• The WFE supports a technology-neutral approach to regulation. Crypto-assets should be subject to the “same activity, same risk, same rules” principle.

  • The prudential framework should promote the trading of assets on regulated platforms, ie, acknowledging that risks are reduced when entities that are already regulated and licensed offer these services.

  • The Group 2 exposure limit (relating to coins other than stablecoins and derivatives thereon) lacks justification and ought to be raised or removed. If the Committee wants to keep the exposure limit it should be amended to permit netting benefits, among other things.

  • The infrastructure risk add-on goes against the principles which the Committee is seeking to achieve, ie, tech neutrality and ‘same risk, same rules,’ and should be revisited.