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FRM Part II · FRM Exam Part II · Regulating the Crypto Ecosystem: The Case of Unbacked Crypto Assets

A supervisor notes that a large crypto platform combines exchange trading, brokerage, custody of client assets, and proprietary trading within one group. Which regulatory response is most consistent with addressing the risks of such a structure?

The most consistent response is to limit or separate conflicting functions and segregate client assets, with clear disclosure. A platform combining exchange, custody and proprietary trading creates conflicts of interest and risk to customers' assets, which these safeguards address, unlike self-attestation or holding volatile crypto as capital.

  1. AAllow the combination, since conflicts of interest disappear when blockchain is used
  2. BRequire only a single annual self-attestation by the platform
  3. CLimit or require separation of conflicting functions, with segregation of client assets and clear disclosureCorrect
  4. DRequire the platform to hold only unbacked crypto assets as capital

Explanation

Combining functions creates conflicts of interest and risks to client assets. Functional separation or strong safeguards, segregation of client assets and disclosure address these. Self-attestation is weak, and holding crypto as capital adds volatility.

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