Partner Mike Frisch co-authors Global DCA comment to US Federal Reserve Board

July 23, 2021

Expanded access to the US Federal Reserve’s master accounts (“Accounts”) and financial services (“Services”) is vital to the health and growth of companies in the digital asset and cryptocurrency industry, according to the Global Digital Asset & Cryptocurrency Association (Global DCA).

That was the premise of a response submitted this month by the Global DCA to the US Federal Reserve Board following a request for public comments on its “Proposed Guidelines for Evaluating Account and Services Requests.”

Mike Frisch, partner and head of government litigation and investigations at Croke Fairchild, served as lead author for the Global DCA, collaborating with the association’s membership board, advisory board, and broader community to communicate its position and spell out the risks of the proposed guidelines to fintech startups and other companies innovating in the digital currency space, as well as how the guidelines could be improved.

Specifically, the comment argues that enhanced access to the Fed’s Accounts and Services could expand access to banking and financing options for individuals and communities who have traditionally been underbanked. The Global DCA also argued for a tiered approach whereby new entrants into the digital assets industry would be granted access to Accounts and Services in a manner proportionate to the risk they create for the financial system.

“If adopted, we are concerned that the Fed’s proposed guidelines would discourage companies that are – or are considering – innovating and investing in the decentralized finance and cryptocurrency markets,” said Mike. “Consistent with the Global DCA’s mission, we are advocating for regulations that build public trust, foster market integrity and maximize economic opportunity for all. This comment lays the groundwork for achieving that, and we hope the Board agrees.”

For more information or to read the Global DCA’s full comment, please reach out to Michael Frisch.