Digital finance: Markets in Crypto-assets (MiCA)

We would like to thank the European Commission for giving us the opportunity to submit this feedback. Monerium EMI ehf. is the first Electronic Money Institution (EMI) authorised to issue e-money on blockchains under Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions.

The idea of providing a clear framework to crypto-assets industry players for the protection of consumers and investors is undeniably good. However, if crypto-assets activities form a jungle, the Commission may appear as the harvester uprooting an organic and diverse ecosystem for a monoculture of trees.

Caisse des Dépôts, as a French national institution, is supportive of initiatives providing regulatory clarity and harmonization across the European Economic Area. Clear directives represent a major need of the current DLT environment, a crucial and key ‘block’ for having: - DLT local and global adoption - Fair competitions - Open, large and attractive markets Caisse des Dépôts recognizes the detailed and valuable…

GIM Legal STA is a business law firm that operates mainly in the financial and real estate sectors, including the Fintech and Blockchain industry. We would like to thank the European Commission for giving us the opportunity to submit this paper, together with a brief cover note, and share our views on the proposed Regulation on Markets in crypto-assets. We would be happy to discuss our feedback further.

As a multi-asset servicing specialist, BNP Paribas Securities Services (BP2S) is committed to helping our clients achieve their ambitions both in terms of investments and cross-border distribution. In a changing world, we understand the changing market landscape and the intricacies of the securities services industry.

Adan is thankful to the European Commission for allowing the expression of industry players in this open feedback period. The Association’s objectives are to help create the more favourable environment in the EU for the development of a crypto-asset industry competitive with other regions of the world.

The Italian Banking Association would like to thank the European Commission for the opportunity to provide feedback on the proposed Regulation on a pilot regime for market infrastructures based on distributed ledger technology. Please see document attached.

Coinlex. an Italian think-tank on Bitcoin, Blockchain and Distributed Ledger Technologies, Cryptocurrencies and Crypto-assets welcomes the opportunity to provide feedback on the proposed Regulation on Markets in crypto-assets (MiCA). Please see document attached.

BBVA welcomes the EC’s proposal to regulate the issuance of different types of crypto-assets as well as the provision of related services, as it is broadly consistent with the principle of "same activity, same risk, same regulation". However, some specific provisions should be further clarified and some issues related to financial stability require further consideration.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission’s legislative proposals for an EU regulatory framework for crypto-assets. AFME represents a broad array of European and global participants in the wholesale financial markets.

Dear Sir or Madam, Please find enclosed the comments of Börse Stuttgart for the legislative proposal for a regulation on a pilot regime for market infrastructures based on distributed ledger technology. We would like to thank you in advance for the consideration of our concerns.

Regarding digitization we support legislative initiatives as the Digital Finance Package on EU level or the introduction of electronic and crypto securities (eWpG) on German national level for various reasons. On the one hand blockchain / DLT will have significantly impact the entire asset management industry and the related value chain. All areas, starting with the front office (e.g.

BVI would like to take this opportunity to provide its views on the proposed framework for the pilot regime for market infrastructure based on distributed ledger technology (DLT). An EU regulatory framework should provide a level playing field between crypto and traditional investments in terms of transparency / disclosure obligations as well as risk management for the benefit of investor protection.

The EBF would like to thank the European Commission for the opportunity to share feedback on the proposed Regulation on Markets in Crypto-assets. Please find attached a paper with key messages, for consideration of EU institution in the legislative process.

BVI would like to take this opportunity to provide its views on the proposed framework for markets in crypto-assets (MiCA). An EU regulatory framework should provide a level playing field between crypto and traditional investments in terms of transparency / disclosure obligations as well as risk management for the benefit of investor protection.

Second try, since upload of the PDF document seems to not have worked out: The Association of German Banks welcomes the European Commission’s intention to run pilot operations to identify what adjustments need to be made to existing EU regulation of services involving the issuance, safekeeping and asset servicing, trading and settlement of DLT financial instruments and, in parallel, to develop practicable proposals…

Mastercard welcomes the opportunity provided by the Commission to give feedback on the proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Markets in Crypto-assets, and amending Directive (EU) 2019/1937. Please find our feedback in the attached document.

Societe Generale welcomes the proposal for a regulation on a pilot regime for market infrastructures based on DLT, as it will support the development of secondary markets of cryptoassets qualifying as transferable securities, and represent a meaningful incentive for Societe Generale group to develop even further its experiments and its investment and ancillary services related to security tokens within the EU.

Dear Commission, in accepting the invitation referred to in the consultation paper on the Proposal for a regulation of the European Parliament and of the Council on Markets in Crypto-assets, and amending Directive (EU) 2019/1937, ANASF - National Association of Financial Advisors intends to express the following remarks.

We support crypto-asset regulations that are no longer just at the Member State level, but at the Union level. Indeed, some Member States have already put in place precise rules, which are not necessarily compatible from one State to another, while others have not even started to adapt their legislation.

The Association of German Banks welcomes the European Commission’s intention to run pilot operations to identify what adjustments need to be made to existing EU regulation of services involving the issuance, safekeeping and asset servicing, trading and settlement of DLT financial instruments and, in parallel, to develop practicable proposals for a suitable regulatory framework and targeted adjustments to selected EU…

The Office of Financial Market Innovation of the Principality of Liechtenstein values the proposals of the EU-Commission as very positive contributions to a harmonised market for crypto-assets and security tokens. We share the vision of the potential of the financial appli-cations of blockchain in Europe.

Bolsas y Mercados Españoles (BME) welcomes FISMA initiative to work on the establishment of a European framework for markets in crypto -assets. BME integrates the companies that operate and manage the securities markets and financial systems in Spain.

ESBG supports the establishment of an EU regulatory framework for crypto-asset markets as a key priority; especially as crypto-assets are currently not covered by current EU-legislation. As the main features that constitute a crypto-asset are of a digital/virtual nature, relying on cryptography and use of DLT, the question of the legal nature of the, the difference between asset and technology, and the possible…

DLTs have introduced the notion of digital scarcity, a concept that was not present before the advent of this technological paradigm and that is set to have profound impacts on the economy. Digital scarcity will act as a key enabler of a new digital economy relying on assets that are liquid, divisible, borderless (easily transportable and quickly transferable) and, unlike currencies, have the potential to appreciate…

Crypto-assets pose unique challenges for lawmakers and for supervisors. I do stress the need for an "E-Crypto Directive" to avoid national tendency to regulate in a fragmentary way. The challenge is that crypto-assets is a so broad concept that contains cryptocurrencies, tokens and other assets that have the common point in using cryptography and DLT.