FRM Part II · FRM Exam Part II
Regulating the Crypto Ecosystem: The Case of Unbacked Crypto Assets: formula sheet
Key formulas
- Leverage multiple
- Leverage = Position size ÷ Equity (margin)
- A position of 10 times equity is wiped out by a 10% adverse move, ignoring fees and margin buffers.
- Liquidation price (long)
- Liquidation price ≈ Entry price × (1 − 1 ÷ Leverage)
- Simplified; real platforms add maintenance margin, so liquidation happens earlier.
- Levered return
- Return on equity ≈ Leverage × Asset return
- Leverage magnifies gains and losses equally. Ignores funding costs.
- Harm-to-objective mapping
- Retail losses → investor protection; fraud and manipulation → market integrity; illicit use → AML/CFT; interconnection and runs → financial stability
- There is no numeric formula here. Use this mapping to structure answers.
- Regulatory principle
- Same activity + same risk = same regulation
- This is the technology-neutral principle. It guards against arbitrage between crypto and traditional finance.
- Perimeter logic for DeFi
- No central entity → regulate access points (on-ramps, front-ends, intermediaries, stablecoin issuers)
- Used when no legal person controls the protocol.
- Ban
- Prohibit holding, trading or service provision
- Strength: clear signal. Weakness: hard to enforce, may push activity offshore or underground and reduce visibility.
- Containment
- Limit links between crypto and regulated finance
- Protects banks, insurers and payments from contagion. Does not protect retail users directly and does not regulate the crypto market itself.
- Regulation
- Licensing + conduct + prudential + AML/CFT rules for service providers
- Aims at investor protection and market integrity. Needs supervisory capacity and cross-border cooperation.
- Policy matching rule
- Risk identified → objective → tool → residual gap
- Use this chain to justify any recommendation. Approaches can be combined.
- Guiding principle
- Same activity + same risk = same regulation
- Technology-neutral. Crypto activity that looks like banking or securities activity should face comparable rules.
- Five domestic building blocks
- Perimeter → Licensing → Disclosure → Custody → Prudential
- Use this checklist to classify any rule in a question.
- Who sets what
- FSB = coordination; IOSCO = markets and investors; Basel Committee (BIS) = bank capital; FATF = AML/CFT
- Most MCQs test matching the body to the task.
- Travel rule data flow
- Originator VASP → sends originator and beneficiary information → Beneficiary VASP
- Same purpose as bank wire transfer information. Aim: traceability and sanctions screening.
- Nature of global standards
- Standard setter issues recommendation → national authority implements → peer review of gaps
- Recommendations are not binding until adopted domestically.
Quick revision
- Unbacked crypto assets have no underlying asset or issuer claim behind their value.
- Stablecoins are a different category and aim to hold a stable value against a reference asset.
- Prices are driven largely by sentiment and speculation, so volatility is high.
- Market participants include trading platforms, custodians, wallet providers and decentralised protocols.
- Key risk themes: volatility, leverage, runs and illiquidity, fraud, hacks, weak custody and opaque disclosure.
- Market failures cover information asymmetry, conflicts of interest in integrated platforms, and weak governance.
- Main policy objectives: investor and consumer protection, market integrity and financial stability.
- Three approaches: ban, contain and regulate.
- Banning can push activity underground or abroad and is hard to enforce on borderless markets.
- Containing limits links between crypto and the traditional financial system, for example by restricting bank exposure.
- Regulating brings activity inside a framework with rules on licensing, disclosure, custody and conduct.
- Cross-border activity creates regulatory arbitrage, so international coordination and consistent standards matter.
Common mistakes
- Calling Bitcoin a stablecoin or saying it is backed by reserves. Fix: Unbacked means no issuer claim and no underlying asset. Value comes from market demand alone.
- Treating a tokenised bond as an unbacked crypto asset because it sits on a ledger. Fix: Classify by what the holder is owed. A tokenised bond is a claim on the bond, so it is not unbacked.
- Saying unbacked crypto is already a major systemic threat. Fix: State that links to traditional finance are currently limited but could grow, so the risk is potential and rising.
- Treating stablecoins and unbacked assets as the same. Fix: Unbacked assets have no claim or reserves. Stablecoins claim to be backed and carry run and reserve risks.
- Saying regulation exists because crypto is already a major systemic threat to banks. Fix: Say regulation is partly preventive. Risks grow with scale, leverage and links to traditional finance.
- Treating all unbacked crypto assets as having an issuer to regulate. Fix: For decentralised assets and DeFi, there may be no issuer. Regulate intermediaries and access points.
- Treating containment as a form of ban. Fix: A ban prohibits the activity itself. Containment allows it but separates it from banks, payments and regulated investors.
- Assuming regulation protects the financial system from all crypto risk. Fix: Regulation covers service providers it can reach. Offshore platforms and decentralised activity can fall outside it, so gaps remain.
- Saying FATF sets capital rules for banks holding crypto. Fix: FATF is AML/CFT only. Bank capital belongs to the Basel Committee.
- Treating FSB or IOSCO recommendations as binding law. Fix: They are recommendations. Binding force comes only from national implementation.
Exam tips
- Always start with the claim test. Most classification questions turn on whether an issuer owes the holder something.
- Do not classify by technology. Being on a ledger does not make something unbacked.
- Watch for options that give Bitcoin stablecoin features such as redemption or reserves. They are wrong.
- Link structure to risk: no anchor gives volatility, and combined roles at one firm give conflicts and concentration.
- Match participants to their one core function before reading the answer choices.
- Match each risk to its mechanism. Questions often ask which risk a specific feature creates.
- Reject absolute statements such as 'crypto poses no risk to stability' or 'is already systemic'.
- For leverage numbers, use Leverage × price move and check against 100% of equity.