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8 Jan, 7 tweets, 5 min read
1/ FinCEN's truncated comment period on the proposed rules regulating so-called "unhosted wallets" has ended.

The rule and process may be deeply flawed, but the community response of 7400+ responses has been inspiring. Here's a roundup of comment letters from BA members:
2/ First up, @cLabs & @CMTDigitalLtd:

medium.com/@jai_49950/cla…

cmtdigitalltd.medium.com/cmt-digital-co…
3/ @CoinList & @DCGco

beta.regulations.gov/comment/FINCEN…

4/ @ElectricCoinCo & @Grayscale

docs.google.com/document/d/1Ps…

5/ @StellarOrg & @krakenfx

resources.stellar.org/hubfs/SDF%20NP…

kraken.docsend.com/view/2fxvkmn77…
6/ And last, but certainly not least, @usv

drive.google.com/file/d/1uKYMBY…
end/ We are deeply grateful for the time and consideration our members have given to this matter, at an especially complicated time of year. These are complex issues at the best of times, even more so at the tail end of an outgoing admin, working to skirt the normal process.

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More from @BlockchainAssn

Blockchain Association Profile picture
7 Jan
1/ Check out this must-read thread by @jerrybrito re: a legal challenge to the FinCEN rule.
2/ We at @blockchainassn completely agree with this strategy -- step 1 is to challenge on procedural grounds, which we have a good chance of winning. If not, then step 2 is for @coincenter to lead the constitutional challenge
3/ As Jerry mentioned, @blockchainassn is on this. We’ve been engaged with @kirkland_ellis for weeks and are ready to file if/when the rule becomes final.
Read 12 tweets
Blockchain Association Profile picture
5 Jan
1/ Last night the Blockchain Association responded in support of the @USOCC’s NPRM entitled “Fair Access to Financial Services.”

theblockchainassociation.org/wp-content/upl…
2/ We support the proposed rule, which seeks to require that financial services are accessible to all customers and businesses engaged in legal activities.
3/ Crypto businesses have long struggled to get full and fair access to basic financial services over the past decade. This rule would open up those services and help crypto become further integrated into the global economy.
Read 4 tweets
Blockchain Association Profile picture
5 Jan
1/ Today we submitted our comment to FinCEN’s proposed regulation for “unhosted wallets.” Here’s a few of the most important points and our full response:

theblockchainassociation.org/wp-content/upl…
2/ Big point of basic fairness: Treasury should extend the comment period for the NPRM to *at least* 60 days so that the public can provide substantive feedback. We believe the truncated comment period runs afoul of fundamental tenets of good governance & requirements of the APA.
3/ And now to four glaring flaws:

1st—the rule would be an unprecedented and untested expansion of the Bank Secrecy Act (BSA) to include collection of counterparty information

2nd—money services businesses (MSBs) may be unable to comply with the proposed rule...
Read 7 tweets
Blockchain Association Profile picture
4 Jan
1/ 🚨🚨🚨 @USOCC just released a 3rd interpretive letter re: crypto networks and banks.

Big point: the letter explains that banks have the ability to connect directly with blockchains.

This is yet another notable, pro-crypto move from @USOCC.

occ.gov/news-issuances…
2/ The letter states that blockchains have the same status as other global financial networks, such as SWIFT, ACH, and FedWire.

This is a giant advance for crypto because it paves the way for these networks to be a formal part of the US financial infrastructure.
3/ Also, the idea of US banks contributing to the operations of the blockchains supporting stablecoins -- Ethereum, Stellar, etc. -- is a major step forward.
Read 4 tweets
Blockchain Association Profile picture
30 Dec 20
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."
Read 6 tweets
Blockchain Association Profile picture
23 Dec 20
1/ Have you had enough pre-holiday regulatory crypto news?

Treasury’s self-hosted wallet rule; SEC’s action against Ripple; & today’s action from the SEC on custody...and now we have a statement on stablecoin policy from a joint group of Trump admin officials...
2/ The President’s Working Group on Financial Markets (PWG) has issued a “Statement on Key Regulatory and Supervisory Issues Relevant to Certain Stablecoins.”

Here’s the full text: home.treasury.gov/system/files/1…
3/ So what’s this working group anyway? The PWG was created in '88 by Pres. Reagan to help regulators better address issues + crises w/i the financial sector (think fallout from Black Monday).

The group includes the Treasury Secretary, SEC Chair, CFTC Chair & Chair of the Fed.
Read 8 tweets

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