Engagement
Putting our research to work through testimony before lawmakers, regulatory filings, and policy letters.
Regulatory Filings
Comments to the Office of the Comptroller of the Currency on Exploring Special Purpose National Bank Charters for Fintech Companies
We reiterate and underscore the need for a Special Purpose National Bank charter that is suitable for digital payments companies.
Comments to the Office of the Comptroller of the Currency on Exploring Special Purpose National Bank Charters for Fintech Companies
A coherent national approach to regulating fintech companies will boost American competitiveness, foster technological innovation, and improve financial inclusion.
Fifth Letter to the Uniform Law Commission
We suggest optimal language to achieve the draft act’s policy goals in relation to control of tokens, personal use, and exclusions for licensed money transmitters.
Fourth Letter on the Uniform Law Commission’s Uniform Regulation of Virtual Currency Businesses Act
We generally support the current draft and have filed this comment to address some residual concerns with this important model legislation.
Comments to the Illinois Department of Financial and Professional Regulation in Support of the Proposed Digital Currency Regulatory Guidance
The state has taken a reasonable and transparent approach to regulation that does not attempt to stretch statutory interpretation or apply ill-fitting older rules to new technologies.
Comments to the Securities and Exchange Commission on the SolidX Bitcoin Trust
An insurance-backed Bitcoin ETF will be a component of responsible risk management for investors that will further the evolution of Bitcoin.
Comments to the Federal Elections Commission on Technological Modernization
The Commission seeks to understand “the unique nature of bitcoin” to determine what challenges, if any, it and other similar cryptocurrencies may pose under existing rules and regulations. In this comment letter we address some of the specific questions asked by the Commission, clear up…
Comments to the Office of the Comptroller of the Currency on Receiverships for Uninsured National Banks
Digital currency exchanges have similar risk profiles to chartered trust companies and can be safely governed by the same rules.
Third Letter on the Uniform Law Commission’s Uniform Regulation of Virtual Currency Businesses Act
Coin Center generally supports the current draft of the Uniform Regulation of Virtual Currency Businesses Act. We welcome the opportunity to submit a brief written comment to the committee outlining our residual concerns with this important model legislation.
Letter of Support for Congressional Fintech Policy Resolution
We applaud House Resolution 835 for forward-thinking leadership in encouraging the development of open digital currency networks and other financial technologies.