Steve Cecchetti and Kermit Schoenholtz respond to the 22 questions posed in the Fed's central bank digital currency (CBDC) discussion paper. In general, they doubt that the benefits of a U.S. CBDC will exceed the risks, and that other, less risky, means are available to achieve all the key benefits that CBDC advocates anticipate. But if the Fed were to go ahead, they suggest that there should be no cap on individual holdings, to avoid a premium on CBDC (compared to other central bank liabilities) that would just redirect runs into close substitutes (such as Treasury bills).
Also, the Fed should expect to pay interest on CBDC because it would be politically unsustainable for the Fed to pay interest on wholesale digital liabilities without paying interest on retail digital liabilities. Also, not paying interest on CBDC would diminish its attractiveness relative to other safe, liquid instruments. Plus, that interest will be in part a mechanism to compensate the private intermediaries for performing the necessary services of creating and maintaining accounts, verifying identities, tracking assets, implementing transactions, and monitoring for suspicious activity.
They acknowledge that these would increase run risk in the private financial system, but in their view all of the benefits expected from issuing CBDCs can be achieved less disruptively, and they provide alternative mechanisms for five widely claimed benefits. They see two potential developments that could make a U.S. CBDC worthwhile; (i) if regulation of stablecoins prove politically infeasible (see their earlier post), or (ii) if other highly trustworthy financial jurisdictions (with convertible currencies, credible property rights protections, and free cross-border flow of capital) offer their own CBDC.
If the Fed does go ahead an issue CBDC, offline capability would add to its attractiveness. When the internet is not available, mobile telephony could provide a backup, and to facilitate everyday payments, small transactions also should be feasible offline, via Bluetooth or NFC links.
