One need only look at conventional digital payment services, and the prevailing financial exclusion problem, to understand how much worse it might get if instead of many banks competing against each other (and excluding people one by one over time but never universally), a single private-sector provider with a monopolistic footprint were to dominate. There are a number of reasons for this, but the most important one relates to the longstanding argument that without CBDCs cash would cease to function as a public good in the digital era. The rationale further dictates that if western central banks don’t come to market with cost-effective digital cash substitutes, private sector competitors will issue them within walled-garden structures instead. This would be bad, the theory goes, because it might endow private entities with the ability to extract oversized rents from the system or to disenfranchise many vulnerable segments of society. But to solve this problem CBDCs would have to be structurally designed to be universal and accessible to everyone, regardless of their credit history or record.
While none of that may sound controversial upon first reading, it’s worth considering the wider picture. Central banks have been cautious to avoid two key risks that CBDCs could pose. To avoid disintermediating banks by depriving them of their deposit base, central banks have imposed caps on balances, paid no interest on CBDC, or considered imposing a penalty interest rate on holdings above some threshold. To avoid facilitating illicit activity, central banks have mostly decided against fully anonymous accounts or capped anonymous transactions, and have tasked commercial bank intermediaries with monitoring customers and transactions.
What CBDC research and experimentation appears to be showing is that it will be nigh on impossible to issue such currencies outside of a comprehensive national digital ID management system. Meaning: CBDCs will likely be tied to personal accounts that include personal data, credit history and other forms of relevant information. As the report notes:
Regarding the disintermediation risk Goldman notes: . . . central banks have designed their CBDCs to not pay interest or are considering setting a penalty on holdings above a certain threshold. Some central banks have also imposed caps on total balances or allowed commercial bank intermediaries to limit the degree to which customers can exchange existing deposits for CBDC. Which brings us to problem two. If CBDCs are to be universal and available to anyone, they are likely to have an unfair advantage in terms of funding over the conventional banking sector. And that, as we have often written about, risks turning central banks into state-banking type institutions.
If the system is universal and cannot discriminate, it cannot also prevent the facilitation of illicit activity. Exclusion or blacklisting in such is a system is simply not an option. And that means other mechanics would have to come into play to solve the moral hazard inherent in such a set-up. And herein lies the challenge for central banks, which are also supposed to be subscribed to FATF standards on anti-money laundering and know-your-customer regulations.
The News Highlights
- Why CBDCs are likely to be ID-based
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