Transcript of Question & Answer Session Fireside chat at DLT-Enabled
Paul Derham
For all the people watching, weve got a lot of business owners, a lot of people in what I call the native digital asset sector, and a lot of people in the traditional finance sector who are somehow involved or curious about the digital asset sector and whats happening. We all know that to do business planning, to plan out products, to stay current, we need to know the context. And the pillar of the stable Australian payments system is the Reserve Bank of Australia. And were really lucky to have you, Brad, to talk about whats the current state and whats the future state. So, by the end of this half an hour session, you, the audience, will be able to feel a little bit like youve got a bit of a better grasp on the future state of the central part of the payments ecosystem, or what could be coming, which is an exciting conversation. So just to, I guess, frame it in really concrete terms, Brad, Ive gone back and looked at some of your speeches, which, like white papers on some of these issues – if anyone hasnt read Brads speeches this year and last year and the year before, even I would recommend doing so. Ive already recommended to all of our lawyers to actually read them after reading them myself. If we just go back to a really basic transaction, I want to think, I want the audience to just imagine that youre paying someone $1,000, okay? So hows the RBA involved in that transaction? So, lets say youre paying your business if you use the traditional BECS system, the Bulk Electronic Clearing System, I think Brad, youd call that the Toyota Camry, right? The old trusty – it works. Yeah, is that fair analogy? Yeah, Im seeing you nod. Okay. So if you use that system Im going to log into a bank account if I want to pay someone, and Im going to put in their BSB etc. The way that its processed is that payment, when I click Send, is batched, right? Its cleared in the next clearing cycle, probably overnight. Now the settlement – the funds settle the next business day via the RBAs Reserve Bank Information and Transfer System, the RITS. And thats kind of how the Toyota Camry system rail works. Okay? The more modern one – that what Brad youve called the Ferrari – is the new payments platform. I dont have to type in a BSB or an account number. I can type in something like an email address or a mobile number. Its much easier. Its quicker. The funds are instantly settled using the RBAs Fast Settlement Service. Okay, so its a different platform. Its immediate, nearly always immediate. And thats sort of the newer, faster rail. Now theres a third, Future Money rail, which I think youve put into a number of categories, Brad. Youve got the unbacked crypto, like Bitcoin, some people could pay that $1,000 invoice using Bitcoin. Its clunky, its expensive, its slow. The merchant is probably not going to accept it. Theres also backed crypto, like stablecoins that are fully collateralised. Youve got tokenised bank deposits. And then, I guess if there was a public CBDC for retail, which there isnt, theres sort of this new category. And so if I could just paraphrase everything that Ive just said – weve got an old rail system, weve got a new fast rail system, and then weve got this idea of tokenised money. So, with that as a bit of a backdrop, and the RBA, sort of sitting in the middle of those two rails, the Camry and the Ferrari, can you elaborate on some of the most promising innovations that you see coming in payments?
Brad Jones
Thanks Paul and thanks for the invitation. Its great to connect to this community here. But maybe to answer that question, I could first give some context for what the Banks role is in payments. So we operate the Real Time Gross Settlement system, RITS. We also set policy for payments up to the limit of our regulatory powers, which were a last updated in a really material way back in the late 90s. And what that remit gives us powers to do is to effectively promote efficiency and competition in the payments system subject to controlling risk. So in laymans terms, what we want to see is – our North Star, if you like – is a payment system thats a hotbed of competition, a hotbed of efficiency, but where that competition and efficiency is actually helping to strengthen and stabilise the financial system, rather than working in the other direction. For the Payments System Board that sort of mandate, if you like, has found expression in a few key priorities for us. One is for strengthening the safety and the resilience of our critical market infrastructure, pushing ahead with reforms for payments and market infrastructures. We, for instance, recently got crisis management powers in relation to critical market infrastructure, which were operationalising now. I mentioned promoting competitive, cost effective, electronic payments. Ill come to a couple of examples of that in a moment. Enhancing cross-border is another key priority and shaping the future of money in Australia. So they are all the strategic priorities for the Payments System Board. The few, yeah – I would say were we are technology agnostic. We just want to see those virtues of efficiency and competition result from, you know, the private sector doing what the private sector does best, right, which is to compete, innovate, come up with better, faster, more efficient, more resilient services for customers and for businesses. We try not to be too prescriptive about the functional form that that should take. We feel like thats where the private sector is best placed to. But clearly for us, theres probably three areas that that really stand out. One is this, this evolution thats been underway for a bit about a decade now in real time payments. Its still the case that although weve had a real time payment system for bit over a decade, its not absorbing the lions share of account transfers, for instance – thats still occurring over the old BECS rails. So we think theres significant scope for the country to benefit from 24/7 operation, real time settlement, richer data, enhanced data capabilities and so on. So the transition to real time payments, we think, is still actually in its infancy in Australia, even though the base infrastructure has been with us for, you know, a decade or so. So thats, thats one piece. Theres another piece I mentioned at the outset, around cross-border. This is not an Australian specific issue, but Australia made some commitments to the G20 to increase the speed and reduce the cost of cross border payments. This is a fiendishly complex area. And all Ill say there is that theres been some progress, but its been really slow, and its hard for various reasons, but, but it is a key priority for us. And the third area is wholesale digital money, and thats where the likes of – in the picture you painted stablecoins, potentially tokenised bank deposits and central bank digital currency – come into the frame. And that, I should be clear, that the main area of interest for us as public policy makers here is looking into the issue of how new innovation in programmable money and tokenised money could support the development of tokenised asset markets. Weve done some preliminary work on what we think some of the benefits, but also some of the issues or challenges, could be associated with tokenisation. Theres an ongoing program of work around that. But where were looking at it is what forms of settlement – assets, stablecoins, tokenised bank deposits, or CBDC – could best help enable and facilitate tokenisation of assets. So thats a, thats a key area focus for us. And were running a new pilot, for instance, precisely to examine more closely what some of the policy and technical issues are there.
Paul Derham
Great, well, well, thanks for that. Lets, lets talk a little bit more about central bank digital currencies, CBDCs. Youve, youve talked a bit about these publicly. Theres been, theres been, over the last couple of years, theres been a pilot, and theres a pilot thats starting again. Do you want to talk about Project Acacia and sort of the related issues that youre dealing with at the moment?
Brad Jones
Yeah, sure. So for those that are – some folks on this call were actually involved in our first pilot, which was quite different from Project Acacia, which is our new research project that were running with our research partners at the Digital Finance CRC. The first pilot, we were not prescriptive about use cases at all. We really threw the net as wide as we could, and put it to industry and said – Look, you folks, tell us, where do you see the most promising use cases, whether its retail or wholesale? Were agnostic. We got a whole bunch of ideas, and we whittled that down into a short list and ran with about just over a dozen. We transitioned those through to the formal part of the pilot. That pilot ran for a number of months, and at the end of that project, we wrote up a report, sort of summarising our high-level reflections. One of the key learnings from that pilot was that the use cases that seemed to be most interesting from an economy-wide perspective, were around this issue of tokenisation in wholesale markets. We explored the retail space. We were curious. We wanted to make sure that we hadnt been missing things. Nothing really left off the page to us on the retail side, recognising that we do have a fast, real time payment system, in contrast to some other countries that are looking at a retail CBDC, for instance. And so that led us basically to where we are today, which is the next pilot program, which is focused in a much more concentrated way on this question of tokenised assets, and what are the different forms of money that could help promote the growth of tokenised asset markets. You know, the three that are in scope for us are stablecoins, tokenised bank deposits and wholesale CBDC. We are genuinely, at this point, open minded as to sort of where that research will land. The only sort of guiding – well, one of the guiding principles, though, for us from a public policy perspective, I should be clear about – is that at the Bank we, like all central banks, comply with a set of standards globally known as the Principles for Financial Market Infrastructures. And one of the key principles there is that for systemically important markets, there is a presumption that those transactions should be settling in the ultimate safe asset where you have guaranteed finality and theres basically no credit risk, which is, you know, central bank money. And so part of the reason why were so interested in a wholesale CBDC or doing further research in it, is precisely because if tokenised asset markets ever become truly enormous, then there could well be a case to look at the role that a wholesale CBDC could play in anchoring that market.
Paul Derham
Thats a good point. Lets just, for the sake of the audience watching, theyll all be familiar with stablecoins. We know that CBDC projects are focusing on wholesale markets, as youve pointed out. Can you elaborate a bit more on tokenised bank deposits? Because my understanding is, JP Morgan have sort of done something in this space. Some Australian banks are dabbling. The MAS is sort of collaborating on a wider project with banks. What does that look like, a tokenised bank deposit?
Brad Jones
Yeah so, I wouldnt – youre right, Paul, in that I would say globally, stablecoin issuance is absolutely well ahead of tokenised bank deposit issuance. But the reason that central banks are looking at this, including the central bank of central banks, the BIS, has done a fair amount of work on this, is because the underpinning of todays payments system is that you basically have two tiers. You have central banks, sort of providing the foundational layer, if you like, the foundational tier, which is operating the key settlement infrastructure, RTGS system, but also in settling or ensuring finality of transactions that are going on between banks, commercial banks, who also hold a deposit account at the central bank. And so youve got all this furious transfer going on between banks. The ultimate settlement is happening across the central bank balance sheet, where the central banks basically debiting one banks account with it and crediting another one. And so part of the reason that central banks are looking at tokenised bank deposits is because it could be a functionally superior way of allowing payment, different types of payments, to be made in a way that preserves this two tier system that we understand, that has served the economy well for decades. So that thats why, thats where central banks are looking at it. Its a very different system from a world of stablecoin issuance which could be occurring where you have non-bank issuers, for instance, issuing those claims, and they would be more bearer instruments rather than account or account instruments. And so the central bank would have much less of a role in facilitating, in fact, no role in facilitating ultimate settlement for stablecoins as distinct from, say, a tokenised representation of a bank deposit.
Paul Derham
Yeah, thats a really good explanation, and hopefully it gives a little bit of context to the people watching this, many of whom will have used stablecoins for various reasons and are familiar with that notion. I guess, as you know, Brad, theres also this consultation going on with ASIC about it, re-articulating what it thinks is a financial product and ASIC has come out saying, in draft, we think stablecoins are really financial products. Theyre non-cash payment facilities, and we want to regulate them. People are really concerned about that, because its seen as the final rail thats available to them if they cant get banking access, which is the case for a lot of native digital asset businesses. So its important, I think, for those native digital asset businesses to see theres this strong priority from – at a government systems level – of stability and strength and finality in transactions, and that is why theres this reluctance to suddenly make it easy for anyone to go off and issue their own stablecoin. And so I think that provides a little bit of context, because right now there is a raging debate about, how do we regulate stablecoins in particular. Theres another layer of problems, I guess, with the big global stablecoins that Ive come across as a digital asset lawyer – and you know, our firm acts for a lot of these big global groups, not the two main stablecoin groups, but a lot of the global crypto asset groups – the problem with having a centralised stablecoin that everyones using is its probably, lets say its set up in a low tax jurisdiction. There are billions of dollars of profits being made in another low tax jurisdiction. If theres a criminal fraud situation in Australia, its very difficult to have any recourse if, if someone loses money, or theyre scanned and they brief their lawyers, and its to do with a global stablecoin, theres always, theres all these other problems with these non-Australian, unregulated stablecoins. So anyway, its quite, its quite a wild west, I think, at the moment. And this is sort of leading me into the next question here is – what kind of regulatory reforms do you think we need, Brad? Because I know youre working with Treasury – Treasury put out a consultation paper on regulating payment stablecoins, amongst other things. So yeah, any comments on what reforms you think are needed?
Brad Jones
And thats really a question for the Government. But what I can say, is that the proposal that Treasury floated where stablecoins of different sizes could be subject to different sort of regulatory regimes and different supervisors – so for instance, for the smaller coins, ASIC would have oversight for the larger ones, APRA would, that concept of like proportionality based on size is one that, at least at a philosophical level, would be very supportive of. I think whats also really important is that theres a level playing field for innovation. We as regulators have to be technology agnostic. What weve got to focus on is the outcomes, not so much the precise functional features that industry might want to employ. If innovation is going to promote public trust, its going to promote stability in the financial system, if its not going to result in any competitive behavior that leaves businesses or households worse off, you know, then youre going to have a lot as a proposer of that concept. Generally speaking, youre going to, you know, youre probably going to get further than one that is, is not checking all those boxes. Now, theres no guarantees, of course, but there are some core concepts I think all regulators buy into, which is, you want to minimise cross-border regulatory arbitrage, which, as you said, Paul, is a major issue. And I can tell you, like internationally, the various forums that I attend, its almost agenda item one – how do we minimise cross-border regulatory arbitrage so that stability in the system is not being undermined, and so that we can promote innovation, but in a way that doesnt sort of undermine, really, you know, trust and consumer protections? Thats absolutely foremost in everyones mind.
Paul Derham
Thats good. And I like the way that you described it, Brad, in one of your speeches, that the RBA is an anchor and its an enabler, right? So on one hand, youre balancing protection, stability, risk mitigation, and on the other you want to enable like you said, healthy competition and efficiency. And so I guess its the enabler component that were focusing on today without ignoring the anchor component. Tell us about the sandbox, the regulatory sandbox. In Australia, were at, were at 2.0 arent we, of the enhanced regulatory sandbox? And hey guys, youre probably the next speaker. And yeah, weve got about eight minutes to go. So thats what, exactly what Brad, you and I did. Its a little cameo, accidental to say hi. So theres been the first regulatory sandbox, which is, I guess, a bundle of legislative instruments released by ASIC with its limited law making power, allowing certain activities that would normally require a license to go unlicensed, if its in the sandbox. Then there was 2.0 and thats coming up for review. But I know Brad, youve got a view on sandboxes.
Brad Jones
Yeah, one of the one of the learnings that we actually wrote about in our public report at the conclusion of our first CBDC pilot a couple of years ago now, was the feedback we got from industry, which we reflected on and socialised with the other regulators in Australia, was this sense that the regulatory sandbox was well intentioned, but probably hadnt landed in a way that was proving to be as helpful as it potentially could. And so our sense was that there was certainly scope to have another look. And in particular, we drew some attention to the fact that if Government is to commission another review of the sandbox, and my recollection is, I think it could be due this year, but its really the Governments prerogative as to when it wants to conduct that that next review, that we dont need to be splitting the atom here ourselves – we can look at what other countries have done. Theres some interesting examples internationally where youve seen regulatory sandboxes used in a way that has probably aided the transition between really greenfield innovation and the valley of death, are they getting to actual application. And I suspect if and when that review is done, therell be a number of learnings we can take from the international experience, and embed them in whatever the new form of our sandbox would be. The last thing Ill say is that we recognise, although the Reserve Bank has got a particular remit in regulating aspects of the payments system, that the sorts of issues that were talking about more generally around innovation in in our financial system, in our payments system – that draws in all the regulators, ASIC, APRA, Treasury. And for that reason, a new steering committee thats overseeing that from a governance perspective, our Project acacia, has said that were running with our industry partners, the Digital Finance CRC, we have got representatives from our other agencies sitting around the table, listening to feedback were getting from industry, and engaging so that everyone has an opportunity to hear, you know, given a strong interest.
Paul Derham
Yeah, look, thats excellent. And Ive personally experienced – well, heard the frustrations of clients trying to use enhanced regulatory sandbox. So thats the 2.0 version. And to give you an example, if you want to offer a service that issues a non-cash payment facility, which everyones going to be doing under ASICs, new interpretation – well, every digital currency exchange is going to be doing under ASICs clarified interpretation of a wallet and how it works in certain situations – you cant issue a non-cash payment facility if youre not relying on ADIss for certain parts of the ecosystem, so regulated banks. And so theres a real limitation in the enhanced regulatory sandbox, as it stands for payments innovation. So thats something for those of you – a lot of you who are watching will be putting in submissions to ASICs consultation paper about the draft Information Sheet 225, if youre putting in a response, its due by the end of this month, so in three days. And in your response, you can say – we think there should be an even more enhanced regulatory sandbox, and here are some reasons why. So if anyone wants to do that, thats a way that you can get active on that point. But look, Brad, conscious weve got three more minutes. Tell me what do you think, of all, things that or some of the things weve discussed and things that we havent discussed, whats one of the most promising opportunities that you see coming up in the future of money in Australia?
Brad Jones
As I said, well, I think a few things. One is weve really only scratched the surface, I think, of the full capabilities of real time payments. Thats a first proposition. And so theres a long way to go there, and that, that includes the cross-border piece. Theres been some inhibitors there, but the NPP, for instance, has got, has got a key role, also on the cross-border side. So thats, thats one of them. And I think its, its probably hard to go past the concepts around programmability that a tokenised world could lead us to and the role that different types of money, digital tokenised money, could have in facilitating transactions that are not happening, or facilitating trade in markets that dont yet exist. So that these new forms of money, to my way of thinking up, have the potential to uplift the functioning of our financial system in one of two ways. Its either going to make the existing markets that we have settlement much more efficient. You know, you collapse a t+2 world into a t+0 world. And at the other end – and to be honest, the gains there may be fairly small per trade, but because these markets are so vast, theyre going to aggregate up to some really significant efficiencies and cost savings. So thats one prism. The other prism is these new forms of money. What type of new markets, greenfield markets that dont currently exist today, could they help give life to because of the unique features, real time information updating and so on? Thats really exciting. That ones probably further, you know, out in the ether, maybe 5, 10, years away. But yeah, its hard to not sort of be certainly intellectually curious about where all this might take us.
Paul Derham
Look thanks again for your time. Thanks for sharing with us some of that information, which is really just a snippet of some of the things youve said publicly. So for anyone that wants to know more, theres a whole lot of content on the RBA website of different speeches that Brads given and videos and things like that. Understanding how the RBA sits in the middle of Australias payments system is so important and so few people really have taken the time to look into it, but itll help you understand some of the market forces around regulation of stablecoins, around banking issues, around why settlement takes time, and sometimes when its – and other times its really fast – so thanks Brad and thanks everyone for watching. We need to hand over now. I think its time.