The IIF is pleased to submit our comment letter on the BCBS discussion paper on designing a prudential treatment for crypto-assets . We welcome the opportunity to comment, with our views concentrated on three major themes:

1. Distinguishing the different crypto-asset classes;
2. The need for a risk-based treatment, including the weighting of appropriate risk and activity factors; and
3. Appropriate design of prudential treatment for low-risk crypto-assets.

The IIF supports the BCBS in taking a forward-looking view on the evolving financial landscape, and this discussion paper represents a useful starting point, and a basis to continue with further in-depth analysis on this emerging topic. The IIF looks forward to working with the BCBS and its members as this further progresses.