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Commentary by Steven Lofchie

In extensive comments, the GFMA, FIA, the Institute of International Finance, ISDA, the Bank Policy Institute, the International Capital Markets Association and the Financial Services Forum expressed support for the Basel Committee on Banking Supervision design of a prudential framework for the treatment of cryptoasset exposures.

The Institute of International Bankers ("IIB") released a memorandum intended to help non-U.S. banking organizations obtain approval from the SEC to hold reserve account assets for SEC-registered broker-dealers. The memorandum provides a summary of standards foreign banks must satisfy to be eligible to establish a U.S. branch, and a general overview of how U.S. branches of foreign banks are regulated and supervised. Non-U.S. banks have historically been able to hold reserve account assets for broker-dealers. However, under a recent SEC's rule making, non-U.S. banks would essentially have to