去中心化金融科技：金融稳定、监管与治理影响报告（英文版）.pdf

Decentralised financial technologies Report on financial stability, regulatory and governance implications 6 June 2019 The Financial Stability Board (FSB) is established to coordinate at the international level the work of national financial authorities and international standard-setting bodies in order to develop and promote the implementation of effective regulatory, supervisory and other financial sector policies. Its mandate is set out in the FSB Charter, which governs the policymaking and related activities of the FSB. These activities, including any decisions reached in their context, shall not be binding or give rise to any legal rights or obligations under the FSBs Articles of Association. Contacting the Financial Stability Board Sign up for e-mail alerts: fsb/emailalert Follow the FSB on Twitter: FinStbBoard E-mail the FSB at: fsbfsb Copyright 2019 Financial Stability Board. Please refer to: fsb/terms_conditions/ iii Table of Contents Page Executive summary . 1 1. Introduction . 2 2. Implications for the structure of the financial system and financial stability . 3 2.1 Forms of decentralisation in financial services . 3 2.2 Current examples of technologies that enable financial decentralisation . 4 2.3 Which financial services are likely to be affected? . 5 2.4 Potential benefits and risks for financial stability . 6 3. Issues concerning financial regulation and governance . 7 3.1 Potential implications for public policy . 8 3.2 Areas of further assessment . 9 Annex 1: Case studies . 11 Case study 1 Cross-border payments and settlements . 11 Case study 2 Capital markets (tokenisation) . 14 Case study 3 Trade finance and insurance . 17 Case study 4 Peer-to-peer lending . 19 Annex 2: Clarifying governance issues related to permissionless distributed ledgers . 22 Annex 3: Examples of international organisations relevant to the governance of technology 24 Annex 4: Glossary . 26 iv 1 Decentralised financial technologies Executive summary Many types of financial service providers are incorporating new technologies that could decentralise the financial system. The decentralisation of financial services refers to the elimination or reduction in the role of one or more intermediaries or centralised processes that have traditionally been involved in the provision of financial services. In some instances it refers to the decentralisation of risk-taking away from traditional intermediaries. This already takes place through capital markets, but could be extended more widely, including to the provision of credit and insurance. In other cases it can also involve the decentralisation of decision-making and record-keeping. It is impossible to predict with certainty the future scope or degree of decentralisation in the financial system. Applications that decentralise along all three of these dimensions (risk-taking, decision-making, and record-keeping) have yet to achieve economically significant scale. That said, technologies that facilitate decentralisation along one or two of these dimensions may, over time, have a noticeable economic impact. There are already examples emerging of decentralisation in payments and settlement, capital markets, trade finance and lending. The application of decentralised financial technologies and the more decentralised financial system to which they may give rise could benefit financial stability. It may also lead to greater competition and diversity in the financial system and reduce the systemic importance of some existing entities.1At the same time, the use of decentralised technologies may entail risks to financial stability.2These include the emergence of concentrations in the ownership and operation of key infrastructure and technology, as well as a possible greater degree of procyclicality in decentralised risk-taking. New uncertainties concerning the determination of legal liability and consumer protection may also affect public trust in the financial system. Recovery and resolution of decentralised structures may be more difficult. These issues may pose challenges for financial regulatory and supervisory frameworks, particularly those that currently focus on centralised financial institutions. A more decentralised financial system may reinforce the importance of an activity-based approach to regulation, particularly where it delivers financial services that are difficult to link to specific entities and/or jurisdictions. Certain technologies may also challenge the technology-neutral approach to regulation taken by some authorities. These concerns could continue to be the subject of further consideration by authorities. Regulators may also wish to engage in further dialogue with a wider group of stakeholders, including in the technology sector, that have had limited interaction with financial regulators to date. This should help avoid the emergence of unforeseen complications in the design of decentralised financial technologies at a later stage. 1See FSB (2019), “FinTech and market structure in financial services: Market developments and potential financial stability implications”, February, pp. 1, 4 and 17 for a discussion of the impact of technology on competition and financial stability. 2The FSB has previously concluded that FinTech in general, and crypto-assets which are one application of DLT do not currently pose risks to global financial stability. See FSB (2017a), “Financial Stability Implications from FinTech: regulatory and supervisory issues that merit authorities attention”, June; FSB (2018a), “Crypto-asset markets: potential channels for future financial stability implications”, October. Both reports state that there is the potential for financial stability implications in the future depending on the scale of adoption of such innovations and other factors. 2 This report considers several forms of decentralisation in financial services and identifies technologies that are decentralising or may in the future decentralise financial activities. It makes a preliminary assessment of which financial services are beginning to, and may in the future, incorporate such technologies. The FSBs work in this area responds to a proposal made by the Japanese G20 Presidency, which was approved at the October 2018 FSB Plenary meeting. 1. Introduction Financial technology (FinTech)3is changing many facets of finance. These include retail and wholesale payments, financial market infrastructures, investment management, insurance, credit provision and capital raising. Global investment in FinTech rose to a record US$112 billion in 2018.4Nascent technologies such as distributed ledgers, cloud services, big data, and artificial intelligence (AI) are being tested for a wide variety of financial operations, to make them faster, more robust and less costly.5Their impact on financial services could be broad, and their applications include the settlement of interbank payments and the verification and reconciliation of trade finance invoices. They may also play a role in executing, enforcing and verifying the performance of contracts.6This report focuses on applications of technologies that may reduce or eliminate the need for one or more intermediaries or centralised processes in the provision of financial services.7These are termed decentralised financial technologies. Such technology can facilitate a move away from single entities that grant access to and validate transactions, towards the decentralisation of information recording (e.g. via distributed ledgers) as well as the process by which it is updated (e.g. consensus mechanisms). Technology is also facilitating the decentralisation of risk-taking and decision-making. For example, peer-to-peer (P2P) lending and insurance are, in places, shifting credit and other risks away from a single entity (e.g. a bank or an insurer) to individual savers (or pools thereof).8Entities that use these technologies 3FSB (2017a). FinTech is defined as technology-enabled innovation in financial services that could result in new business models, applications, processes or products with an associated material effect on the provision of financial services. 4KPMG (2019), “The Pulse of FinTech 2018”, February; CB Insights (2019), “FinTech trends to watch in 2019”, January. 5Distributed ledgers are defined as a collection of data that is spread across multiple nodes and whose consistency is enforced by means of a distributed ledger technology. “Distributed” refers here to having multiple locations for data. This is related to, but not identical with the concept of decentralisation of record-keeping (see Section 2.1). See Annex 2 for definitions. 6The report draws on some examples from specific private firms involved in FinTech. These examples are not exhaustive and do not constitute an endorsement by the FSB for any firm, product or service. Similarly, they do not imply any conclusion about the status of any product or service described under applicable law. Rather, such examples are included for purposes of illustration of new and emerging business models in the markets studied. 7This disintermediation of established financial institutions and infrastructures is distinct from the more general impact technology is having on the structure of the financial system (e.g. through changes in cost structures, barriers to entry and competition). These issues have been considered in other FSB work on market structure so will not be considered here; see FSB (2019). 8See IAIS (2017), “FinTech developments in the insurance industry”, February. 3 may have no clear location or multiple locations across jurisdictions, some of which may change over time (e.g. via the flexible configurations of servers).9The technologies underlying such applications may themselves be decentralised. Such technologies for example distributed ledger technology (DLT), which can store information in a decentralised manner are the focus of this report. But technologies that underlie decentralised provision of financial services need not, themselves, be decentralised. For example, cloud computing or technology based on AI and machine learning may be provided in a centralised manner, but still be used to provide decentralised financial services through online platforms.10Bearing this distinction in mind, this report identifies specific technologies that enable the decentralisation of financial activity and assesses which financial services are beginning to see various forms of decentralisation. It also makes a preliminary assessment of the implications of these technologies for financial stability, and some issues this might raise for financial supervision and regulation. This report responds to a request initiated by the Japanese G20 Presidency. To inform its preparation, a workstream of the FSBs Financial Innovation Network (FIN) held a series of discussions with the public and private sectors, relevant organisations and academics. These took place through conference calls and a workshop hosted by the Organisation for Economic Cooperation and Development (OECD) on 25 February.2. Implications for the structure of the financial system and financial stability 2.1 Forms of decentralisation in financial services There are a number of different types of decentralisation in financial services. These vary in the degree to which they affect different segments of financial services, but generally take three broad forms: Decentralisation of decision-making. This involves a move away from a single trusted financial intermediary or infrastructure towards systems in which a broad set of users is able to make decisions about whether and how to undertake financial transactions. Decentralisation of risk-taking. This involves the shift away from the retention of risk (e.g. credit and liquidity risk) on the balance sheets of individual traditional financial intermediaries towards more direct matching of individual users and providers of financial services. Decentralisation of record-keeping. This involves a move away from centrally held data and records, towards systems in which the ability to store and access data is 9It is important to note that in some cases, these organisations will still play some form of intermediary role, though it may differ from that played by currently established intermediaries. 10Decentralised technologies are an aspect of FinTech that has been the subject of previous work by the FSB. See CGFS and FSB (2017), “FinTech credit: market structure, business models and financial stability implications”, May; FSB (2017b), “AI and machine learning in financial services: market developments and financial stability implications”, November; and FSB (2018a, 2019) on crypto-assets, and FinTech and market structure. 4 extended across broader consortia of users. Verification of such data and records may also be more distributed, for example via consensus mechanisms. Applications displaying all three forms of decentralisation that is, full decentralisation of decision-making, risk-taking and record-keeping seem unlikely to achieve an economically significant scale in the near term. Instead, the majority of existing applications instead retain forms of centralisation across one or two of these dimensions. This is for a range of reasons, most notably those around scalability (e.g. of “proof-of-work” consensus mechanisms)11and limits to the degree to which some underlying technologies can currently establish adequate trust, maintain accountability and handle disputes to the same extent as centralised bodies.12Nonetheless, there is the potential for greater decentralisation along each of these dimensions in the future. 2.2 Current examples of technologies that enable financial decentralisation For this