Key Points:

• We agree with the Basel Committee that the approach should follow the principle of “same risk, same activity, same treatment” and that the prudential framework should be technology neutral. However, as we suggest below, adjustments are needed to achieve true technological neutrality. 
• We also believe the framework should be as simple as possible; however, there  are some aspects of the proposal that should be further simplified, while other aspects should be made more risk sensitive.
• Lastly, given the cross-border nature of the cryptoasset markets, the Associations support having minimum global standards, supported by coordination across jurisdictions to help ensure an approach that is consistent and comparable.