July 3, 2024
Question 1 for Mei Lin Fung
What regulatory measures can be implemented to balance innovative fintech solutions with traditional banking regulations while ensuring consumer safety and trust, within the framework of a global network of regional networks of sandboxes?
Answer: Balancing innovative fintech solutions with traditional banking regulations requires a nuanced approach that fosters innovation while ensuring consumer safety and trust. One effective regulatory measure is the implementation of a global network of regional networks of sandboxes. This concept, proposed at the WSIS 2019 High-Level Panel of Ministers and Regulators on Enabling Environment, provides a structured environment where new fintech solutions, such as digital asset registries and Central Bank Digital Currencies (CBDCs), can be tested under the supervision of regulators. This allows for real-time monitoring and adjustment of regulatory frameworks to address emerging risks and ensure consumer protection.
Regional sandboxes enable neighboring regulators to collaborate closely, sharing best practices and addressing common challenges. This localized approach fosters a deeper understanding of cross-border issues and helps develop harmonized regulatory frameworks that facilitate smoother international transactions and reduce regulatory arbitrage. By allowing for tailored experimentation, regional sandboxes ensure that regulatory measures are relevant and effective in specific local contexts.
The International Telecommunication Union (ITU) can support these efforts by maintaining a digital cross-sector regulation repository. This repository would document and disseminate detailed use cases from various sandboxes, enabling regulators worldwide to learn from each other’s experiences. By fostering continuous improvement and adaptation of regulatory approaches, this repository ensures that digital financial services remain safe, inclusive, and trustworthy.
Furthermore, incorporating digital wallets, as outlined by the Open Wallet Foundation (OWF), into these regulatory measures can significantly enhance security, interoperability, and user trust. Digital wallets store digital assets, credentials, and other useful items such as tickets and keys. The OWF advocates for an open-source software engine that ensures these wallets are portable, secure, privacy-preserving, standards-based, interoperable, and multi-functional. By integrating these principles into sandbox environments, we can ensure that digital wallets are developed with high security and interoperability standards, avoiding vendor lock-in and enhancing user trust.
Developing digital common law at both the national and regional levels allows for an adaptive regulatory regime. This dynamic approach ensures that laws and regulations evolve in response to new challenges and technological advancements, harmonizing regulations and enabling global coordination. By integrating digital common law with regional sandbox networks and the ITU’s repository, we can create a robust regulatory ecosystem that balances innovation with consumer protection, fostering trust in digital financial services.
This approach can also serve as a general model for other areas of cross-sector regulation, such as health and transportation. Ultimately, digital cross-sector regulation must consider the aggregate impact of all vertical regulatory regimes on individuals, families, neighborhoods, and communities. By looking at the holistic impact rather than isolated effects on specific groups, we can create a regulatory environment that supports overall societal well-being and progress.
Question 2
How can Central Bank Digital Currencies (CBDCs) contribute to creating a safe, secure, and inclusive digital financial ecosystem, particularly for MSMEs, within the framework of a global network of regional networks of sandboxes?
Answer: Central Bank Digital Currencies (CBDCs) can significantly enhance the inclusiveness and security of digital financial ecosystems by providing a reliable and accessible form of digital money. For Micro, Small, and Medium Enterprises (MSMEs), which account for a substantial portion of global employment yet often face barriers in accessing finance, CBDCs offer a pathway to more equitable prosperity. By digitizing monetary systems, CBDCs facilitate simple and people-centric digital lending, reducing the reliance on traditional banking mechanisms that may exclude small businesses.
Building on the framework of a global network of regional networks of sandboxes, as proposed at the WSIS 2019 High-Level Panel of Ministers and Regulators on Enabling Environment, CBDCs can be developed and tested in a controlled and collaborative environment. This structure promotes localized learning and adaptation while fostering international collaboration. Regional sandboxes allow regulators to tailor their approaches to local conditions, addressing specific challenges and priorities. By collaborating closely with neighboring regulators, these regional networks facilitate the sharing of best practices and innovative solutions.
The ITU’s digital cross-sector regulation repository can play a crucial role in this process. By serving as a centralized database of regional and national use cases, the repository allows regulators to access, search, and contribute to a growing body of knowledge. This resource supports the continuous improvement of regulatory frameworks, ensuring that they evolve dynamically in response to new challenges and technological advancements.
Elaborating on Digital Asset Registries (DARs):
Digital Asset Registries (DARs) can significantly enhance the financial resilience of MSMEs. DARs function similarly to land title registries by providing a formal mechanism to record ownership of digital assets. This recognition unlocks substantial economic value by enabling digital assets to be used as collateral for loans, thus increasing MSMEs’ access to finance.
In the absence of clear ownership and registries, much of the world’s digital assets remain economically inert. DARs address this issue by formalizing digital property rights, allowing for secure and efficient transactions. This is analogous to the historical formalization of land rights, which unlocked hidden wealth and facilitated economic growth. Digital asset registries can similarly transform the digital economy by making vast amounts of digital capital accessible for economic activities.
Implementing DARs within the framework of CBDCs involves creating a robust legal and technical infrastructure. This includes defining digital property rights, establishing secure and scalable registry systems, and ensuring regulatory oversight to maintain trust and transparency. By integrating DARs with CBDCs, we can enhance creditworthiness assessments, reduce fraud, and increase financial inclusion for MSMEs.
Promoting Financial Stability and Inclusion:
Digital asset registries and CBDCs, when combined, can promote financial stability by reducing systemic risks. DARs provide transparency and traceability, essential for assessing and managing financial risks. By enabling non-bank financing using digital assets, DARs reduce reliance on traditional banking systems, thereby mitigating risks associated with bank runs and financial crises.
This integration also supports the development of a competitive market for MSME financing, facilitated by Prosperity Data Networks (PDNs). PDNs aggregate and analyze economic and behavioral data, enabling informed lending decisions without relying on concentrated data power held by a few large tech companies. This decentralized approach ensures equitable access to credit and fosters a vibrant ecosystem of digital finance.
Conclusion
By integrating CBDCs, regional sandboxes, and digital asset registries within a framework supported by the ITU’s regulation repository and digital common law, we can create a secure, inclusive, and innovative digital financial ecosystem. This holistic approach ensures that digital financial services address the needs of MSMEs while promoting overall societal well-being and economic growth. This model can also be applied to other cross-sector regulations, ensuring that all regulatory regimes consider their aggregate impact on individuals and communities.
References
Fung, M, Bussolli, P., Stein, J.,2024 A Gateway to Finance for MSMEs Paving a Practical Path to Prosperity. Italy G7, Think7 published policy brief. https://think7.org/cbdcs-a-gateway-to-finance-for-msmes-paving-a-practical-path-to-prosperity/
Appendix: Fung, M., Stein, J., Flynn, S. 2024, Implementing Financial Resilience by Digital Asset Registries in CBDCs. Unpublished (link) appendix on Digital Asset Registries
Stein, J., Fung, M., Bertalosa, M., Bersanetti, F., Gupta, S., Strauss, R., Isaacs, C., Asjoma, C., Improving Global Governance: Data Cooperatives for Global Cooperation. Italy G7, Think7 published policy brief. https://think7.org/publications-t7-Italy/improving-global-governance-data-cooperatives-for-global-cooperation/ Alternative link
Fung, M., Tobing, D., Bertolaso, M. Potluri, V., 2023, People-Centered Science and Digital Transformation: A Practical Proposal for the G7 and G20. Japan G7, Think7 published policy brief https://think7.org/people-centered-science-and-digital-transformation-a-practical-proposal-for-the-g7-and-g20/
Fung, M., Stein, J., Flynn, S. 2024, Implementing Financial Resilience by Digital Asset Registries in CBDCs. Unpublished paper (link)
Paola Subacchi, David Vines, John Beirne, Andy Filardo, Mei Lin Fung, Alicia Garcia Herrero, Simone Romano, Mina Toksoz, Paul van den Noord 2022, Keeping the world economy on track: dealing with the short-term emergency and pursuing longer-term objectives. German G7 Think 7 Policy Brief
Singh, T., Fung, M., Murray, E., Lacavaro, A., Gamser M., Omwenga. B., Ndemo, B., Kharas, H. 2022, Global Public-Private Digital Utilities for MSME Recovery and Transition https://think7.org/global-public-private-digital-utilities-for-msme-recovery-and-transition/ German G7 Think 7 Policy Brief
Beirne, J., Bilotta N. Fung, M., Singh T. 2022, Central Bank Digital Currencies: Governance, Interoperability, and Inclusive Growth German G7, Think7 published policy brief https://think7.org/central-bank-digital-currencies-governance-interoperability-and-inclusive-growth/ German G7 Think 7 Policy Brief
Fung, M, Flynn, S., 2021, Digital Economics is Experimental Economics Everywhere. (link). Presentation at World Economic Forum, Digital Economics workshop, Colombia University.
Fung, M, Flynn, S., 2021, Getting it Right From the Get-Go: Establishing a Global Public Utility for SME Financing and Investment (link) Paper for the presentation by Mei Lin Fung, closing keynote on Digital Transformation at the World Bank/IFC Global SME Financing Forum October 2020 (slides). Video published by the Global SME Financing Forum