On Monday, May 17, 2021, the Federal Deposit Insurance Corporation (“FDIC”) issued a request for information and comment (“RFI”) regarding the current and potential digital asset activities of insured depository institutions (“IDIs”). The RFI is intended to inform the FDIC’s understanding of digital asset activities, including associated risk and compliance management issues. Comments on the RFI are due by July 16, 2021.
The RFI categorizes digital asset activities into five use cases and solicits comments based on this framework. The five use cases are (i) technology solutions, such as token-based systems and distributed ledgers; (ii) asset-based activities, such as investments and margin lending; (iii) liability-based activities, such as deposit services and reserves; (iv) custodial services; and (v) other activities, which could include market-making and decentralized financing. The RFI requests comment on whether additional use cases should be included within this framework and which use cases have the greatest demand in the marketplace. The RFI also requests that commenters provide more detailed information about the use cases that IDIs currently conduct or are considering conducting.