Financial Associations Recommend Action to Remove Barriers to Digital Assets Innovation

Washington, D.C. - A coalition of financial services trade associations urged the President's Working Group on Digital Asset Markets to support efforts to remove barriers to financial institutions engaging in digital asset activities. The associations include the Bank Policy Institute, American Bankers Association, American Fintech Council, Americas Focus Committee of the Association of Global Custodians, Financial Services Forum, Securities Industry and Financial Markets Association and The Clearing House Association.

In a joint letter, the associations acknowledge the meaningful progress the Federal Reserve, the FDIC and the OCC have made in rescinding policies and guidance that have hindered banks' ability to engage in digital asset activities. The associations recommend additional steps that the banking agencies can take to advance bank innovation further.

"The U.S. will not be able to achieve a leadership position in digital assets and financial technology under the status quo," the letter states. "Banks are an essential component of the financial and payments systems and are governed by a comprehensive regulatory framework carefully crafted to mitigate the risks inherent to financial activities. It is therefore critical that the federal banking agencies take further steps to facilitate banks' ability to engage in digital asset activities."

The associations made three key recommendations in the letter:

1. Create consistent rules across agencies. The federal banking agencies should coordinate to issue joint rules and guidance when possible. If joint guidance isn't possible, the agencies should at least align their policies to avoid conflicting requirements.
2. Regulate the activity, not the technology. The agencies should affirm that banks may engage in permissible banking activities regardless of the technology used. A tokenized asset is no different from the traditional form of that asset; therefore, the regulatory framework should be technology-neutral.
3. Set clear risk-management expectations. Rather than requiring individual institutions to obtain permission from their regulator prior to engaging in digital asset activities, the agencies should issue uniform expectations for how institutions should manage the risks of those activities, including anti-money laundering, capital and liquidity risks.

The associations' recommendations are aligned with the objectives outlined in the President's Executive Order on Digital Asset Markets and build on their February 20, 2025, letter to the PWG. While the banking agencies have addressed many of the recommendations, the associations continue to urge the Federal Reserve to revise its Policy Statement on Section 9(13) of the Federal Reserve Act and to rescind SR 23-7, "Creation of a Novel Activities Supervision Program."

To access a copy of the letter, please click here.

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About Bank Policy Institute.

The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

Media Contacts

• Austin Anton, Bank Policy Institute, austin.anton@bpi.com
• Sarah Grano, American Bankers Association, sgrano@aba.com
• American Fintech Council, Press@FintechCouncil.org
• Walter Palmer, Americas Focus Committee of the Association of Global Custodians, walter.palmer@us.bnpparibas.com
• Laura Peavey, Financial Services Forum, lpeavey@fsforum.com
• Katrina Cavalli, Securities Industry and Financial Markets Association, kcavalli@sifma.org
• Greg MacSweeney, The Clearing House Association, gregory.macsweeney@theclearinghouse.org