 percent of all transactions, as measured by the Boston Fed's survey of consumer payment choice. Here the anti-cash crowd backs off the cry of "cashless," running out a "less cash" compromise. Large notes, some say, are used far more often for illegal activities than not, and the proof seems to be TV shows, movies, and pop culture. Seriously. Don't we have to do better than that before dispensing with a primary bloodline for commerce? There is no denying that the untraceable nature of cash frustrates crime fighting; it also frustrates surveillance against the just. Those who value liberty are likely to continue to value the option to spend anonymously.

There is at least one official push to rid society of cash, and its sponsors include card networks, who would stand to benefit were cash to disappear. Anyway, legislating safety that overpromises and hides the harm it can do holds considerable risk.

Photo of Julius Weyman By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed

December 12, 2016 in currency | Permalink

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December 5, 2016


Making Sense of Dollars, Part I

A 1969 short on the BBC's Tomorrow's World made bold predictions about where computers would take banking. If you haven't seen the clip, I encourage it. It's fascinating, especially if you bear in mind that at the time, computers were still more the stuff of science fiction than reality while banking was staid and stubbornly unchanging. In the barely four minute segment, a card was "dipped" (not to mention authorized with a PIN) and a check was shunned—presuming its disfavor in the face of auto-charging and other electronic payment options. The obsolescence of paper filing systems was projected and branch/conventional banking was guaranteed to diminish if not utterly fade away. Among all the prescient predictions, they tossed in this throwaway: "If cash is to become the first major casualty of the computer revolution,…" Oops.

Amid relentless predictions of its demise, folding money remains. Prognosticators have left off predicting cash's downfall since its resilience has repeatedly put to lie such ideas. Instead, folks have taken to advocating against it. Even there, anti-cash champions seem willing, for now, to settle for us just agreeing to "less cash" rather than forcing us to go "cashless" in a lurch. Listed below are the main arguments of anti-cash advocates:

  • Paper-based transactions are inefficient, making cash expensive as a cost of acceptance for merchants. While I see this argument less often than the others below, it pops up enough to earn a place on the list.
  • Cash makes tax evasion pervasive and simple. For businesses that are cash intensive, it's difficult to verify sales and income. In some of the articles I've read, tax evasion deserves its place among the most heinous of crimes. It's stealing, no arguing about that, but for this post's purpose, the main point is that cash is at the heart of tax evasion…or so I've heard.
  • The latest evil that cash has foisted off on the unsuspecting is it complicates monetary policy. Cutting interest rates below zero is made difficult by the existence of cash because savers can withdraw and hold cash outside of the banking system. This hinders if not fully defeats the purpose of taking interest rates into negative territory.
  • I've saved the biggest for last: cash enables and encourages crime like racketeering, drug and human trafficking, terrorism, to name the headliners. Paper money underpins the vilest criminal enterprises because, among other things, it defines liquidity, is almost universally accepted, and provides absolute anonymity.

So there it is. Case closed, yes? Well, let's not say that quite yet. If you're interested in the other side, you will have to wait until next week's post. I rarely see the counterpoints other than for them to be mentioned and dismissed. Critical thinkers may be interested in seeing both sides before deciding the fate of cash.

Photo of Julius Weyman By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed

December 5, 2016 in currency | Permalink

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November 7, 2016


The Downside of a Wide Paintbrush

Fall is the time of the year that I normally do my exterior home painting and touchup. During the summer, I noticed that my deck and stair metal support poles were a bit dull and had some rust spots, so that was to be my project. The poles have a 4-inch diameter, so I was in a bit of a quandary over the best width paintbrush to use—a 2-inch or a 4-inch. The 4-inch brush would provide faster coverage so my football-game-watching time wouldn't be compromised, but the 2-inch brush would give me greater control and reduce drips and splatters. I went with the expedient choice, and it turned out to be a mistake, as my coverage was uneven with plenty of drips and splatters.

I mention this story because I recently appeared at the National ATM Council's (NAC) annual conference. NAC is an industry trade organization representing nonfinancial-institution ATM owners/operators in the United States. I was asked to speak primarily about the Fed's research into the use of cash as well as the current chip card and terminal deployment status. After my presentation and in the subsequent days of the conference, I was approached by a number of owners/operators telling me that their banks had recently terminated their longstanding relationships; they were deemed to be "high risk" since they were in the currency business. Many were scrambling to establish new banking relationships and wondering why this was happening.

Being an old ATM guy, I was a bit surprised hearing about this action due to the built-in controls on ATM currency settlement and reconciliation that severely limit the ability for an ATM owner/operator to launder money through an ATM. It would be very easy for the bank to spot an imbalance if the money being replenished far exceeded the currency paid out by the ATM. There is still the concern, of course, regarding the initial load (deposit) to establish the account to ensure that those are legitimate funds, but that concern exists with the establishment of all banking relationships by any type of business.

Financial institutions certainly have the obligation to develop a risk management strategy and determine which types of business activities they deem acceptable versus those considered high risk. Supporting ATM operators with their currency needs could be considered a niche business with some unique requirements and may not be the best allocation of resources for all financial institutions. At the same time, bankers may not want to paint a business with the wide brush of "high risk" just because they deal with currency as a major part of their business operation. To do so may force many of these operators to shutter their units, which often are located in areas where there is not a wide choice of ATM locations.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

November 7, 2016 in ATM fraud, banks and banking, currency | Permalink

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Good article, Thank you for your comments.

Chris Waters
National ATM
NAC Board member

Posted by: Chris Waters | November 23, 2016 at 08:49 AM

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July 25, 2016


Cash: Reports of Its Pending Death Are Greatly Exaggerated

I usually chuckle when I read an article forecasting the impending elimination of cash from the U.S. payments system. It seems the frequency of these articles is steadily increasing, and I wonder why. What do these people have against cash? Yes, I can somewhat understand the argument about trying to abolish the penny when it costs more to produce it (1.7 cents) than its face value. Canada, New Zealand and Australia have done so, and their citizens' lives don't seem too dramatically altered.

There is no question that consumers continue to embrace card-based payments as an alternative to cash and checks, none more so than the millennials. Critics of cash portray it as a payment method with a number of negatives including harm to personal safety (robbery) and its being expensive to acquire or process. Yet research by the Federal Reserve through its 2013 Consumer Payment Choice Survey project shows that 89 percent of the population continues to have at least some cash, and the number of currency notes that the public holds continues to grow. Additionally, while prepaid cards have made an impact on the un- and under-banked, cash is still an essential form of payment for them.

But as the 1964 Bob Dylan song goes, "the times they are a-changin'." The survey demonstrated the potential increasing influence on the future of cash that millennials might have, as more than 60 percent of those surveyed as "cash-adverse" (they never hold or spend cash) fall into the millennial age range. But will this behavior persist as they grow older and build their financial resources? The survey results provided some conflicting data for this group that hopefully will be resolved in the next survey to be conducted in the fall. For example, while they claim to not hold or use cash, nearly one-fourth indicated that cash was their preferred payment method.

The anonymous nature of cash is often cited by governmental and law enforcement officials as a reason for using it for illegal business transactions or tax avoidance. But perhaps most importantly, cash has almost universal acceptance and, in times of natural disasters, may be the only payment method that can be used for the purchase of goods and services. The reality is that cash is the payment method used by two-thirds of consumers for transactions under $10. While vending machines and parking meters are being enhanced to accept card and mobile payments, and the prepaid gift card has eliminated a lot of $20 bills in birthday cards, it's extremely difficult for me to consider a world without cash. And I believe history is on my side. Although many new payment methods have been introduced, I don't know of any that have been eliminated over the last two hundred years. So I take reassurance as I open my physical wallet and there among my various debit and credit cards, my $23 in cash sits waiting to be spent. I suspect that cash will continue to exist for centuries after my own obituary has been written.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

July 25, 2016 in currency | Permalink

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May 9, 2016


Follow the Money!

This catchphrase originated in the movie All the President’s Men. It is usually used in politics and means to follow the trail of corruption to the source. This catchphrase came to mind when I attended a panel discussion, “Cash Visibility & the Supply Chain: Tracking Your Cash,” at the NACHA Payments Conference last month in Phoenix. Besides the moderator from the Federal Reserve, the panel comprised a representative from GS1 US (the United States affiliate for the international standards body for supply chain management), a banker, and two big-box merchants.

Throughout the industry, cash handling is well-controlled and secure, but it can be inefficient and prone to error and duplicative work in the quest to minimize the ever-present potential for loss or theft. It is ironic that something as valuable and fungible as cash is tracked in some cases with less sophistication and efficiency than a package delivered to a consumer. State-of-the-art supply chain logistics that have long been in use for retail giants like Walmart and Target are just now being pursued among cash industry partners through the Cash Visibility initiative.

The idea behind this initiative is to apply the latest supply chain logistics to the collection, transport, reconciliation of deposits and orders, and distribution of cash among banks, cash processing facilities, merchants, and the Federal Reserve Banks. The Federal Reserve Banks are in the mix as the wholesale suppliers of cash to banks.

Depending on the type of big-box merchant, cash purchases at the point-of-sale can range from 10 to 25 percent or more of total payments. That's hundreds of billions of dollars in annual sales that need to be withdrawn and deposited at banks for retailers that deal in cash. The following is a representation of the proposed process for improving the wholesale and retail delivery of cash:

Future-cash-cycle-management-image
Source: GS1 US. Used with permission.

The panelists identified the following benefits once the system is widely adopted:

  • Faster resolution of discrepancies between origin and destination
  • Improved data accuracy with reductions of staff time, errors, and exceptions due to reduced manual data entry and paper records
  • Value-added information on status and value of cash in transit
  • Automated custody instead of manual paper-based systems that exist today

It was further noted that as the initiative gains traction, other improvements can be realized such as the depositor and receiver having real-time access to where cash is in transit and when it will arrive at its destination.

Various proof-of-concepts are being planned for later this year from the partners participating in this initiative. Partners include the Federal Reserve, financial institutions, armored carriers, retailers, and solution providers. One early finding at a cash processing facility where the concept was tested was an average reduction in staff time involved in cash handling from six hours to two hours. This web page offers more information on the initiative and how to get involved. Similar programs are under way in France and Germany.

Prior to the session, I would not have guessed there was any opportunity to advance the evolution of cash to a faster and more secure payment system.

Photo of Steven Cordray  By Steven Cordray, payments risk expert in the Retail Payments Risk  Forum at the Atlanta Fed

May 9, 2016 in currency | Permalink

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October 19, 2015


Got Cash?

The governments in countries such as Sweden and Nigeria may have taken initial steps to move to a "cashless" nation, but here in the United States, there is no question that cash is still king. It remains the most-used retail payment instrument, especially for low-value payments. This finding from the Fed's Cash Product Office (CPO) was welcome news to a group of independent (nonfinancial institution) ATM operators that I had the pleasure of addressing last month at their annual conference. The primary business of these entrepreneurs is getting cash into the hands of consumers through their terminals located in a variety of malls and merchandise, food, and beverage stores. Of the estimated 400,000–425, 000 ATMs and cash dispensers operating in the United States, approximately 60 percent are owned by these nonfinancial institutions.

One of the CPO's main missions is maintaining a supply of currency and coin to meet demand in both normal times and special situations such as natural disasters, when other forms of payment might be unavailable. As a critical part of accomplishing that mission, the CPO constantly evaluates research to determine how cash use is changing in this country. One of the main sources of research is the Fed's Diary of Consumer Payment Choice (DCPC). Data collection was last fielded in 2012, but is being conducted again now. To collect the data, the DCPC asks a representative national sample of about 2,500 individuals to record all their financial transactions over a rolling three-day period. In addition to recording the transaction and demographic information, respondents were also asked to indicate their top preferred payment method and their second preferred method of payment in instances when their top choice is not available.

Some of the major findings of that study include:

  • Debit and credit cards represent the stated primary payment choice, at 64 percent, but 30 percent of the consumers stated their primary payment preference was cash.
  • Cash serves as the backup payment method for all segments, reflecting its importance in our overall payment infrastructure.
  • Interestingly, although 3 percent of the consumers said their preferred payment method was checks, they actually used cash twice as often as writing checks.
  • Reflecting the tendency for people to use cash for small-value payments, cash payments represented 40 percent of the number of payments made by the survey participants but only 14 percent of the total value of the payments.
  • Cash clearly dominates the small-value segment under $10.
  • Cash was the payment method used in two-thirds of person-to-person (P2P) payments.
  • The use of cash in P2P transactions is different from other cash transactions; P2P transactions are two-thirds higher in value ($35 versus $21) than other types of expenditures.
  • While 51 percent of the adults in the 18–34-year-old age group indicated that debit cards are their most preferred payment method, cash followed closely at 40 percent for the 18–24 year olds and 31 percent for the 25–34 age groups. Will the 2015 results show a departure from this finding?

It is clear that the United States is a long way from becoming a cashless society despite the predictions of many over the last twenty years. The 2015 results will provide important information as to how cash continues to be used by the general population and the emerging millennials segment in particular.

So is there cash in your wallet? I bet there is and will be for quite some time.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

October 19, 2015 in cards, checks, currency, payments | Permalink

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November 10, 2014


Virtual Currency Environment Still Fluid after Latest Rulings

The end of October was filled with multiple news-grabbing headlines reflecting the growing fears of Ebola, the exciting seven-game World Series, and the release of the first-ever college football playoff rankings. The launch of ApplePay also saw its fair share of headlines, but one piece of payments-related news might have flown a bit under the radar. On October 27, the United States Department of Treasury's Financial Crime Enforcement Network (FinCEN) issued two virtual currency administrative rulings stemming from its March 2013 guidance on regulations to persons administering, exchanging, or using virtual currencies.

The first administrative ruling involves a virtual currency trading platform that matches its customers' buy-and-sell orders for currencies. The company requesting this ruling stated that they operated the trading platform only and were not involved with money transmissions between it and any counterparty. FinCEN determined that money transmission does, in fact, occur between the platform operator and both the buyer and seller. Consequently, FinCEN said that this company and other virtual currency trading platform operators should be considered "exchangers" or "operators" and required to register as money transmitters subject to Bank Secrecy Act (BSA) requirements.

The second administrative ruling involves a company that enables virtual currency payments to merchants. This company receives payment in fiat currency from the buyer (or consumer) but transfers an equivalent amount of virtual currency to the seller (or merchant) using its own inventory of virtual currency to pay the merchant. This particular company asserted that it wasn"t an "exchanger" since it wasn't converting fiat currency to virtual currency because it was using its own reserve of virtual currency to pay merchants. However, FinCEN determined that this company, and similar companies, is a money transmitter because it accepts fiat currency from one party and transmits virtual currency to another party.

These two rulings confirm that if a virtual currency-related company's services allow for the movement of funds between two parties, that company will be viewed as a money transmitter and will be subject to BSA requirements as a registered money transmitter. As financial institutions consider business relationships with these types of companies, they should make sure that these companies are registered as money transmitters and have BSA programs in place.

The virtual currency regulatory environment continues to be fluid. For example, in his recent comments at the Money 2020 Conference, Benjamin Lawsky, superintendent of the New York Department of Financial Services, suggested that his office will soon be releasing its second draft of a proposed framework for virtual currency business operating in New York. Portals and Rails will continue to monitor this regulatory environment at the state and federal level.

By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

November 10, 2014 in currency, mobile banking, mobile payments, transmitters | Permalink

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September 2, 2014


Not All Digital Currencies Are Virtual

Besides a few classic novels, my summer reading list has largely consisted of various papers and reports on virtual and digital currencies. Not all digital currencies are virtual currencies, though these two terms are often incorrectly used interchangeably. For example, the Consumer Financial Protection Bureau recently issued a warning about the risks associated with Bitcoin and other virtual currencies, yet some media outlets reported that the agency issued a warning about digital currencies. And while the media statements are technically correct since virtual currency is one form of digital currency, they fail to recognize that digital currencies are broader than just virtual currencies. In an effort to clear up confusion and create a better understanding of digital currencies, Portals and Rails offers the following simple framework and definitions.

Framework-image

Digital currency is a digital representation of value and consists of both electronic and virtual currency. Digital currency can be used to purchase physical, digital, and virtual goods. Some, but not all, digital currencies use cryptography as their primary method of security.

Electronic currency, also referred to as e-money, is pegged to a fiat currency. It is a digital representation of value that is government-issued legal tender. The link between electronic currency and fiat currency is preserved and has a legal foundation. The funds of an electronic currency are expressed in the same unit of account as the fiat currency. Examples of electronic currency transactions include payments via credit, debit, and prepaid cards; ACH; and PayPal.

Virtual currency is not pegged to a fiat currency. It is a digital representation of value that is not government-issued legal tender. The funds of a virtual currency are not expressed in a fiat currency. There are currently more than 300 tracked virtual currencies, and as we noted in a Portals and Rails post last year, these currencies can take on multiple characteristics. Examples of virtual currencies include Bitcoin, Ripple, Ven, and Dogecoin.

Photo of Douglas A. KingBy Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

September 2, 2014 in currency | Permalink

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June 9, 2014


Magic 8 Ball, Will We Ever Be Cashless?

Predictions of a cashless society have been broadcast sporadically throughout the decades. It became a popular concept in the United States in 1965 when Thomas J. Watson Jr., CEO of IBM, said, "In our lifetime, we may see electronic transactions virtually eliminate the need for cash." Watson believed, or hoped, that the newly released IBM mainframe computers would revolutionize financial transaction processing and make carrying cash unnecessary. Later that decade, the concept was expanded to a checkless/cashless society, with some predicting that both payment forms would be extinct by the 1980s.

Despite consumers' growing use of cards and the emergence of the ACH system, the cashless society concept took a bit of a detour during the 1980s and 1990s—ATMs and shared EFT networks proliferated, both offering tremendous convenience and making it very easy to distribute currency. When card-based point-of-sale (POS) programs also emerged, they offered an alternative to currency and checks, while also increasing the convenience of currency by allowing cash-back transactions. This expansion of currency convenience took place even as consumers were being warned of the dangers of coin and currency—the germs, the cocaine residue, the increased chance of robbery, and so on. Certainly this was a more intense negative campaign than the spontaneous combustion danger my mother warned me about when I was young. I'd received some birthday money that I was anxious to spend, and she declared that the money was "burning a hole in your pocket."

While the central banking authorities of some countries such as Sweden and Nigeria have announced a goal of moving to a less-cash society, consumers in the United States are seemingly moving in the opposite direction, as evidenced by some recent San Francisco Fed research. Researchers examined the data from the 2012 Diary of Consumer Payment Choice (DCPC) study by the Boston, Richmond, and San Francisco Federal Reserve Banks. The San Francisco Fed research included these key findings

  • Cash remains the most-used form of payment, accounting for 40 percent of payment transactions.
  • Cash is generally used for lower-value transactions. The average value of a cash transaction was only $21, compared with $168 for checks and $44 for debit cards.
  • Cash is used most often in gift and P2P (or "person-to-person") transfers, with food and personal care supply purchases second (see the chart).
    Figure 4: Payment Instrument Shares, by Spending Category
  • Contrary to the conventional wisdom of millennials' love for all things electronic, 40 percent of 18–24 year olds prefer cash over all other payment methods—the highest percentage of any age group.

Yes, card, ACH, and other electronic transactions are continuing to increase and gain larger shares of the overall consumer transaction mix while check usage remains in a steady decline. Despite the dire outlook for checks, my colleague Doug King pointed out in a recent post that check usage among P2P users actually increased, according to the latest Fed payments study. My Magic 8 ball is predicting that coin and currency are going to be around for quite some time. What does yours say?

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

June 9, 2014 in cards, checks, currency | Permalink

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December 9, 2013


What Do Crayons and Virtual Currencies Have in Common?

Coloring with my young boys the other day, I was a bit amazed by the variety in colors. The days of a single blue crayon from my childhood has now expanded to at least 10 different shades of blue with names such as "Pacific blue" and "cerulean." I quickly learned that my regulation of the usage of crayons by the boys also varied by color. For example, the lone black crayon required ample regulation (and was quite challenging to enforce) to prevent an all-out toddler brawl. Because the blue crayons had such variety, they clearly required less and were much easier to enforce.

Just as crayons come in a variety of colors and shades, virtual currencies have a variety of different attributes, including:

  • Open or closed: Closed virtual currencies can be used only within a specific community. Open virtual currencies can be used anywhere the currency is accepted.
  • Unidirectional or bidirectional: Unidirectional flow allows the currency to be obtained at a specific exchange rate using fiat currency. This currency cannot be exchanged back to the fiat currency. Bidirectional currencies are bought and sold according to exchange rates.
  • Centralized or decentralized: A centralized currency has a central authority that issues the currency and operates the system. A decentralized currency does not have a single entity acting as a central issuer or clearing house.
  • Asset backed or demand backed: An asset-backed currency is tied to an asset or assets held in reserve while a demand-backed currency has no tangible value other than the value established by its market.
  • Machine-based or human-based: Monetary policy of machine-based currencies, or crypto-currencies, is managed by computers. A central authority establishes monetary policy with human-based currencies.

The regulation of my children's crayon usage differed depending on the particular crayon being used. In that case, it was a matter of scarcity, so the analogy isn't perfect—but it will also be imperative for the regulation of virtual currencies and their enforcement to differ according to the characteristics of the various currencies. Undoubtedly, a decentralized, demand-backed currency not only poses different risks than a centralized asset-backed currency does but it may also include a unique set of participants not part of other virtual currency schemes.

Most of the regulatory discussion currently taking place is focused squarely on a particular virtual currency. And while this particular currency has an enormous market share of the virtual currency market, there are at least 50 other virtual currencies in the marketplace. If I had regulated the blue crayons in a similar way as the black crayon, my children would likely have left their coloring books and moved on to the train table.

I fear that should regulations be developed based on a single virtual currency and then applied to the market at large, the regulations could drive away the innovators in the virtual currency space that may hold long-term promise if they promote a faster, more secure, and more efficient payment system.

Douglas A. KingBy Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

 

December 9, 2013 in currency, regulations | Permalink

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While I'm not well versed in virtual currencies, your point about regulations being based on one market mover and then applied to the rest of the industry is interesting. In general, I think most financial regulation is applied in this manner since it serves as a simplifying assumption and since regulation is generally reactive rather than proactive. My guess would be that the other virtual currencies will continue to innovate around whatever regulation is issued. However, I understand that some may exit the industry altogether if that regulation is too stifling.

Posted by: Saba H | December 13, 2013 at 07:47 AM

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