Dear Ms. Ross:

My name is Jack Solowey, and I am a policy analyst for financial technology at the Cato Institute’s Center for Monetary and Financial Alternatives. I appreciate the opportunity to comment on the proposed rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications, which seeks to subject popular digital payment and wallet applications to Consumer Financial Protection Bureau (CFPB or the Bureau) supervisory authority. The Cato Institute is a public policy research organization dedicated to the principles of individual liberty, limited government, free markets, and peace, and the Center for Monetary and Financial Alternatives focuses on identifying, studying, and promoting alternatives to centralized, bureaucratic, and discretionary financial regulatory systems. The opinions I express here are my own.

The Bureau must provide a justification for the Proposed Rule that identifies the specific risks posed to consumers by popular digital payment apps, or else withdraw the Proposed Rule in its entirety. In the event that the Bureau does provide an adequate justification for the Proposed Rule based on specific risks, it must nonetheless expressly clarify that the Proposed Rule does not properly apply to self-hosted crypto wallets.