Regulatory Filings

Coin Center amicus brief in U.S. v. Coinbase

Coin Center filed this amicus curiae brief in federal court opposing the IRS’s overbroad and indiscriminate request for Coinbase customer financial records

Comments to the Securities and Exchange Commission on the Bitcoin Investment Trust

This would give the investing public a safe and secure financial instrument on a national securities exchange with which to obtain the bitcoin exposure they seek.

Letter to the Government of India, Department of Economic Affairs

We share six principles that we have found to be at the heart of successful approaches to government regulation of or self-regulation by the open blockchain industry.

Sixth Letter to the Uniform Law Commission

Our final comments on the ULC’s model Regulation of Virtual Currency Business Act offer several critically important changes. 

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.

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 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.

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

Bitcoin political contributions should not be subject to a $100 limit.

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's 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.

Comments to the European Securities and Markets Authority on its Consultation on Distributed Ledger Technology Applied to Securities Markets

Our comments on ESMA’s conclusion that “open” or “permissionless” blockchains may be inappropriate for financial services in its discussion paper entitled, “The Distributed Ledger Technology Applied to Securities Markets.”

Letter to the Washington Department of Financial Institutions

Concerning draft legislation that the Department of Financial Institutions is helping develop that would add virtual currency to Washington’s money transmission law.

Letter to the to the California Senate Banking and Financial Services Institutions Committee

Coin Center sent this letter outlining its concerns with the amended language of California's Assembly Bill 1326 Digital Currency. 

Second Letter to the Uniform Law Commission

Coin Center submitted this letter to the Uniform Law Commission regarding regarding definitions proposed by Coin Center for the Uniform Regulation of Virtual Currency Businesses Act (URVCBA).

Letter to the Uniform Law Commission

Coin Center submitted this letter to the Uniform Law Commission regarding its model law to license virtual currency businesses.

Letter to Conference of State Bank Supervisors

Coin Center submitted this letter to the Conference of State Bank Supervisors regarding its Model Regulatory Framework for Virtual Currency Activities.

Letter of Support for AB 1326 to California State Senate

The updated bill would create a smart licensing regime for virtual currency businesses in the state.

Second Letter to California State Assembly

A second letter regarding the California State Assembly's virtual currency bill.

Letter to California State Assembly

The California State Assembly is considering a digital currency bill. Here is what we told them. 

Comment on Revised NY DFS BitLicense Proposal

The updated proposal is better but we still have some concerns. Here is what we told the NY DFS. 

CFPB Proposed Rules Relating to Prepaid Accounts Comment

The Consumer Financial Protection Bureau may apply rules meant for prepaid products to digital currency businesses. We recommend against it. 

CSBS Virtual Currency Framework Comment

The Conference of State Bank Supervisors has issued a forward thinking draft model state regulatory framework for virtual currency activities

New York BitLicense Comment

Submitted on behalf of Coin Center, The Center for Democracy and Technology, and TechFreedom.

Based in Washington, D.C., Coin Center is the leading non-profit research and advocacy center focused on the public policy issues facing cryptocurrency and decentralized computing technologies like Bitcoin and Ethereum. Our mission is to build a better understanding of these technologies and to promote a regulatory climate that preserves the freedom to innovate using permisionless blockchain technologies.