Thread by @BlockchainAssn

1/ FinCEN’s deadline for comment on proposed regulation for “unhosted wallets” is Jan 4.

This is a wildly unreasonable window to review a rule that would be so consequential.

We’ve retained former Solicitor General Paul Clement to prepare a challenge to this process.

2/ Here’s the full text of a letter we sent to Secretary Mnuchin this morning.

We suggest reading through the entire document (attached), but here are a few statements that sum up our view of this process:

theblockchainassociation.org/wp-content/upl…

3/ "The highly truncated comment period [for the NPRM] sets up the government for failure on procedural grounds in the courts.

But far more important in the long run, the breakneck speed at which the proposed rule is proceeding all but guarantees a...flawed final product."

4/ “The NPRM claims to target money laundering, terrorism financing, and other illicit uses of convertible virtual currency or digital assets.

The Blockchain Association fully supports those laudable goals. But the proposed rule would do little if anything to advance them.”

5/ “At most...the proposed rule would lead those who wish to keep their transactions private to keep their digital currency in a self-hosted wallet, thereby reducing the very transparency that FinCEN purports to be trying to foster.”

end/ "There is a better way...FinCEN, Treasury, and the public would all be better served by extending the comment period to ensure that both stakeholders and regulators can give these weighty matters the full and fair attention they deserve."