海外之声 | 欧央行视角下的法定数字货币、金融科技与经济转型

导读

根据国际清算银行的测算，全球央行正在热烈地拥抱数字货币的新潮流与新趋势。数字货币的发展标志着金融科技的创新与经济转型的巨大潜力，构成了对于传统货币流通与经济规则的重塑与革新。欧洲央行始终走在技术与潮流的前列，致力于维持技术中性的同时兼顾居民支付行为的潜在转变。迄今为止，流通中的现金具有的价值与信任关系使得居民仍然保持较高的现金需求。欧洲央行的职责与使命很大程度上在于为未来的转型与变革做好准备。金融科技将加速无现金经济的到来，意味着居民不再持有无风险的央行现金资产，而基于金融基础设施与货币发行媒介保证安全的货币供应与可信赖的支付方式至关重要。欧元区内对于数字货币与无现金经济的辩论是分析性的，居民的消费行为偏好将决定其是否构成重要的政策议题。尽管数字货币仍然缺乏商业化的使用先例，但无法阻止探索数字货币的最佳设计形态，欧元区内的数字货币实验已经成为一项重要的议程。央行发行的绝大多数货币已经构成事实上的数字化，尽管名称不同于“央行数字货币”。央行同所有中央对手方的交易通过批发式的信贷操作实现，央行资产负债表的管理与央行真正的数字货币紧密相联。批发式的数字货币仅限于小部分金融机构的流通与使用，而零售式的数字货币将引领数字经济的革命。欧洲数字货币的法理依据在于欧盟法的授权，核心在于数字货币是否具有同传统货币一致的合法标的物，即跨越时空局限的普遍可交换性与应用性。那么央行是否有法理意义上排他性的数字货币发行权呢？两种潜在可行的构建数字货币体系的方式包括基于电子标记与基于央行的存款账户。前者有助于推动去中心化进程，保证央行的匿名性，而后者则基于庞大的货币存款保障数字货币自身的安全性。央行数字货币涉及到无数繁杂的技术细节与金融安全问题，包括私营部门的公法适用性与经济实体的监管。零售式的数字货币面临着的潜在风险在于其放大了金融机构的系统性风险，挤出数量庞大的银行存款，间接推动银行系统的金融脱媒。央行在发行零售货币的同时需要保证零售贷款业务的畅通，显著改变原有的面向客户的金融生态与央行重要的存贷便利货币政策的实施，出现风险超过潜在收益的情形。央行应当如何缓解数字货币对于金融体系的冲击呢？潜在的可行措施包括以低于市场利率的价格补贴数字货币的发行，激励非银行的金融机构基于二级市场的流动性交易，或者实施多层利率体系，规避负利率的风险与推动欧元资产的保值增值。更加理性成熟的政策建议仍然在酝酿之中。

欧央行将坚持技术中立与技术服务人民的原则以确保数字货币的实施在一个安全稳定与负责任的框架的运作，并始终对金融科技前沿的发展与经济转型保持开放的心态与高昂的热情。央行数字货币的试验并非简单的技术问题，而是深刻的政策与法律问题。为未来做好万分准备，是现代中央银行义不容辞的责任。

作者 | 伊夫·默什（Yves Mersch），欧央行执行委员会成员

英文原文如下：

An ECB digital currency – a flight of fancy?

Speech by Mr Yves Mersch, Member of the Executive Board of the European Central Bank and Vice-Chair of the Supervisory Board of the European Central Bank, at the  Consensus  2020 virtual conference, 11 May 2020.

A recent survey among 66 central banks by the Bank for International Settlements shows that more than 80% are working on central bank digital currencies (CBDCs).[1]

The European Central Bank is one of them.Not because we want to keep up with fashionable trends, but because we have to be ready. Ready to embrace financial technological innovation which has the potential to transform payments and money faster, and in more disruptive ways, than ever before.We are technology neutral. But if our customers, the people of Europe signalled a change in payments behaviour, we would want to preserve their direct link to the ultimate owner of our currency by maintaining their access to central bank liabilities in euro. Although cash often gets a bad press, demand is not receding. We currently see no indication that the public at large is willing to abandon the valued and trusted advantages of cash. But we are preparing to be ready should things change.

Part of ECB mandate to be ready for change

One implication of financial technological innovation could be an increasingly cashless economy in which people may no longer be able to hold risk-free central bank money. Reliable access to money would then hinge on the stability and efficiency of private retail infrastructures. And trust in money itself would rely on trust in the intermediaries that issue private money.[2]

This is one reason why central banks keep fully up to speed on financial technological developments. After all, providing safe money and a reliable means of payment have been an integral part of the mandate and core business of central banks since their very inception. The ECB is no exception.So we should be looking ahead and consider whether, in the future, central banks will need to provide the public with some form of digital currency. While electronic payments are already crowding out the use of cash in some countries, whose currencies seem less attractive than the euro, there is no such trend away from cash in the euro area. Some 76% of all transactions in the euro area are carried out in cash, amounting to more than half of the total value of all payments.[3] The demand for cash in the euro area currently outstrips the rate of nominal GDP growth. In crisis times, the demand for cash surges even higher. At mid-March this year, the weekly increase in the value of banknotes in circulation almost reached the historical peak of €19 billion.[4]The ECB’s debate on CBDCs is therefore mainly analytical. Whether and when it becomes more of a policy debate will largely depend on the preferences of households. We are always willing to innovate in the form of money and payment services that we provide. If, for instance, people voiced a preference tomorrow for plastic or polymer banknotes rather than the traditional paper ones, we would happily accommodate them. In the same vein, we closely follow technological developments and reflect on the type of money and payments that are best suited to the needs of an increasingly digital economy.The lack of a concrete “business case” for a CBDC at present should and does not stop us from seriously exploring the optimal design of a CBDC so that we will be well prepared should we evertake a policy decision to issue a digital currency. To this end, we have set up a task force on a CBDC within the Eurosystem.Let me give you a preview of our deliberations, starting with different design options.

Legally solid despite fancy design?

Most of the money issued by central banks is in fact already digital, albeit not called CBDC. This is true for the bulk of the money issued through our wholesale credit operations with our counterparties. At present, access to the central bank balance sheet offers the possibility to access digital central bank money.

What could change in the future is the scope of the parties eligible to access our central bank balance sheets. Indeed, this lies at the heart of the discussion on CBDCs.A wholesale CBDC, restricted to a limited group of financial counterparties, would be largely business as usual. However, a retail CBDC, accessible to all, would be a game changer. So a retail CBDC is now our main focus.Setting up a CBDC would require a solid legal basis, in line with the principle of conferral under EU law. One key consideration here is whether a retail CBDC could and should have the same legal tender status as banknotes and coins. In practice, legal tender status implies that a CBDC would have to be usable at any location and under any condition, possibly even offline. Without legal tender status, the legal basis would need to be clarified, as would the relationship between a CBDC and euro banknotes and coins, along with the process by which one could be exchanged for the other. Should it not be acknowledged that the ECB’s exclusive right to authorise issuance in euro would also be applicable to a digital issuance?A retail CBDC could be based on digital tokens, which would circulate in a decentralised manner – that is without a central ledger – and allow for anonymity towards the central bank, similar to cash. Some argue that a token-based digital currency might not guarantee complete anonymity.  If that proved to be the case, it would inevitably raise social, political and legal issues. We are currently looking into the legal questions raised by the potential use of intermediaries to facilitate the circulation of a CBDC and also the processing of transactions in a CBDC. To what extent are we permitted to outsource public law tasks to private entities? And what would be the appropriate extent of supervision over such entities?Alternatively, a retail CBDC could be based on deposit accounts with the central bank. Though involving vast numbers of accounts, it would not be a particularly innovative option from a technological viewpoint. For the euro area, it would basically mean increasing the number of current deposit accounts offered from around ten thousand to between 300 and 500 million. A CBDC of this nature would enable the central bank to register transfers between users, thereby providing protection against money laundering and other illicit uses (or those considered illicit by the rulers of the day), depending on the degree of privacy granted to users.These are just two of the many ways to design a CBDC. We are currently scrutinising the various options to assess their potential impact – both positive and negative – on the financial system and on our ability to honour our mandate.

Disintermediation – economically inefficient and legally untenable

You may wonder why central banks have not chosen to provide retail access to central bank money, despite the technology for an account-based CBDC already being largely available. The main reason is that introducing a retail CBDC could have major consequences for the financial system.

If households were able to convert commercial bank deposits into a CBDC at a rate of 1 to 1, they may find it far more attractive to hold a risk-free CBDC rather than bank deposits. During a systemic banking crisis, this could trigger digital bank runs of unprecedented speed and scale, magnifying the effects of such a crisis.Banks might manage to render their deposits more attractive than central bank ones. They could, for instance, provide additional services to those offered by central banks. Such services could include paying bills, or cross-selling financial insurance products. Otherwise – even in the absence of a crisis – a readily convertible CBDC could crowd out bank deposits, leading to the disintermediation of the banking sector. This  could have far-reaching implications  for the structure of the financial system and for the ability of central banks  to perform their core tasks and ensure that their monetary policy is transmitted to the real economy.If the central bank were to take retail deposits, it might also have to provide loans, with all the ensuing consequences. The central bank would need to launch customer-facing business lines. Deposit and lending facilities would also require the central bank to take on the burden of regulatory compliance in areas such as anti-money laundering, consumer protection and confidentiality.Some argue that this may reinforce monetary sovereignty, as disintermediation would make the financial system safer and reduce the moral hazard of banks by diminishing their role in money creation.[5]But disintermediation would be economically inefficient and legally untenable. The EU Treaty provides for the ECB to operate in an open market economy, essentially reflecting a policy choice in favour of decentralised market decisions on the optimal allocation of resources.Historical cases of economy-wide resource allocation by central banks are hardly models of efficiency or good service. Furthermore, a retail CBDC would create a disproportionate concentration of power in the central bank.These potentially highly adverse effects on the financial system would appear to outweigh the benefits envisaged by the introduction of a retail CBDC.What, then, could be done to mitigate the impact of a CBDC on the financial system?One option could be to remunerate CBDC at below-market rates in order to create incentives for non-banks to rely more on market-based alternatives rather than on central bank deposits. The drawback would be that, in times of crisis, it may become necessary to apply highly negative rates, which could generate criticism from the public and substantially undermine public confidence in the central bank as well as in the basic values of saving which underlie our societies.Another option is a tiered remuneration system.[6] In line with the functions of money, the first tier could serve as a means of payment. The central bank would have to refrain from setting a lower or a negative interest rate in order to keep a CBDC attractive to the public as a means of payment. While the second tier could serve as a store of value, the central banks could discourage people from using it as such by setting unattractive interest rates. However, such schemes should draw from the experience of multiple exchange rate regimes. And the repercussions of the intentional use of such schemes need to be subjected to an additional comprehensive investigation.So we have plenty of questions on CBDC to discuss. I am nearing the end of my speech but look forward to exchanging views with you during our virtual Q&A session.

Conclusion

In monitoring the evolution and uses of technology, the ECB respects technological neutrality. We do not serve technology – technology serves us. We will only introduce a digital currency if we become firmly convinced that it is both necessary and proportionate to fulfil our tasks in ensuring the stability of our currency.

In the meantime, we take a keen interest in digital innovation and in the changing expectations of money users, and we are refining our thinking on CBDC – both within the ECB, the Eurosystem and in the international central banking community. CBDC design choices are not merely technical questions. They have policy and legal implications. This is why we are devoting so much attention to every detail.If and when the time comes, we want to be ready – and we will be ready.

Notes1. See Boar, C., Holden, H. and Wadsworth, A. (2020), “Impending arrival – a sequel to the survey on central bank digital currency”, BIS Paper, No 107.2. Including payment solutions denominated in currencies other than the euro, which could affect monetary sovereignty.3. Survey data from 2017; see Esselink, H. and Hernández, L. (2017), “The use of cash by households in the euro area”, Occasional Paper Series, No 201, ECB.4. Blog post by Fabio Panetta, Member of the Executive Board of the ECB, (28 April 2020): “Beyond monetary policy – protecting the continuityand safetyof payments during the coronavirus crisis”.5. Dyson, B. and Hodgson, G. (2016), “Digital cash: why central banks should start issuing electronic money”,Positive Money.

6. See Bindseil, U. (2020), “Tiered CBDC and the financial system”, Working Paper Series, No 2351, ECB.

编译  谢智愚

编辑  李锦璇

来源  BIS

审校  金天、蒋旭

监制  董熙君、安然、魏唯

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