For example, according to the survey results, fixed-term deposits are the most common financial product among households (26%), and yet they are also one of the least known (just 73% have heard of them). The population segment least aware of this basic investment product is that with the lowest educational attainment and the lowest income (around 60% have heard of them).2  1  Real assets include principal residence, other real estate property (homes, building plots, rural property, garages, industrial premises, shops, commercial premises, offices and hotels) and the value of businesses related to selfemployment, jewellery, artworks and antiques. 2  Bover, O., L. Hospido and E. Villanueva (2018) “Survey of Financial Competences 2016: Main Results”. 4  The public’s lack of basic financial literacy is also evident in their unfamiliarity with the concept of risk diversification. Specifically, the Survey of Financial Competences gauges whether respondents understand that, generally speaking, a broad portfolio of equities will offer less volatile returns than a single share. According to the survey, only half of the population understands this concept. For some years the Banco de España has been implementing its Financial Education Plan, an initiative designed to help the public better manage their personal and household finances, and to foster what we now call “financial health”. This plan has been run from the outset in collaboration with the National Securities Market Commission and more recently with the Ministry of Economic Affairs and Digital Transformation.

Though the authority in the Dodd-Frank Act is limited in some ways—it applies only to certain systemically important activities and the designation process requires coordination across regulatory agencies and related administrative processes—the scheme is flexible in other ways because it contemplates an activities-based approach to regulation and oversight in addition to a prudential approach for certain institutions.33 To be crystal clear, I am not saying that any digital currencies are currently ripe for consideration under the FSOC designation process; just that a similarly flexible though not necessarily identical process involving coordination and collaboration across multiple regulators may be warranted. The Path Forward In applying lessons learned from the past to the modern era, one path forward might be to consider the following questions in determining whether a broader regulatory scheme is sensible: 1. First, who should be authorized to act as an issuer of a digital currency or as an intermediary that can hold or transfer a digital currency on behalf of a holder? And, is existing regulation adequate to cover each? If not, should we consider expanding the regulatory perimeter to address each from a prudential regulatory standpoint? 2. 3. 4. 5. Doing so would provide us with an avenue for addressing risks each may pose to holders or the system more broadly. Second, are there certain features of digital currencies that are either desirable or undesirable from a regulatory or policy standpoint? If so, are there restrictions or incentives we should adopt to avoid a recurrence of a landscape that resembles the wildcat era?