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FINTECH
      NOTES

THE RISE OF DIGITAL MONEY
         Tobias Adrian
     Tommaso Mancini-Griffoli

             NOTE/19/01
The Rise of Digital Money

                     Tobias Adrian and Tommaso Mancini-Griffoli
                                                    July 2019

I N T E R N A T I O N A L   M O N E T A R Y       F U N D
©2019 International Monetary Fund
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Names: Adrian, Tobias, 1971-, author. | Mancini-Griffoli, Tommaso, author. | International
    Monetary Fund, publisher.
Title: The rise of digital money / Tobias Adrian and Tommaso Mancini-Griffoli.
Other titles: FinTech notes (International Monetary Fund).
Description: Washington, D.C. : International Monetary Fund, 2019. | FinTech notes /
    International Monetary Fund. | July 2019. | Includes bibliographical references.
Identifiers: ISBN 9781498324908 (paper)
  Subjects: LCSH: Digital currency. | Digital currency—Law and legislation. | Banks and
banking.
  Classification: LCC HG1710.A37 2019

ISBN 978-1-49832-490-8 (paper)

 DISCLAIMER: The views expressed in FinTech Notes are those of the author(s) and do
 not necessarily represent the views of the IMF, its Executive Board, or IMF management.

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THE RISE OF DIGITAL MONEY

    Alipay. Libra. M-Pesa. Paxos. Stablecoins. Swish.                  forms of e-money are stablecoins. E-money may be
WeChat Pay. Zelle. All, and many others, are increas-                  more convenient as a means of payment, but ques-
ingly in our wallets as consumers and on our minds                     tions arise on the stability of its value. It is, after all,
as policymakers. But how should we think of these                      economically similar to a private investment fund
new digital forms of money? Are they money at all,                     guaranteeing redemptions at face value. If 10 euros go
and does that matter? Will they really benefit from                    in, 10 euros must come out. The issuer must be in a
rapid adoption? If so, what might their implications                   position to honor this pledge.
be, on the banking sector to start with—where money                       Banks will feel pressure from e-money, but should
is customarily created and managed today? And how                      be able to respond by offering more attractive ser-
might central banks react? Is there an opportunity to                  vices or similar products. Nevertheless, policymakers
benefit from these rapid transformations, or just a need               should be prepared for some disruption in the bank-
to regulate?                                                           ing landscape. Today’s new entrants in the payment
    This paper takes a first step in tackling these                    arena may one day become banks themselves and offer
questions. Given their complexity, it limits the scope                 targeted credit based on the information they have
of analysis and does not venture into the normative                    acquired. The banking model as such is thus unlikely
realm. The goal of this paper is to offer a conceptual                 to disappear.
framework to categorize new digital monies, identify                      Central banks will play an important role in mold-
some of their risks, think through the implications,                   ing this future. The rules they set will bear heavily on
and offer some policy options for central banks to                     the adoption of new digital monies, and on the pres-
consider. The focus is mostly on the interplay between                 sure these exert on commercial banks. One solution
new forms of money and the banking sector; thus on                     is to offer selected new e-money providers access to
financial stability and consumer protection. Other                     central bank reserves, though under strict conditions.
risks and implications—touching on financial integrity,                Doing so raises risks, but it also has various advan-
monetary policy and capital flows, and antitrust—are                   tages. Not least, central banks in some countries could
mentioned in passing but do not represent the core of                  partner with e-money providers to effectively provide
the discussion.                                                        “central bank digital currency (CBDC),” a digital
    In short, the paper argues that the two most com-                  version of cash. We call this arrangement “synthetic
mon forms of money today will face tough compe-                        CBDC.” While painting these prospects, we highlight
tition and could even be surpassed. Cash and bank                      the many questions that still need answers before con-
deposits will battle with e-money, electronically stored               crete policies can be designed.
monetary value denominated in, and pegged to, a                           This paper is organized into four parts. The first
common unit of account such as the euro, dollar, or                    reviews the different models of digital money and
renminbi, or a basket thereof. Increasingly popular                    offers a simple conceptual framework to compare and
                                                                       contrast them. The second part argues that adoption of
   Without implicating their views, for substantial input we thank     certain new models may be extremely rapid. Despite
Federico Grinberg, Matthew Jones, Alfred Kammer, John Kiff, Sole-
                                                                       not offering the best store of value, their convenience
dad Martinez Peria, and Cedric Tille. For helpful comments we are
indebted to seminar participants at Consensus 2019, the Graduate       as means of payment could be unrivaled due to
Institute in Geneva, the IMF, and the Norges Bank, as well as gen-     network effects and online integration. In short, while
erous reviewers at the IMF, in particular Itai Agur, Craig Beaumont,   the first part offers a taxonomy of change, this part
Yan Carrière-Swallow, Giovanni Dell’Ariccia, Kelly Eckhold, Chris
Erceg, Ulric Eriksson von Allmen, Vikram Haksar, Dong He, Nigel        concludes that some changes are here to stay. The third
Jenkinson, Amina Lahreche, Ross Leckow and colleagues in the           part discusses the potential impact of digital money
IMF’s legal department, Aditya Narain, Adina Popescu, Tahsin Saadi     adoption on the banking sector. It considers three sce-
Sedik, Nadine Schwarz, Herve Tourpe, and Romain Veyrun. We also
thank Jeffrey Hayden and his team for superb editorial assistance.
                                                                       narios: one in which digital monies are complements,

                                                                                          International Monetary Fund | July 2019   1
FINTECH NOTES

one in which they are substitutes but banks are able                  monetary economics. (Their “money flower” is com-
to compete effectively for deposits, and one in which                 plementary to our framework; indeed, some flowers
banks are transformed into private investment funds                   blossom on trees!)
following massive deposit outflows. Other risks are also                 The first attribute that defines a means of payment
described briefly. The fourth and final part considers                is type—either a claim or an object.2 The cash used to
how central banks might respond. It discusses the                     pay for the coffee mentioned earlier is an example of
potential benefits of allowing some digital money                     an object-based means of payment. The transaction
providers to hold central bank reserves and argues that               is settled immediately as long as the parties deem the
this could offer an effective model to introduce CBDC                 object to be valid. No exchange of information is nec-
to the public at large.                                               essary. The other option is to transfer a claim on value
                                                                      existing elsewhere. That is the case when coffee is paid
                                                                      for with a debit card. Swiping the card gives instruc-
New Digital Forms of Money                                            tions to transfer ownership of a claim on bank assets
    “How much for your coffee?” 1 euro, a dollar,                     from one person to another.
10 yuan . . . Whatever the price, we might pull out                      Claim-based payments simplify transactions, but
local notes and coins to settle the bill. Or we might                 require a complex infrastructure. With the advent of
swipe a card or wave our phone and walk away just                     claim-based systems in the Renaissance, merchants
as reassured that the coffee was paid for. Someone                    could conveniently travel with letters of credit from
watching from another century would think it were                     their banks and exchange them for goods abroad
magic. Indeed, it nearly is. The steps, hidden from                   instead of carrying heavy and risky gold coins in
view, are extraordinarily complex, involving informa-                 their purse. Today, most payments are claim-based.
tion exchange, legal and regulatory structures, as well               These require that payers be recognized as the rightful
as back-end settlement of funds. And yet, we think                    owners of the claim they offer, that sufficient funds be
nothing of it.                                                        identified to back the claim, and that the transfer be
    What if someone walked into the same coffee shop                  registered by all relevant parties.
and paid using a stablecoin, or by way of a social                       The second attribute of means of payment is value.
messaging app? Or in digital tokens backed by gold                    When classifying claims, the relevant question is
or other safe and liquid assets like U.S. Treasury bills?             whether redemption of the claim in currency is at fixed
Would we feel like the visitor from another century?                  or variable value. Fixed value claims guarantee redemp-
    To make sense of these new payment technologies,                  tion at a pre-established face value denominated in
it is useful to introduce a common vocabulary and                     the unit of account. For payments, this useful feature
conceptual framework. We propose one in the fol-                      allows parties to a transaction to easily agree on the
lowing section. Against this backdrop, the subsequent                 value of the claim they exchange in the relevant unit
section briefly surveys existing and potential future                 of account. For instance, a claim on a bank in the
means of payment.                                                     form of deposits for, say, 10 euros can be exchanged
                                                                      for 10 euros worth of bills and notes. These claims
                                                                      resemble debt instruments (which may or may not pay
A Taxonomy—The “Money Tree”                                           interest) that can be redeemed upon demand at face
   We compare and contrast different means of                         value. Other types of claims can be exchanged for cur-
payment through the lens of a simple conceptual                       rency at variable value, meaning at the going market
framework. We highlight four attributes of means                      value of the assets that back the claim. Such claims
of payment: type, value, backstops, and technology.1
These are discussed below and illustrated in Figure 1.                   2The terminology used here deviates slightly from that intro-

Because of its branch-like structure, we refer to the                 duced by Khan and Roberds (2009) of account- versus token-based
                                                                      payment systems. This is to more clearly distinguish this level of
figure as the “money tree,” borrowing from Bech and                   classification from the technology used, as the word “token” often
Garratt’s (2017) original use of botanical analogies in               denominates a blockchain-based payment instrument. Further
                                                                      confusion arises from a debate over whether blockchain-based
   1We do not refer to the issuer of a means of payment in this       technology would be better labeled as account-based since it checks
framework in order to identify criteria that capture the essence of   ownership of coins on a ledger (see Milne 2018). For an earlier and
different means of payment, without being skewed by the particular    important contribution to the discussion of money, see also Kocher-
forms these take today.                                               lakota (1998).

2          International Monetary Fund | July 2019
The Rise of Digital Money

Figure 1. Money Trees

      Type                                                            Claim                                                              Object

      Value                               Fixed value redemptions             Variable value redemptions               Unit of account                Other

    Backstop                   Government                           Private

   Technology          Centralized     Decentralized    Centralized       Decentralized     Decentralized      Decentralized   (De)centralized    Decentralized

                       Debit card        None           AliPay                Paxos           Gold-coins           Cash             CBDC          Public coins
    Examples           Cheque            prominent      WeChat Pay            USD-Coin        Libra?                                              (Bitcoin)
                       Wire                             M-Pesa                TrueUSD                                                             Managed coins
                                                                                                                                                  (Basis)

    Types of
                                B-money                             E-money                    I-money              Central bank money            Cryptocurrency
     Money

Source: IMF Staff.
Note: CBDC = central bank digital currency.

thus resemble equity-like instruments with an upside,                                 Five Different Means of Payment
but also downside risks. These parallels are intended                                    The above attributes help us distinguish among five
to facilitate exposition, and do not necessarily imply                                different means of payment: (1) central bank money;
that the means of payment we classify as debt-like or                                 (2) crypto-currency; (3) b-money, which currently is
equity-like would be recognized as such in a court of                                 issued by banks; (4) electronic money, or e-money,
law. When classifying object-based means of payment,                                  offered by new private sector providers; and (5)
the relevant question instead is their denomination,                                  i-money, short for investment money, issued by private
in the domestic unit of account or their own. The                                     investment funds.
concept of redemption does not apply to object-based                                     The most recognizable is central bank money in
means of payment.                                                                     the form of cash—the notes and coins we have been
   The third attribute of means of payments applies                                   carrying in our wallets for centuries. As discussed
only to claims in fixed value. The question is whether                                earlier, cash is an object-based means of payment. It is
the redemption guarantee is backstopped by the govern-                                denominated in the local unit of account, is issued by
ment, or relies merely on prudent business practices                                  the central bank, is settled in a decentralized fashion
and legal structures put in place by the issuer. In the                               among transacting parties, and obviously has physical
latter case, we call the backstop “private.” The distinc-                             appearance. Its digital counterpart is currently being
tion is important as it may affect users’ trust in the                                debated under the heading of “central bank digital cur-
different forms of money, and the regulatory response.                                rency,” or CBDC for short. Unlike cash, CBDC would
   The final attribute is technology; is settlement cen-                              likely not be anonymous, although it could protect
tralized or decentralized? Transactions leveraging cen-                               users’ data from third parties. Its validation technology
tralized technologies go through a central proprietary                                could be centralized or decentralized, and it could offer
server. Decentralized transactions making use of decen-                               interest. Mancini-Griffoli and others (2018) offers a
tralized ledger technologies (DLT) or blockchain tech-                                detailed review of CBDC designs and implications.
nologies are settled among several servers. These can                                    The other object-based means of payment is crypto-
be limited to a trusted few (“permissioned” networks),                                currency. It is denominated in its own unit of account,
or open to the public (“permissionless”). Decentralized                               is created (or “minted”) by nonbanks, and is issued on
instruments could extend across borders more easily.                                  a blockchain, commonly of the permissionless type.

                                                                                                            International Monetary Fund | July 2019            3
FINTECH NOTES

An additional distinction is relevant—whether the                              ant innovation relative to cryptocurrencies is to issue
algorithm underlying the creation of cryptocurrency                            claims that can be redeemed in currency at face value
attempts to stabilize its value relative to fiat currency                      upon demand (Figure 2). Borrowing from our earlier
by issuing more currency when its price is high and                            analogy, it is a debt-like instrument. It is like b-money
withdrawing currency from circulation when its price                           except that redemption guarantees are not backstopped
is low. We refer to these systems as “managed coins”                           by governments. They merely rest on prudent man-
(some also call these “algorithmically stabilized value                        agement and legal protection of assets available for
coins”). However, the model is not yet widely tested,                          redemption. Transfers can be centralized, as in the case
though has been proposed by startups such as Basis.                            of many of the popular payment solutions in Asia and
We refer to other cryptocurrencies as “public coins,”                          Africa, including Alipay and WeChat Pay in China,
including Bitcoin and Ethereum.                                                Paytm in India, and M-Pesa in East Africa (also called
    The most widespread use of claim-based money                               “stored value facilities”). Note that banks can also issue
is b-money, which typically covers commercial bank                             e-money to the extent they deal with clients that do
deposits. In many countries, most payments entail the                          not benefit from deposit insurance.4 Blockchain-based
transfer of funds from one bank account to another,                            forms of e-money—such as Gemini, Paxos, TrueUSD,
often from one bank to another, and possibly across                            and USD Coin by Circle and Coinbase—are also
borders. As discussed earlier, we associate b-money                            popping up. These are often referred to as “fiat tokens.”
with debt-like instruments denominated in a unit                               The term “stablecoin” is also widely used, though
of account, redeemable upon demand at face value.                              suffers from a vague definition which also covers the
Transfers are most commonly carried out through cen-                           “managed coins” discussed earlier.5
tralized technologies, as in the case of debit cards, wire                        Finally, i-money is a potential new means of pay-
transfers, and checks.                                                         ment, though one which may or may not take off.6
    The key distinguishing feature of b-money is that its                      I-money is equivalent to e-money, except for a very
redemption guarantee is backstopped by the govern-                             important feature—it offers variable value redemptions
ment. Of course, a prudent business model helps meet                           into currency; it is thus an equity-like instrument.
potential redemption requests. But public policy also                          I-money entails a claim on assets, typically a com-
plays a role. Banks are regulated and closely super-                           modity such as gold or shares of a portfolio. Exam-
vised. Where regulation is effective, banks cannot                             ples of gold-backed i-money are Digital Swiss Gold
take excessive risks and must keep ample liquidity. In                         (DSG) and Novem.
addition, if banks run out of liquid assets to honor
requests for withdrawals, central banks may provide                               4We understand this to be the case for J.P. Morgan’s JPM Coin,
liquidity via overnight loans or emergency facilities in                       which for now is only available to institutional clients. More
times of systemic stress. Finally, deposits are insured in                     information can be found on the J.P. Morgan website: https://​www​
many countries up to a certain limit. To the extent this                       .jpmorgan​.com/​global/​news/​digital​-coin​-payments.
                                                                                  5Warren Weber (2019) offers a useful overview, but introduces
insurance is credible, consumers do not worry about                            terms that are not consistently used by others. See also PWC and
their ability to redeem their deposits, and businesses                         Loopring (2019). Notice that the above definition of e-money
should be reassured by effective regulation.                                   does not imply that the companies listed here legally issue or create
                                                                               money, operate large balance sheets, or themselves have direct liabil-
    E-money is emerging as a prominent new player
                                                                               ities to their customers. Many place client funds in escrow accounts
in the payments landscape.3 Its single most import-                            off balance sheet, as discussed later. Finally, notice also that not all
                                                                               the e-money providers listed above necessarily issue legally binding
                                                                               guarantees of redemptions at face value, despite pledging 1 for 1
   3The term is also used in recent legislation. See for instance Singa-       convertibility into fiat currency on their websites and white papers.
pore’s 2019 Payment Services Act which emphasizes that “e-money”               Models remain to be tested in stressed markets.
is denominated in currency, “pegged” to a currency, and is intended               6Whether or not i-money is actually a form of “money” is open

to serve as a “medium of exchange.” https://​sso​.agc​.gov​.sg/​Acts​          for debate. To economists, money is a stable store of value, a
-Supp/​2​-2019/​Published/​20190220​?DocDate​=​20190220. See also              widespread means of payment, and a unit of account. No generally
the European Commission’s 2009 Directive on electronic money,                  accepted legal definition exists, though most emphasize the ready
available at https://​eur​-lex​.europa​.eu/​legal​-content/​EN/​TXT/​?uri​=​   exchange into currency, as well as denomination in a unit of account
CELEX:​32009L0110. The European Commission defines e-money                     and widespread acceptance as a means of payment. Most likely, there
in a somewhat more general way, referring to “a claim on the issuer            would be a continuum of i-monies depending on the assets backing
which is issued on receipt of funds for the purpose of making pay-             these. Those backed by the safest and most liquid assets, if widely
ment transactions.” According to this definition, even pre-paid cards          accepted, could be considered a form of money. See He and others
(which were originally associated with e-money) must be redeemable.            (2016) for a detailed discussion of what is money.

4           International Monetary Fund | July 2019
The Rise of Digital Money

Table 1. Summary of Forms of Digital Money and Their Attributes
  Elements                CBDC             Cryptocurrency           B-money                    E-money                        I-money
 Type           Object                     Object           Claim                      Claim                        Claim
 Value          Unit of account            Other            Fixed value redemptions    Fixed value redemptions      Variable value redemptions
 Backstop       n/a                        n/a              Government                 Private                      n/a
 Technology     Centralized & blockchain   Blockchain       Centralized & blockchain   Centralized & blockchain     Blockchain
 Source: IMF staff.

   Private investment funds—such as money market                        The transfer of Libra—essentially shares of Libra
funds, and exchange-traded funds—offering relatively                    Reserves (though potentially without a legal claim)—
safe and liquid investments have been growing rapidly                   would comprise a payment, just as in the
but do not yet offer widespread means of payment.                       above example.7
In the United States in particular, the market-based                       We offer Table 1 as a summary of the different
financial system is larger than the traditional banking                 forms of money we just evaluated along the four ele-
system. Private funds have begun allowing clients to                    ments of our conceptual framework.
make payments. However, these have relied mostly on
collateralized lending (credit card payments) or rapid
and low-cost redemptions into fiat currency for subse-                  Adoption of E-money Could Be Rapid
quent payments.                                                            If a means of payment—either claim or object—has
   Today, however, shares in private investment funds                   stable value in the unit of account most relevant to
could become i-money. They can be tokenized,                            users, it is much more likely to be widely adopted.
meaning they can be represented by a coin of any                        For one, parties will agree to hold it at least for the
amount on a digital ledger. The coin can then be                        time it takes to complete the transaction. In addi-
traded directly, at low cost, and constitute a payment                  tion, they will more easily agree on its value relative
denominated in the underlying portfolio, valued at the                  to the contracted transaction price, usually expressed
portfolio’s going worth in any currency. For instance,                  in a common unit of account. Stable value is thus a
if B owes A 10 euros, B could transfer 10 euros worth                   necessary condition for an object or claim to be widely
of a money market fund to A. To the extent that the                     used as a means of payment. The question is how
fund is liquid, its market price should be known at                     stable? And can e-money be as stable as some of its
any point in time. And to the extent the fund com-                      competing forms of money? If not, can its advantages
prises very safe assets, A may agree to hold these with                 as a convenient means of payment compensate and still
the expectation of using these to pay for future goods                  lead to widespread adoption? Note that we focus here
and services at approximately the same exchange rate                    on e-money, but many of the insights could extend to
with local currency. In other words, i-money could be                   i-money if and when it also takes off.
sufficiently stable to serve as a widespread means of
payment. However, as the transfer of i-money entails
a transfer of ownership of securities, it may be subject                How Stable is E-money?
to regulatory restrictions that could limit transactions                   Differences in terms of stability of value are actu-
across borders, for instance.                                           ally quite marked between different forms of money.
   A tangible example of i-money backed by a port-                      Users may compare monies according to returns and
folio of assets may be Libra, the coin just announced                   risks. We measure these in nominal terms, relative to
by Facebook and members of the Libra Association.                       domestic currency, unless otherwise noted.8 This helps
Details on Libra, announced June 18, 2019, are still                    us focus just on the design of monies, not on their
to be released. However, it seems as if Libra would                     macroeconomic context, which would be common to
be backed by a portfolio (called Libra Reserves) made                   all designs.
up of bank certificates of deposit and short-term
government paper. Libra coins could be exchanged                           7We do not advance a definite view as to whether Libra should be

                                                                        considered a security from a regulatory standpoint.
into fiat currency at any time for their share of the                      8Our decision to focus on the nominal stability of value relative to
going value of the underlying portfolio, without any                    the domestic currency is less defendable in countries with very high
price guarantees. This sets Libra apart from e-money.                   inflation in which the means of payment denominated in foreign
                                                                        currency may be preferred independently of other design features.

                                                                                               International Monetary Fund | July 2019           5
FINTECH NOTES

                                    Figure 2. Stylized e-money Setup
                                                    eMoney/
                                                    iMoney               Claim
                                        End
                                                              Issuer                   Assets
                                        user
                                                    Pay                  Holds
                                   Source: IMF staff.

   Cryptocurrency is by far the riskier, though it poten-                 Then come the monies in the form of claims which
tially offers higher returns (capital gains). This is espe-            are potentially much riskier by design. Equity-like
cially true of public coins whose value in fiat currency               instruments like i-money directly inherit the risk of
can fluctuate significantly. The standard deviation of                 their underlying assets. I-money backed by Treasury
day-on-day changes in Bitcoin prices is approximately                  bills will be less risky than i-money backed by stock
10 times higher than in most G7 currency pairs, and                    market shares.
even a little higher than in the Venezuelan Bolivar to                    Backing in liquid and safe assets also helps b-money,
U.S. dollar exchange rate.                                             but it is especially the government backstops that pro-
   Managed coins exhibit lower price volatility by                     vide safety as a store of value, as discussed earlier; the
design. However, these use some variation of a simple                  bank deposits and central bank liquidity.
system to stabilize value, which is not always cred-                      What about e-money? Stability of value comes from
ible. Issuers purchase coins when their value is low                   the guaranteed redemption at face value. But because
using another asset, and they sell coins when their                    e-money does not benefit from government backstops
value is high. While public coins are akin to a float-                 as does b-money, can it always be in a position to
ing exchange rate, managed coins resemble managed                      honor redemption requests? It must privately generate
exchange rates. Their outstanding stock is supposed                    the means to do so through a strong balance sheet and
to keep the exchange rate with fiat currency within                    specific legal structures. Otherwise, e-money may be
tight bands. However, we know too well the common                      subject to run-risk. In essence, e-money shares many
fate of pegs. When a country’s economic fundamen-                      characteristics of constant net asset value (CNAV)
tals are off-kilter, the central bank can run out of the               funds, which also pledge that customers will at least
foreign exchange reserves needed to purchase domestic                  get their money back.9 But as we were reminded
currency in the marketplace. Providers of managed                      after the Lehman bankruptcy, runs materialized when
coins can also run out of assets to support the price                  money market funds “broke the buck.” That is, inves-
of their coins, especially because they may stand on                   tors believed these funds would return a dollar for each
shaky fundamentals—use determining value, and value                    dollar invested, but they got back less when the value
encouraging use. Nevertheless, never say never when it                 of the funds’ riskier assets plunged as markets crashed.
comes to technological innovation!                                        In general, e-money is exposed to four types of risks,
   At the other extreme, central bank money—cash or                    in addition to operational risk (including cyber risk),
CBDC—is perfectly stable as a store of value (again,                   which is common to all means of payment to differ-
in nominal terms). Central bank money cannot be                        ent degrees. Liquidity, default , market, and foreign
redeemed at the central bank against anything (such as                 exchange rate risk all potentially undermine the guar-
gold), as it is the unit of account. Of course, techni-                antee of redeemability at face value.
cally, government bonds balance central banks’ cash                    •• Liquidity risk means there may be a lag before
liabilities to the public in a modern fiat system. As                     redemption requests can be met. Liquidity risk
a consequence, the government’s solvency underpins                        depends on the market liquidity of the assets held
the value of money—but in real terms. Unfortunately,                      by the e-money issuer.
there are plenty of examples of countries with weak                    •• Default risk captures the scenario in which the
fiscal positions whose currency is wiped out through                      e-money issuer defaults, leaving client funds at risk
hyperinflation due to a run to foreign currency or
monetary financing of the debt.                                          9The parallel is made for expositional purposes. Differences

                                                                       remain. For instance, CNAV funds typically do not have the legal
                                                                       obligation to cap investors’ losses, despite striving to do so.

6         International Monetary Fund | July 2019
The Rise of Digital Money

                  Figure 3. E-money with Trust to Protect Client Funds
                               eMoney             Authorization                    Claim
                     End
                                         Issuer                     Trust                          Assets
                     user
                                Pay                  Pay                          Holds

                 Source: IMF staff.

   of seizure by other creditors. Default can occur due              where necessary in order to protect customers and
   to losses on other business activities or the inability           avoid risks to financial stability.10
   to meet one’s debt obligations.
•• Market risk emerges from the assets held by the                   E-money issuers are adopting some of the above
   e-money provider. Sufficiently large losses relative to        options. To date, the most popular assets held by
   the capital of the e-money provider can put redemp-            e-money providers are bank deposits. These have the
   tions at risk.                                                 advantage of offering redemption on demand at face
•• Foreign exchange rate risk is present to the extent that       value, but banks can default. And because e-money
   claims held as e-money are denominated in a cur-               issuers are wholesale creditors, their funds are generally
   rency other than the domestic unit of account. That            not protected by deposit insurance. Other systems will
   is the case of Libra, for instance which is denomi-            have to be developed to protect e-money providers
   nated in a basket of currencies.                               and their clients from bank defaults, perhaps along the
                                                                  lines of private investment protection plans.
    To minimize exposure to these risks and thus                     To minimize risk that e-money providers default,
maximize the stability of their value in currency,                client funds may be transferred to trusts (illustrated
e-money issuers have various options. Extending the               in Figure 3).11 Trusts have the advantage of segregat-
earlier exchange rate analogy, these amount to pushing            ing client funds from the balance sheets of e-money
e-money to resemble a currency board, and embracing               providers. However, the legal protection of trusts is
transparency.                                                     not watertight in all jurisdictions. As a result, it may
•• They can invest in safe and liquid assets, such as             not always be possible to protect client funds from
   short-term government paper. The safest and most               other creditors in courts of law. If anything, legal
   liquid assets of course are central bank reserves.             proceedings could delay the re-appropriation of funds.
   These can be held directly, if access is granted,              Depending on the country, other legal structures may
   or indirectly through a specialized bank such as a             be more effective in protecting client funds.
   payments bank in the United States or India or a
   special purpose vehicle with a bank license.
•• They must contain the creation of e-money so that              E-money Adoption Could Be Fast for Its Attractiveness as
   it is always lower or equal to the value of the client         a Means of Payment
   funds received. Over-issuance would undermine the                 So if e-money cannot be as stable a store of value
   ability to meet redemption requests.                           as b-money or central bank money, could its adop-
•• Assets held must not be encumbered—namely,                     tion still take off? The answer is yes, due to its relative
   pledged as collateral for loans—and would ideally
                                                                     10If e-money were to become its own unit of account through very
   be segregated from the e-money issuer’s balance
                                                                  widespread use, these risks would become less relevant, as users may
   sheet in order to protect client funds in the case             no longer seek redemption unless e-money were debased through
   of bankruptcy.                                                 excessive issuance (in the same fashion that households and firms
•• Sufficient capital would help offset losses and thus           sell domestic currency for foreign currency). In this case, the new
                                                                  form of money would become akin to a fiat currency, and its issuer
   ensure full redemption of client funds. Although               to a central bank. Chances of this scenario occurring are higher if
   this is not a paper on regulation, clearly regulation          the particular form of e-money were required for purchases, such
   of e-money issuers must be quickly strengthened                as on a popular retail shopping site. This is akin to the government
                                                                  “generating demand” for domestic currency by requiring that taxes
                                                                  be paid in it.
                                                                     11Taken from Duffie (2019).

                                                                                          International Monetary Fund | July 2019   7
FINTECH NOTES

attractiveness as a means of payment. Clearly, this will         in their account, without any settlement lag and
depend on country circumstances and the technolog-               corresponding risks.
ical advancements adopted by banks to improve the             •• Trust: In some countries where e-money is taking
convenience of b-money. We will come back to this                off, users trust telecommunications and social media
point when discussing the impact of e-money growth               companies more than banks.12
on banks. But even where b-money can be exchanged             •• Network effects: If merchants and peers also use
very efficiently, e-money can bring additional benefits          e-money, its value to prospective users is all the
as noted below.                                                  greater. And as new users join, the value to all
   In China and Kenya, for instance, the question is             participants—existing and prospective—grows.
moot; e-money already rules. Ninety percent of Ken-
yans over age 14 pay with M-Pesa, and the value of               The first five reasons may be the spark that lights
e-money transactions in China, such as with WeChat            the fire of e-money; the sixth is the wind that could
Pay and Alipay, surpass those worldwide of Visa and           spread the blaze. The power of network effects to
Mastercard combined.                                          spread the adoption of new services should not be
   The adoption of e-money may also grow rapidly              underestimated. Why did we switch from email to text
elsewhere for one or several of at least six reasons:         messaging, and from text to social messaging plat-
•• Convenience: E-money is better integrated into our         forms like WhatsApp in such short periods of time?
   digital lives relative to b-money or central bank          The adoption of WhatsApp was one-third faster than
   money. It is typically issued by companies that            that of Gmail. And today, WhatsApp has surpassed
   fundamentally understand user-centered design and          Gmail in user-base and is well past the 1.5 billion
   integration with social media.                             users mark. The dominance of WhatsApp relative to
•• Ubiquity: Cross-border transfers of e-money would          standard text-messaging solutions is even more stark.13
   be faster and cheaper than of cash and bank depos-         At the beginning, however, all allowed communication
   its. However, various other hurdles might emerge,          in writing. Why did one form come to dominate? It
   such as requiring that market makers in foreign            was a tad easier on the social messaging apps, a tad
   countries be ready to provide redemption in local          more integrated with other features such as photos,
   currency. To limit the scope of this paper, we do          a tad friendlier, cheaper . . . But, importantly, it was
   not explore further the rich and important topic of        interoperable across providers, phones, and countries,
   cross-border payments using digital currencies.            and all our friends used it. We could even invite them
•• Complementarity: If assets like stocks and bonds           to group chats. Network effects amplified the small
   were moved to blockchains, blockchain-based                objective differences in features. WhatsApp in particu-
   forms of e-money would allow seamless payment              lar is a great example of a service that spread without
   of automated transactions (so-called delivery versus       any marketing, only through word of mouth—only
   payment, assuming blockchains were designed                through network effects.
   to be interoperable), thereby potentially realizing           Economists beware! Payments are not just the act of
   substantial efficiency gains from avoiding manual          extinguishing a debt. They are an exchange, an interac-
   back-office tasks. More generally, e-money function-       tion between people—a fundamentally social experi-
   ality more naturally lends itself to being extended by     ence. If two people use the same payment method, a
   an active developer community, which may draw on           third is more likely to join. And, yes, payments can
   open source codes as opposed to proprietary tech-          be fun, more fun, at least, in e-money and i-money
   nologies underpinning b-money. Developers could            than in paper bills. Emojis, messages, and photos, or
   for instance allow users to determine the goods that       perhaps a customer rating, cannot be sent with a mere
   e-money could purchase—a useful feature for remit-         debit card payment!
   tances or philanthropic donations.
•• Transaction costs: Transfers in e-money are nearly            12See for instance Cuthell (2019) and Sapienza and Zin-
   costless and immediate, and thus are often more            gales (2012).
   attractive than card payments or bank-to-bank                 13A thorough discussion of WhatsApp’s and Gmail’s growth is pro-

                                                              vided on their respective Wikipedia pages: https://​en​.wikipedia​.org/​
   transfers especially across borders. As a result, people
                                                              wiki/​WhatsApp​#User​_statistics and https://​en​.wikipedia​.org/​wiki/​
   might even agree to sell their car for an e-money          Gmail​#History​_2, and further discussion is available online such as
   payment as the funds would immediately show up             on https://​growthhackers​.com/​growth​-studies/​whatsapp.

8         International Monetary Fund | July 2019
The Rise of Digital Money

   This is where the world’s big tech companies and           adoption (though eventually leading to monopoly
fintech start-ups come in. They are experts at delivering     power and favoring first movers), the large fixed
convenient, attractive, low-cost, and trusted services        costs needed to establish operations at scale, and the
to a large network of customers. User-centered design         exponential benefits of access to data. Indeed, very
is second nature. They understand how people behave           large datasets allow inference of client behavior based
on social media and online. They can make payments            on near-randomized trials controlling for a rich set
integrate seamlessly. They did it once with social            of characteristics, as well as those of peers identified
media; they could do it again with money, whether             through transactions. In addition, firms may be able
with an “e” or even perhaps an “i” in front of it.            to extend their monopoly position to related services
                                                              which can also leverage the same dataset.
                                                                 Risks to monetary policy transmission, for instance,
Effects of E-money on the Banking Sector                      could emerge from currency substitution in countries
   If e-monies took off because of their attractiveness       with weak institutions and high inflation if new forms
as means of payment, backed by large big tech firms           of money become widespread. As usage of foreign
with large existing user bases—or nimble fintech              e-money spreads, the domestic unit of account could
start-ups—will that spell the demise of b-money and the       switch to that in which e-money is denominated. For
banks behind them? Will retail bank deposits migrate          instance, instead of redeeming e-dollars coming into
to e-money providers in large amounts? Not so fast. In        the country from remittances into domestic currency,
fact, banks are unlikely to disappear. This part considers    both merchants and households might be happy
three possible scenarios. First, however, it lays out other   holding e-dollars. Soon enough, merchants would start
risks of rapid e-money adoption for completion, though        pricing their goods in dollars. As a result, central banks
without going into details to limit this paper’s scope.       could lose monetary policy control.14
                                                                 Relative to financial integrity, decentralized tech-
                                                              nologies in particular raises new challenges. Issuers of
Risks of Rapid E-money Adoption                               blockchain-based money and their partners involved in
   Risks other than banking disintermediation are             onboarding clients and verifying transactions will remain
also possible and need to be understood and carefully         liable for anti–money-laundering and counter-terrorism
weighed. Regulatory frameworks generally exist to             financing (AML/CFT) obligations. These include identi-
tackle many of these risks, but likely need to be revised     fying customers, monitoring transactions, and reporting
and strengthened. For instance, financial services            suspicious transactions to the competent authorities, as
offered by big tech firms might be designated and reg-        well as respecting United Nations or country-specific
ulated as being globally systemic. One guiding princi-        sanctions lists. However, when transaction verification is
ple is that regulation should be proportionate with the       decentralized, and the number of entities involved (such
risks and types of services offered. Fintech firms that       as crypto-exchanges, governance bodies, wallet providers,
offer banking services would be regulated as banks, and       client fund managers, and market makers) very large
firms that offer the equivalent of investment funds, or       and fragmented across firms, sectors and countries,
broker dealer services, would be regulated as such.           enforcement of AML/CFT obligations becomes diffi-
   Earlier, we touched on risks to consumer protection        cult. If anything, international cooperation will become
and financial stability stemming from runs on e-money         all the more relevant to avoid regulatory arbitrage and a
which have features of CNAV funds. In addition, risks         dilution of regulation.
may emerge to privacy, monetary policy transmission,
seignorage following a drop in currency demand,
market contestability, financial integrity, as well as        Scenario 1: Coexistence
policymaking in general if precious data such as on              Returning to disintermediation risks, the first, and
cross-border capital flows were lost.                         most likely, scenario is that e-money and b-money will
   Risks to market contestability—namely the emer-            coexist; the battle will wage on. To begin with, banks
gence of large monopolies that hamper entry of new            are often in a position of strength. They have captive
firms and extract rents—may be difficult to contend
with. E-money providers may be natural monopo-                  14A recent speech (May 2019) by Tobias Adrian touches in these

lies due to the strong network effects spurring their         important issues. See also Edwards and Magendzo (2001).

                                                                                   International Monetary Fund | July 2019       9
FINTECH NOTES

                      Figure 4. Stylized Example of Deposit Substitution
                                                               (2) CDs funding
                                                               replaces deposit
                                       Bank                                            eMoney Provider
                                                               funding

                            Bonds                   Deposits                      Bank CDs               eMoney

                            Loans               Wholesale
                                                                      (1) Deposit
                                                                      outflow to pay
                                                                      for eMoney

                      Source: IMF staff.
                      Note: CD = certificate of deposit.

users—though potentially much smaller user bases than                        is leeway to increase rates on deposits without significant
large big tech firms—and strong distribution networks.                       macroeconomic consequences. Drechsler, Savov, and
They can cross-sell other financial services to customers,                   Schnabl (2018) point to banks’ market power as a prime
including means to overcome cash-in-advance con-                             explanation for the low and stable rates they tend to pay
straints by offering overdraft protection or credit lines.                   on deposits across countries. However, banks must cover
    Moreover, e-money providers might recycle many                           distinct costs such as deposit insurance fees, regulatory
of their client funds back to banks, as certificates                         costs, and branch networks.
of deposit or other forms of short-term funding                                  Banks could also rival the quality of payment
(Figure 4). Clearly, from the banks’ standpoint, the                         services in e-money, at least domestically, though
outcome is not optimal. First, they would swap cheap                         not necessarily across borders. In fact, b-money has
and stable retail funding for expensive and runnable                         grown increasingly convenient thanks to payment
wholesale funding. Second, they could be cut off from                        innovations such as touchless cards and phone-based
client relationships, and third they could lose access to                    apps that facilitate payments by debit card—such as
valuable data on customer transactions. In addition,                         Venmo, Zelle, or Apple Pay Cash in the United States.
funding from e-money providers might be concen-                              More fundamental change is also possible through
trated in a few large banks (though it would eventually                      “fast payment” systems rolled out by central banks in
trickle down to other banks). So smaller banks might                         many countries (as TIPS—TARGET instant payment
feel greater funding strains, or at least experience                         settlement—in the euro area) allowing banks to settle
greater volatility in funding.                                               retail transactions nearly in real time at negligible cost.
    In any case, banks can respond in three ways: offer                      A related example, though developed by a consortium
higher interest, improve services to retain deposits                         of banks, is Swish in Sweden. Even JPM Coin is a
(including by buying up promising startups), or find                         prominent example of how banks are fighting back by
other sources of funding.                                                    entering the e-money space.
    Banks have leeway to raise interest on deposits. Since                       But will banks adapt fast enough? Can they live and
banks make profits from maturity transformation (hold-                       breathe online customer satisfaction, user-centered
ing assets of longer term than deposit liabilities), they may                design, and integration with social media the way big
be able to offer higher interest than e-money providers,                     techs do? Are they sufficiently agile to change business
even than conservative i-money providers (note, Libra                        models? Some will be left behind no doubt. Others
has announced that it will not offer any interest to users).                 will evolve, but must do so quickly.
E-money providers must hold very liquid assets and                               In the transition, central banks can help. They can
thus could offer approximately overnight money market                        provide temporary liquidity if banks lose deposits
rates. Higher rates on deposits could be met with greater                    rapidly. But central banks will be reluctant to offer
operational efficiency, lower profits, and potentially                       this crutch for too long as their balance sheets might
slightly higher lending rates. Andolfatto (2018) argues                      grow, and they could become embroiled in difficult
that if banks start from a position of market power, there                   lending decisions. Short of this, banks can also find

10        International Monetary Fund | July 2019
The Rise of Digital Money

                           Figure 5. Stylized Example of Splitting the Payment and
                           Credit Functions of Banks
                                                            Bank

                                                   Bonds            Deposits

                                                   Loans           Wholesale

                                   Deposits used                              Wholesale funding
                                   to purchase                                to debt or equity
                                   eMoney                                     stake in fund
                                    eMoney Provider                Private Investment Fund

                                Bonds              eMoney          Loans           Wholesale

                           Source: IMF staff.

alternative forms of funding by issuing longer-term                mediated by markets. While we view this as the least
debt or equity.                                                    likely scenario, it is a contingency worth considering to
                                                                   better prepare for, and attempt to shape, the future.
                                                                      Commercial banks’ deposit-taking and credit func-
Scenario 2: Complementarity                                        tions could be split. The deposits we hold for payment
    In the second scenario, e-money providers could                purposes could migrate to e-money, and in turn could
complement commercial banks. This outcome is already               be held abroad, in government bonds, or in central
visible in some low-income and emerging market econ-               bank money. And those we hold as savings could be
omies. E-money can draw poorer households and small                channeled to mutual funds, hedge funds, and capital
businesses into the formal economy, familiarize them               markets for the allocation of credit. Alternatively, they
with new technologies, and encourage them to migrate               could remain in banks, which would themselves mostly
from making payments to seeking credit, more complex               rely on wholesale funding.
saving instruments, accounting services, and financial                The result would be a very different world and a
advice provided by commercial banks. In Kenya, for                 very different banking model (Figure 5). It would
example, credit growth increased steadily for several              greatly limit fractional banking. Fractional banks take
years as e-money was being rapidly adopted after 2008.             deposits but only hold a fraction of these in liquid
    But even in advanced economies, a partnership                  assets such as central bank reserves and government
could be envisioned. E-money providers could leverage              bonds; the rest is lent to households and firms and
their data to estimate customers’ creditworthiness, and            thus helps the economy grow.
sell their findings to banks or intermediate bank fund-               Would it be a desirable world? It depends on whether
ing for a more efficient allocation of credit. Moreover,           we believe fractional banks are an accident of history or
it is perfectly possible that some of the larger e-money           a socially efficient solution, and whether technological
providers will eventually migrate to the banking busi-             innovation changes their relative efficiency.
ness, bolstered by the data they have accumulated and                 Unfortunately, feelings are strong in this area, but
their scale, and attracted by the margins from maturity            empirics are scarce.15 How much liquidity would get
transformation. Thus, while today’s brands could dis-              locked up in e-money and no longer be available to
appear, the banking model is unlikely to be forgotten.             extend loans to the private sector? Currently, banks are
                                                                   able to lend the liquidity buffers we hold for a rainy
                                                                   day—to cover liquidity shocks such as dental work or
Scenario 3: Takeover                                               car repairs—assuming we will not all get hit by the
   The third scenario entertains a radical transforma-
tion of the banking model whereby banks mostly rely                  15Seminal papers in this field are Calomiris and Khan (1991),

on wholesale funding, and credit is increasingly inter-            Diamond and Rajan (2001), and Kashyap, Rajan, and Stein (2002).

                                                                                           International Monetary Fund | July 2019   11
FINTECH NOTES

same shock at once. Would only these buffers migrate                       Importantly, central banks also settle payments
to e-money, or would more? What about uninsured                         between banks. Otherwise, interbank payments
deposits? Could monetary policy offset the effect?                      would be expensive, slow, and potentially contentious.
Would credit to firms and households be rationed or                     Indeed, short of exchanging cash or gold, banks have
become more expensive as mutual and hedge funds                         to extend credit to each other in order to settle pay-
are required to receive funding before they can extend                  ments between themselves and their customers.
a loan? But don’t banks have to abide by the same                          This is where the central bank comes in. All banks
prudent rules in practice, despite being able to create                 hold accounts at the central bank, and a payment from
loans and deposits at the same time on paper? Would                     one to the other is settled by transferring perfectly safe
specialized funds develop to offer and hold nonstan-                    funds (called central bank reserves) from one account
dard and illiquid loans such as mortgages? Would these                  to another. Not only does this remove credit risk from
be able to lock in funding for long enough to support                   inter-bank transactions, it also ensures that payments are
credit even during stressed times? What portion of                      interoperable across banks. As a result, no single bank—
these loans could be securitized and mutualized? And                    however large its network—has an advantage in allowing
could the monitoring function that banks offer be                       payments among more customers. Interoperability is
taken up by funds, by specialized agencies with some                    essential to level the playing field between banks.
skin in the game, or simply by technology such as
artificial intelligence and big data analytics? And what
about the shadow banking sector, which we generally                     Tomorrow’s World: What If E-money Providers Could
believe is risky and under-regulated? Would funds flow                  Hold Central Bank Reserves?
from the shadows to e-money providers, and might                           What if providing a level playing field also meant
this enhance welfare?16 Whatever the answers to these                   offering settlement services to e-money providers?
questions, the transition could be rocky.                               What if these firms could also hold central bank
   It is urgent that we seek answers to these questions.                reserves, just like large banks, to the extent that they
With those in hand, we will be able to better assess                    satisfied certain criteria and agreed to be supervised?
the costs and risks of a world with more e-money. And                      The suggestion is not new. In fact, some central
only then will we be able to plan a course for policy,                  banks, such as the Reserve Bank of India, the Hong
leaning in favor or against this new world, which is                    Kong Monetary Authority, and the Swiss National
already emerging before our eyes.                                       Bank already offer special purpose licenses that allow
                                                                        nonbank fintech firms to hold reserve balances, sub-
                                                                        ject to an approval process. The Bank of England is
The Role of Central Banks and Synthetic CBDC                            discussing such prospects. Meanwhile, China has gone
   What will we use in the future as a means of pay-                    even further. The central bank requires the country’s
ment and store of value: e-money, or potentially even                   large payment providers, Alipay and WeChat Pay, to
i-money, issued by big tech firms, or commercial bank                   hold client funds at the central bank in the form of
deposits? Will e-money encroach on the fractional                       reserves. Despite these examples, many of the details
banks we know today? Policymakers will not be able to                   of the proposal to allow e-money providers to access
remain bystanders. Central banks in particular could                    central bank reserves would have to be worked out.
play a key role in shaping this future.                                    The ability to hold central bank reserves would fill
                                                                        the sails of e-money providers by allowing them to
                                                                        overcome market and liquidity risk, and would trans-
Today’s World                                                           form these into narrow banks. Narrow—as opposed
  To date, central banks have favored fractional banks.                 to fractional—banks are financial institutions that
As discussed earlier, central banks and other regulators                cover 100 percent of their liabilities with central bank
help ensure the safety of our deposits by supervising                   reserves and do not lend to the private sector. They
banks and offering liquidity when needed.                               merely facilitate payments.17

     16Such   is the argument in Greenwood, Hanson, and Stein (2016).     17A   seminal paper is Tobin (1987).

12             International Monetary Fund | July 2019
The Rise of Digital Money

   Fractional banks would feel greater pressure. For          related to the scenario of client funds being dispersed
one, they would no longer benefit from wholesale              across many banks. Assuming the elimination of
funding from e-money providers, as discussed ear-             default risk through appropriate legal structures and
lier. Nevertheless, banks should still be able to fight       potential regulatory reforms, e-money would then be
back with more attractive service offerings (scenario 1       credibly redeemable at par for domestic currency.
discussed earlier) and some e-money providers could              Second, central banks could ensure interoperability
persist in funding banks to seek higher returns (if given     of payments and thus protect consumers from the
the option), or could evolve into banks themselves            growth of e-money monopolies offering payments
(scenario 2 discussed earlier).                               among a large network of users. A payment from one
   While banks should be able to hold their ground in         to another in e-money must be shadowed by a shift of
normal times, a question mark arises in crisis times.         funds from one e-money provider’s trust account to
Would there be massive runs from bank deposits into           another’s. Only then would the newly held e-money be
e-money in times of crises? If client funds backing           fully backed and redeemable. Such contemporaneous
e-money were held as wholesale funding for banks, the         transfers of client funds would be seamless if carried
run could be in reverse, from e-money to b-money as           out on the central bank’s books. In addition, central
clients seek the protection of banks’ deposit insurance.      banks could require e-money providers with access to
But if client funds were held as reserves at the central      their accounts to adopt technological standards allow-
bank, then run risks cannot be discounted. Certainly,         ing e-money wallets to “talk to each other,” enhancing
uninsured deposits might migrate from banks to                interoperability and competition.
e-money providers.                                               Third, central banks and regulators might not be
   However, several points attenuate this apparent            able to contain the growth of large e-money monopo-
threat. First, in many countries, systemic bank runs are      lies. These could be large international firms operating
associated with runs to foreign currencies and would          as nearly natural monopolies given the importance of
thus occur irrespective of e-money. Second, there are         network effects, rents from access to data, and the sunk
already safe and liquid assets in many countries, such        costs required for entry. In that case, central banks
as Treasury-only funds, but they did not see massive          might want to give preference to domestic e-money
inflows during the global financial crisis. Third, while      providers operating under their direct supervision
bank runs can be destabilizing, they can be countered         by offering them the means to issue money that is
by central bank lending as long as the effects are tem-       perfectly safe and liquid, and thus potentially more
porary. In this case, lending to banks would balance          attractive than the foreign offering. This would also
inflows to central bank reserves. In any case, the risk of    allow central banks to retain seignorage revenue, to the
rapid disintermediation of the banking sector should          extent they did not pay interest on reserves held by
be taken seriously.                                           e-money providers.18
                                                                 Fourth, monetary policy transmission could be more
                                                              effective for two reasons. The first follows from the
Potential Advantages                                          above point. By offering an attractive means of pay-
   There are also important benefits to consider from         ment in domestic currency, substitution into foreign
offering e-money providers access to central bank             currency (“dollarization”) provided by global e-money
reserves, or potentially requiring e-money provid-            providers is less likely. Second, central banks could
ers to do so.                                                 pay interest on the reserves held by e-money provid-
   The first is ensuring the stability of e-money. As         ers. Doing so would more directly transmit monetary
argued earlier, trust in e-money can be shaken by             policy rates to consumers and—as argued earlier—put
default, market, liquidity and FX risk, as well as poten-     greater pressure on banks to offer rates on deposits
tial over-issuance relative to backing in client funds. All
can lead to costly runs and devaluations, undermine
confidence in the payments system, destroy significant           18If they did pay interest on reserves, and if competition in the

wealth, and ultimately put financial stability at risk.       e-money space forced providers to transfer this interest income to
                                                              e-money holders, then seignorage can be thought of as being rebated
E-money backed by central bank reserves can eliminate
                                                              to the population. Seignorage here is defined as the profits made
liquidity and market risk, and thus attenuate default         by the central bank by issuing liabilities at a rate lower than that
risk. It would also facilitate oversight of issuance          received on assets.

                                                                                    International Monetary Fund | July 2019     13
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