The 1% exposure limit applies only to Group 2 assets. It means that because Group 2 assets are extremely risky, banks won’t be allowed to have much in the way of exposure to them. In the example above, J.P. Morgan has Tier 1 capital of 13.7% of total risk-weighted assets. So for J.P. Morgan, total Group 2 crypto asset holdings (including bitcoin) can’t be more than 0.137% of its total risk-weighted assets – and considerably less of its total assets unweighted for risk. Admittedly, for a bank the size of J.P. Morgan, that is still a lot of bitcoin. But it’s worth remembering that the previous version of the BIS proposals, issued in June 2021, didn’t impose a total exposure limit. So, far from encouraging banks to hold bitcoin, the revised proposals actually make it more difficult.
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