Summary of stakeholder comments and our responses for Capital and Liquidity Treatment of Crypto-asset Exposures (Banking) Guideline (2027)
| Section | Stakeholder feedback | Our response |
|---|---|---|
IX. Minimum capital requirements for credit and market risk of Group 2 crypto-assets | Stakeholders requested the removal of the “time to maturity” dimension from the Group 2a capital requirements calculation. | We made no change to the final guideline. We are maintaining the current treatment of cross-tenor hedges for Group 2a crypto-assets at this time to maintain alignment with international standards. |
IX. Minimum capital requirements for credit and market risk of Group 2 crypto-assets | Stakeholders requested that client exposures arising from client-clearing activities be excluded from Group 2 capital requirements. | We made no change to the final guideline. The change to hedging recognition in the final guideline will allow for greater netting of Group 2a crypto-assets, bringing the treatment of client-cleared positions closer to that of non-crypto-assets. As such, the existing Group 2 capital treatment for client-cleared activities broadly aligns with that for traditional assets, subject to the conservative treatment of Group 2b crypto-assets. |
XI. Minimum capital requirements for counterparty credit risk | Stakeholders requested that Group 2a crypto-assets be recognized as eligible financial collateral for capital purposes. | We made no change to the final guideline. Group 2a crypto-assets continue to present challenges for broad recognition as collateral, including with respect to legal enforceability, liquidity, and volatility during times of stress. Further, recognizing only certain lower risk Group 2a crypto-assets could introduce inconsistencies into the collateral framework. |
XIII. Group 2 exposure limit | Stakeholders requested that exposures arising from client-clearing activities be excluded from the Group 2 exposure limit calculation. | We updated the language in paragraph 75 to exclude exposures arising from client-clearing activities from the Group 2 exposure limit calculation. This was done to reflect the limited residual risk after offsetting positions between the client-facing and qualifying central counterparty facing legs of a clearing transaction. |
XIII. Group 2 exposure limit | Stakeholders requested the removal of the Group 2 exposure limit from the crypto-asset guideline. | We made no change to the final guideline. We continue to retain the Group 2 exposure limit as a prudential backstop while responding to industry feedback through targeted adjustments, such as increasing the limit in October 2025 and excluding client-clearing exposures from the limit in the final guideline. |