GDF & CCI Response to FCA Discussion Paper on Regulating Cryptoassets: Admissions & Disclosures and Market Abuse Regime for Cryptoassets
GDF and CCI are the two leading global members’ associations representing firms delivering crypto and digital assets solutions. Our members span the digital asset ecosystem and include the leading global crypto exchanges, stablecoin issuers, digital asset Financial Market Infrastructure providers, innovators, and investors operating in the global financial services sector.
The input to this response has been curated through a series of member discussions, industry engagement, and roundtables, and both GDF and CCI are grateful to their members who have taken part.
GDF and CCI have worked with members to provide constructive feedback on the proposals, and also aim to identify options to overcome challenges identified in the DP. Through this process our collective members have identified key areas that may require further drafting consideration or changes to the FCA’s proposed guidance for purposes of clarity, proportionality, and effective implementation. The six core areas identified are:
1. The Need to Reflect in the Regime the Idiosyncrasies of the Cryptoassets Market and Developing International Regulatory Regimes
2. The Need for Better Sub-Categorisation of Tokens and their Respective Associated Risks
3. The Need for Proportionality and A Risk-Based Approach Across All Aspects of the Regime
4. The Need for Improved Definition and Segmentation of CATPs Based on Client Classification and Token Sub-Categorisation
5. The Need for Detailed Guidance on the Market Abuse Risks for Different Cryptoasset Typologies and Between CATPs Aimed at Wholesale vs Retail Customers
6. The Need to Further Assess the Unique Ways in which Market Abuse Occurs in Cryptoasset Markets
Overall, GDF and CCI recognise the significant task the FCA faces in developing a robust regulatory framework amid complex policy considerations, tight timelines, a diverse and evolving industry, and shifting government priorities. We greatly appreciate the FCA’s proactive approach in navigating these challenges and remain fully committed to supporting its efforts in any way possible. Our combined membership stands ready to assist you as you continue to navigate the challenges ahead.
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