3/ As we’ve grown along with the broader crypto industry, we’ve made it a point to cultivate members working on varied aspects of the diversifying field.
Our members innovate on lending, trading, mining, venture capital, network security, custody, DeFi, and more.
4/ So...we say it’s important to grow our membership. Why does that matter for the industry?
Speaking as a disciplined chorus, rather than brilliant soloists, that’s what DC lawmakers and regulators pay attention to.
Crypto is still young, and vulnerable to DC mood swings.
5/ The past 6 months are typical; from FinCEN trying to ban "unhosted" wallets, to the prospect of a crypto champion at the SEC, to new (sometimes crypto-skeptical) ppl at Treasury, to Musk rattling the cages...it’s vital to have a loud voice in DC to fight for the industry.
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/ 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.
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.
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:
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...
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.