Engagement
Putting our research to work through testimony before lawmakers, regulatory filings, and policy letters.
Regulatory Filings
Comments to the Consumer Financial Protection Bureau on “Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications”
To whom it may concern: Coin Center is an independent nonprofit research and advocacy center focused on the public policy issues facing cryptocurrency technologies such as Bitcoin. Our mission is to build a better understanding of these technologies and to promote a regulatory climate that…
Comments to the Department of Treasury on “Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions”
To whom it may concern: Coin Center is an independent nonprofit research and advocacy center focused on the public policy issues facing cryptocurrency technologies such as Bitcoin. Our mission is to build a better understanding of these technologies and to promote a regulatory climate that…
Coin Center Suggestions to Address Uncertain Tax Treatment of Digital Assets
In Response to a Request for Feedback from Senate Finance Committee Chairman Ron Wyden and Finance Committee Ranking Member Mike Crapo
Further Comments to the Securities Exchange Commission on Amendments Regarding the Definition of ‘Exchange’ and Alternative Trading Systems
To whom it may concern: Coin Center is an independent nonprofit research and advocacy center focused on the public policy issues facing cryptocurrency technologies such as Bitcoin. Our mission is to build a better understanding of these technologies and to promote a regulatory climate that…
Comments to the Department of Treasury Regarding Ensuring Responsible Development of Digital Assets
This comment describes concretely why digital assets, and cryptocurrencies in particular, are essential to the operation of decentralized systems, and what the actual benefits of decentralization and disintermediation are for users.
Comments to the Securities Exchange Commission on Amendments Regarding the Definition of ‘Exchange’ and Alternative Trading Systems
A SEC proposal has a serious change hidden within its complex language. Our comment explains why it is unconstitutional.
Comments to the Thirty-First Legislature (2022) of the State of Hawaii on S.B. No. 3076 relating to special purpose digital currency licensure and S.B. 3025 relating to digital currency licensing program
Both of these bills would create a dangerously overbroad licensing requirement that could impose criminal liability on an untold number of Hawaiians
Proposals for Clarifying Laws Around Cryptocurrency and Blockchain Technologies in Response to Requests for Feedback from Senator Pat Toomey
Rather than promote policies that would benefit any particular business building on top of cryptocurrency networks, we seek policies that maximize the freedom to innovate using free and open blockchain networks. The American economic success story of the internet did not come to pass because…
Comments to the Financial Action Task Force on the March 2021 Draft updated Guidance for a risk-based approach to virtual assets and VASPs
We welcome this opportunity to comment on the FATF’s draft guidance. For clarity we have included a table of contents outlining our three major concerns with respect to the draft guidance as well as an addendum with a list of specific textual ambiguities and suggested…
Additional Comments to the Financial Crimes Enforcement Network on Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets
The procedural and statutory deficiencies in this rulemaking, detailed in our past two comments,1 have been ameliorated with the recent 60-day comment period extension2 and the passage of the 2021 National Defense Authorization Act (NDAA).3 We are especially heartened that FinCEN no longer wishes to…