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handle is hein.crs/govefoz0001 and id is 1 raw text is: Digital Wallets and Selected Policy Issues

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April 18, 2022

Digital Wallet Landscape
A digital wallet is a software application that stores
payment or account details to facilitate traditional payments
that use bank and credit card details and/or cryptocurrency
transactions. In addition, wallets facilitate peer-to-peer
transfers, which have grown rapidly in recent years (Figure
1). This In Focus discusses three types of digital wallets and
addresses selected policy issues.
Functionality and Scope of Use
Digital wallets are generally used for (1) payments to
merchants through the use of near-field communication or
QR codes for in-person purchases; (2) peer-to-peer transfers
of funds through an app, via text message, or QR codes; (3)
storing value from a linked bank account or debit card on
an app-based account; or (4) storing, providing access to,
and transacting in cryptocurrency. (For more on
cryptocurrency, see CRS Report R45427, Cryptocurrency:
The Economics of Money and Selected Policy Issues.)
Digital wallets generally require the use of internet-
connected hardware, such as a smartphone. Some, including
Apple Pay and Google Pay, may work only with certain
devices and associated operating systems. Others, such as
the PayPal or Cash apps, can be downloaded and accessed
from a range of devices, irrespective of operating system.
For conceptual simplicity, it can be helpful to think of
digital wallets as belonging to one of three groups: retailer-
specific, general purpose, or cryptocurrency.
Figure I. Peer-to-Peer Transaction Value
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Source: eMarketer, https://www.emarketer.com/content/zelle-
recordis-explosive-q2-growth-faces ..rivals.
Retailer-specific mobile wallets are offered by a retailer for
use to purchase its goods and services. They allow
individuals to store payment card information, upload funds
to digital or registered gift cards, or prefund a balance on an
app for future transactions.
General purpose mobile wallets provide much of the same
functionality as retail-specific wallets do but are not limited

to a specific merchant. For example, someone might use a
wallet to make payments at a grocery store, purchase goods
online, or pay rent. General purpose mobile wallets include
apps tied to a smartphone and those that can be used on any
device. Often the companies that provide general purpose
wallets are regulated as money transmitters, a state-licensed
financial business that moves money between customers.
Cryptocurrency wallets can be divided into three types.
Custodial wallets are hosted or maintained by third-party
institutions (such as a crypto exchange). They are funded by
bank accounts, and most can be used to buy, sell, or trade
certain digital assets. Platforms that host custodial wallets
execute digital asset transactions on the account holder's
behalf and log them on the custodian's books (or off-
chain) rather than on the distributed ledger blockchain of
the coin. Non-custodial wallets are not hosted by third-party
institutions. They maintain the keys necessary to access and
sign the assets for transmission to blockchains and represent
the asset's location on the network. Loss of private keys
renders cryptocurrency irretrievable. A non-custodial wallet
user can transact in crypto without relying on a custodian.
Cold-storage wallets are pieces of hardware that allow end
users to store cryptocurrencies offline, a practice that
shields them from hacking. Cold-storage wallets can be
connected to the internet to perform transactions.
Policy Considerations for Digital Wallets
Wallets are not themselves accounts or payments but a
vehicle for accessing accounts or making payments. Many
policy issues that relate to accounts and payments, but not
wallets, are often conflated with digital wallet issues. Policy
issues highlighted below are specific to wallets.
Data Privacy and Security
Companies offering digital wallets and payments
companies generate, and may collect, information about
users as part of their business models, raising concerns
about privacy and data security. These companies are
subject to certain provisions of the Gramm-Leach-Bliley
Act (P.L. 106-102) that protect users' nonpublic personal
information (NPI). In particular, the act requires the
companies to provide privacy notices to consumers about
how they use their data and to safeguard the confidentiality
of NPI from unauthorized access, but they can typically
share information with affiliates and may share information
with nonaffiliates unless users opt out.
This policy issue may be addressed through a potential
proposed rulemaking for Section 1033 of the Dodd-Frank
Act (P.L. 111-203). Section 1033 requires any company or
individual offering financial services to provide information
it has collected in offering or providing the service to any
consumer that requests it. The law, which has not yet been

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