GDF & CCI Jointly Respond to FCA & PSR Call for Information on Big Tech and Digital Wallets
GDF and CCI are the two leading global members associations representing firms delivering crypto and digital assets solutions. Jointly, this response was developed through a series of member discussions and industry engagement. Both GDF and CCI are grateful to its members who have taken part.
The following are the key principles discussed in further detail in our full response to this consultation:
1.) The FCA/PSR’s Broad Definition and Discussion of ‘Digital Wallet’ Does Not Distinguish Between Digital Wallets that Rely on Centralised Intermediaries and Self-Hosted Wallets, Which Do Not;
2.) Different Types of Wallets May Require Different Regulatory Treatment – Requirements Should be Proportionate & Appropriate; and
3.) Emerging Frameworks Should be Technology Neutral and Future Proof as the Digital Wallet Ecosystem is Fast Evolving.
