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2:53 - Dr Lucien van Romburg: Social Dimension of CBDCs
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4:44 - The Core Argument: CBDCs Need Broader Social Consideration
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9:47 - Stakeholders, Public Participation & When Not to Issue a CBDC
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15:33 - Retail vs. Wholesale CBDCs Explained
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21:42 - Inclusion, Consumer Protection & Public Understanding
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32:11 - Prof. Dirk Zetzsche and Marian Unterstell Overview
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35:35 - Problems with the EU Sustainable Finance Framework
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40:28 - Intended Audience & Why Current Regulation Falls Short
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43:46 - Exclusionary ESG Approaches vs. True Impact Investing
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49:23 - The Five Reform Points: Shifting from Inputs to Proven Impact
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54:26 - The Materiality Principle & Reducing Reporting Overload
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1:00:26 - Key Takeaways: Impact Over Compliance
Building Better Financial Systems
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Advancing the Impact Investing Framework + The Social Dimension of CBDCs
Ep #85 with Prof Dirk Zetzsche, Marian Unterstall, and Dr. Lucien van Romburg
Disclaimer: The views expressed in this podcast are solely those of the host and speakers.
Today’s episode starts with a spotlight discussion with Dr. Lucien van Romburg of UNSW, on an article he recently co-authored with Scientia Professor Ross Buckley about including broader social dimensions into the decision to issue central bank digital currencies (CBDC). After that, we chat with Professor Dirk Zetzsche and Marian Unterstell, both from the University of Luxembourg, about their article on the road towards a European Union impact investing framework.
Dr. Lucien van Romburg is a postdoctoral research fellow at the School of Private and Commercial Law and a member of the Faculty of Law & Justice at UNSW-Sydney.
Professor Dirk Zetzsche is Professor Dirk Zetzsche is a professor of financial law, the ADA Chair in Financial Law (Inclusive Finance), and co-lead at the University of Luxembourg’s National Centre of Excellence in Financial Technology Research & Innovation. He is also coordinator of the House of Sustainable Governance & Markets, and a member of the University’s Faculty of Law, Economics and Finance, as well as head of its Law Department.
Marian Unterstell is a doctoral researcher, ADA Chair in Financial Law (Inclusive Finance), and a member of the University of Luxembourg’s Faculty of Law, Economics and Finance.
PODCAST DISCUSSION. The spotlight chat commences with Lucien van Romburg sharing with Regulatory Ramblings host Ajay Shamdasani on why broader social dimensions should be considered before central banks issue CBDC. His recent article on the matter, which he co-wrote with UNSW Scientia Professor Ross Buckley, is entitled The Need to Address the Broader Social Dimensions in Any Decision to Issue A Retail Central Bank Digital Currency and appears in Volume 48(3) of the UNSW Law Journal.
The abstract to the article states: “Central banks, in deciding to issue a Central Bank Digital Currency (‘CBDC’), tend to focus on how it might best support their policy objectives. While central banks typically view themselves as being in the service of society, the ‘need’ for a CBDC will usually be assessed within the scope of their primary mandates, traditionally concerned
with monetary policy. This is problematic, as grounds for the issue of a CBDC that fall outside this scope may not be considered fully. We suggest that the broader needs of society and the effects of a retail CBDC should be given substantial weight in decisions concerning a potential CBDC. States should collaborate with central banks and other diverse sources of expertise to ensure broad public engagement and participation in deciding whether there is an actual need for a CBDC, as well as its design.”
Lucien proceeds to explain why he and Ross decided to write the article and what he believes it adds to an already large and growing body of literature on CBDC, as well as why it is problematic to looks at CBDC issuance primarily through the lens of monetary policy. As Lucien and Ross stress in their article: “States should collaborate with central banks and other diverse sources of expertise to ensure broad public engagement and participation in deciding whether there is an actual need for a CBDC, as well as its design,” to emphasize that CBDC may not always be recommended. They cite the experience of the Bank of Finland’s issuance of its Avant Smart Card (often dubbed the world’s ‘first CBDC’ – although no Distributed Ledger Technology or Blockchain Technology was used in its development) as a cautionary tale of the importance of clarity about the precise reasons for issuing a retail CBDC. “We ultimately argue that as CBDC issuance will have society-wide effects, decisions concerning a potential CBDC, including whether there is an actual need for one, should involve multiple agencies within government, and broad public engagement and participation. It should not be a process driven only by central banks and directed only through the lens of their monetary policy mandates,” they say. Lucien takes great care to distinguish between wholesale and retail CBDCs by saying: “The arguments for a wholesale CBDC are quite different, with wholesale CBDCs potentially offering substantial efficiency gains in cross-border trade transaction payments, and capital market transactions…This article focuses upon retail CBDCs – those designed for use by the general population, not major banks and corporations. Whereas a retail CBDC could be used by households and businesses to effect online transactions and transfers of funds to family and friends, a wholesale CBDC would only be accessible to a limited range of market participants, such as commercial banks, and would be used to effect wholesale payments and settlements.” Lucien and Ross’ analysis shows that although central banks serve the general public in performing their mandates, “their perceptions on the need for a CBDC may be restricted by the scope of their primary mandates, which are traditionally concerned with monetary policy and financial stability. This is problematic, as the grounds for and consequences of a CBDC issuance that fall outside this scope may not be fully considered.” The discussion concludes with Lucien articulating what policy positions he and his co-author advocate for.
IMPACT INVESTING FRAMEWORK. We also chat with Professor Dirk Zetzsche and Marian Unterstell (University of Luxembourg) about their recent article entitled Towards an EU Impact Investing Framework, co-authored with Professor Ross Buckley (UNSW-Sydney) and the Professor Douglas Arner (University of Hong Kong) and team leader of this podcast.
The abstract to their article notes: “Sustainability-oriented investors want to pay for impact, not compliance. We analyze the regulatory challenges and opportunities of impact investing. We find that advancing impact investing requires a departure from the EU Sustainable Finance Framework's (EUSFF) prevailing input-orientation and an adjustment of EU asset-management law towards an EU Impact Finance Framework.”
“In its current form, the EUSFF over-emphasizes exclusion, using rule-based ex ante definitions of sustainable business (herein termed input). If a large share of global capital follows these rules, unsustainable firms’ capital costs will increase, furthering innovation of sustainable alternatives. However, the EUSFF alone cannot prevent global capital flows into unsustainable investments, and non-EU countries follow different approaches. Although the EUSFF encourages, in effect, the sale of unsustainable EU businesses to non-EU firms, its input orientation has not helped the planet: the same activities continue elsewhere, often under weaker environmental and social standards, leaving the planet worse off. Further, the EUSFF’s disregard for proven ex post impacts risks large-scale capital misallocation and “impact washing”. Worse, the input focus comes at the cost of investments paired with audited evidence of positive ESG impacts ex post.” “We argue for shifting EU financial regulation from input to (proven) impact. Yet, rather than adding a new product category, we propose recognizing positive impacts through five fine-tuned steps that simplify EU financial regulation, taking into account regulatory developments in the United Kingdom and Switzerland. These include abolishing the link between “do no significant harm” under the Taxonomy Regulation and the Sustainable Finance Disclosure Regulation, simplified reporting aligned with product materials and the emerging IFRS Disclosure Standards, introducing a new proportionality threshold for mid-sized AIFMs, and revising ESMA’s rules on fund names.” Dirk and Marian share with Ajay the timing for their article as well as their intended audience, and the policy outcomes they would ideally like to see. Dirk acknowledges the burdens EU companies are under to report on multiple variables and noted that when it comes to European legislative reform, it was intriguing that the EU’s draft came out 10 days after the release of their article.
Regulatory Ramblings podcasts is brought to you by The University of Hong Kong - Reg/Tech Lab, HKU-SCF Fintech Academy, Asia Global Institute, and HKU-edX Professional Certificate in Fintech, with support from the HKU Faculty of Law.
Useful links in this episode:
You might also be interested in:
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Must have book by Ross Buckley, Douglas Arner & Dirk Zetzsche - FinTech: Finance, Technology & Regulation
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Building Better Financial Systems: FinTech Sustainability - Research
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HKU-SCF Fintech Academy - website
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Asia Global Institute - website
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Most sought after Fintech course on edX - Introduction to Fintech
Regulatory Ramblings Podcasts List

Regulatory Ramblings Podcast
Welcome to Regulatory Ramblings, a podcast from a team at The University of Hong Kong on the intersection of all things pertaining to finance, technology, law and regulation. Hosted by the HKU Reg/Tech Lab, HKU-Standard Chartered FinTech Academy Asia Global Institute, and the HKU-edX Professional Certificate in FinTech, join us as we hear from luminaries across multiple fields and professions as they share their candid thoughts in a stress-free environment - rather than the soundbites one typically hears from the mainstream press.
Regulatory Ramblings is a forum for those that appreciate long-form conversation. While it is something that may be regarded as lost art of an older time, it is nonetheless sorely needed in an age when glibness and flippancy pass for analysis in conventional journalism.
Having said that, we are grateful to be able to avail ourselves of modern technological resources to bring you chats with people you are probably not going to hear from elsewhere.

Ajay Shamdasani is a veteran writer, editor and researcher based in Hong Kong. He holds an AB in history and government from Ripon College, JD and MIPCT degrees from the University of New Hampshire Franklin Pierce Law School, and an LLM in financial regulation from the Illinois Institute of Technology’s Chicago-Kent College of Law.
His 15-year long career as a financial and legal journalist began as deputy editor of A Plus magazine – the journal of the Hong Kong Institute of Certified Public Accountants. From there, he assumed the helm of Macau Business magazine as its editor-in-chief, and later, joined Asialaw magazine as its deputy editor. More recently, he spent close to seven years as a senior correspondent with Thomson Reuters’ subscription-based trade-wire service Regulatory Intelligence/Compliance Complete (previously called Complinet) in Hong Kong. While there, he covered regulatory developments in that city, as well as Singapore, India and South Korea.




















