1/ Sen Warren sent a letter to Reps McHenry & Waters which argues “new regulatory frameworks around the $157B stablecoin market…could amplify and entrench…risks rather than mitigate them.”

That's backwards thinking – properly drafted stablecoin legislation helps, not hurts. 2/ Stablecoin settlement is instant, cheap, and frictionless – a more efficient way to move value around the globe. Treasury, the Fed, and policymakers agree that Congress should act on stablecoin legislation to protect consumers and our national security.

1/ Tomorrow, Dep. Sec. Adeyemo will testify before the Senate Banking Committee on the issue of illicit finance. With the Dep. Sec.'s primary focus on crypto's role in terror financing, we implore Congress to consider all of the facts.

🧵

banking.senate.gov/hearings/an-up… 2/ The digital asset industry is pro-law enforcement.

We applaud the work of the FBI, DOJ, and others for catching and prosecuting bad actors in our ecosystem. BA members include top blockchain analytics firms that support this critical work.

1/ Any amount of funding that goes to support terrorist activity – in any form – is too much.

We share many of Sen. Warren’s questions – and we think further examination will reveal the limited and dwindling role that crypto played.

forbes.com/sites/digital-… 2/ Why focus solely on crypto? We also encourage her and her colleagues in Congress to dig into the facts further, asking about the other – more significant – funding sources of Hamas.

reuters.com/world/middle-e…

1/ TODAY: we sent FOIA requests to the following govt agencies, seeking info on the potential de-banking of lawful crypto business:

FDIC
Board of Governors of the Federal Reserve System
and the OCC

theblockchainassociation.org/blockchain-ass… 2/ BA is investigating troubling allegations – including account closures and refusal to open new accounts – which have grown more concerning in the wake of this week’s banking crisis.

A crisis that long term crypto opponents have rushed to blame, incorrectly, on the technology.

1/ New York. The election is over and @GovKathyHochul has a full term ahead, so what’s next for crypto in the state…two paths to consider: 2/ The path forward: sign @clydevanel + @JSandersNYC's bill.

It creates a taskforce that gives NY time to examine how crypto benefits the under/unbanked, improve on existing regulation, improve city + state services & help NY reach its enviro goals.

nyassembly.gov/leg/?bn=A09275…

1/ Today we announced we filed an amicus brief supporting a correct interpretation of Howey in the SEC’s two-year legal battle against @Ripple.

A judge now has the opportunity to issue a substantive opinion on how Howey applies to digital assets.

Here's what's at stake🧵🧵🧵 2/ For years now, the SEC has chosen to target crypto through a "regulation by enforcement" pattern.

Rather than working toward joint solutions with industry members, they've instead sought to punish crypto companies with foggy and haphazard justifications.

1/Yesterday we submitted a letter strongly urging the SEC to approve NYSE Arca’s application to convert Grayscale's BTC Trust to an ETF.

sec.gov/comments/sr-ny… 2/Although we applaud the SEC’s recent decision to approve ETPs that hold bitcoin futures contracts, the time has come for the SEC to also approve spot bitcoin ETPs.

1/ Today, the SEC released an order disapproving @vaneck_us's proposal for a spot bitcoin ETF. We're disappointed by the SEC's continued refusal to give investors access to a spot bitcoin vehicle and strongly disagree with the decision. 2/ VanEck proposed an ETF that would hold actual bitcoin rather than expensive futures contracts that track bitcoin's price. Most experts believe this type of product is better for investors than the already-approved futures ETFs, because it’s less complex and incurs fewer costs.

1/ This week's hearing w/ SEC chair Gensler has re-sparked a false narrative: that crypto is a partisan issue.

D.C.’s reflexes may make it seem that there is a big divide on the promise of this tech, but beyond a few well-known partisans, we think crypto enjoys wide support. 2/ Some ground rules: “main street” is very crypto curious + engaged about the future of digital finance.

Case in point: according to Statista, ~2/3 of Americans are expected to use digital banking by next year. Crypto will be a big part of those services for many people.

1/ @blockchainassn and its 46 member companies—companies with tremendous expertise in the crypto ecosystem—appreciate the Senate’s ongoing engagement on the digital asset tax information reporting provisions in the bipartisan #infrastructurebill. 2/ While some minor improvements have been made, the latest language still poses fundamental concerns and questions about certain terms and definitions used in the provision.

1/ The Blockchain Association now has 40 members. We want to tell you about who’s joined the team…🧵 2/ We’re proud to welcome 8 new members: @AaveAave, @ClimateTrade, @edgeandnode, @hiFramework, @GenesisTrading, @Ledger, Metrika, & @investvoyager.

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…

1/ Check out this must-read thread by @jerrybrito re: a legal challenge to the FinCEN rule.

https://twitter.com/jerrybrito/status/1347200470385909770?s=20

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

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.

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.

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.

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…

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…

1/ With all the dark DC news of the past few days, it’s refreshing to hear some good news: the SEC has paved the way for the custody of digital asset securities by special purpose broker dealers.

sec.gov/news/press-rel… 2/ For a period of 5 years, the SEC will refrain from taking enforcement actions related to the Customer Protection Rule if the special purpose broker dealer meets the enumerated requirements listed in the statement.

sec.gov/rules/policy/2…

1/ Self-hosted wallets, a term you will likely hear more about as we roll in 2021. So, what are they and why are they important? A quick thread (with an in-depth report at the end): 2/ Simply put: self-hosted wallets allow individuals to engage in transactions over the internet on a peer-to-peer basis, with no other individuals or entities party to the transaction.

Quick thread on where we're at in the U.S. with securities law, plus what we're doing to address those issues 1/ Today, many securities, like real estate investment and corporate equity contracts, are ultimately paper-based.

“Tokenizing” these assets would make them easier to manage and trade, improving the efficiency and liquidity of such financial markets. 2/