Regulatory Comment Letters
Feb. 19, 2024 – Financial Accounting Standards Board (FASB)
Letter on Next Steps for Crypto Asset Accounting Standards
Jan. 22, 2024 – Financial Crimes Enforcement Network (FinCEN)
Proposal of Special Measure Regarding Convertible Virtual Currency Mixing
Jan. 10, 2024 – House Financial Services Committee Subcommittee on Oversight and Investigations
Urging to Investigate the SEC’s Handling of Bitcoin-Related Matters
Jan. 5, 2024 – Senate Finance Committee and House Ways & Means Committee
Urging Consideration H.R. 1414, the Keep Innovation in America Act
Nov. 29, 2023 – U.S. Senate and U.S. House of Representatives
Letter of Support for National Defense Authorization Act (NDAA) Provisions
Nov. 15, 2023 – U.S. Internal Revenue Service
Proposed Regulations on Broker Reporting for Digital Asset Transactions
Nov. 2, 2023 – Office of the Secretary Public Company Accounting Oversight Board
Response to Proposed Amendments to PCAOB Rule 3502 on Contributory Liability Standards
Oct. 31, 2023 – U.S. Securities & Exchange Commission
Response to SEC Dissent – NFT Regulatory Framework
Oct. 30, 2023 – U.S. Internal Revenue Service
Response to Proposed Broker Regulations
Oct. 20, 2023 – New York Dept. of Financial Services
Response to Proposed Coin Listing Policy Framework
Oct. 19, 2023 – U.S. Securities & Exchange Commission
Amicus Brief Submission for U.S. SEC v. Binance.US
Sept. 8, 2023 – U.S. Senate Finance Committee
Comments on the Taxation of Digital Assets.
Aug. 23, 2023 – U.S. House Financial Services Committee
Comments on letter from Better Markets
Aug. 16, 2023 – U.S. Dept. of the Treasury
Comments on Illicit Finance Risk Assessment on Decentralized Finance
Aug. 11, 2023 – U.S. Securities & Exchange Commission
Amicus Brief on SEC v. Coinbase
June 20, 2023 – U.S. Securities & Exchange Commission
Comments on Amendments Regarding the Definition of “Exchange”
June 19, 2023 – U.S. Internal Revenue Service
Comments on Treatment of Certain NFTs as Collectibles
June 16, 2023 – National Institute of Standards and Technology
Identity and Access Management (IAM) Roadmap
June 5, 2023 – Financial Accounting Standards Board
Accounting Standards Update (Subtopic 350-60)
May 8, 2023 – U.S. Securities & Exchange Commission
Safeguarding Advisory Client Assets
May 2, 2023 – U.S. Securities & Exchange Commission
Questions Related to the SEC’s Staff Accounting Bulletin
April 19, 2023 – House Committee on Financial Services
Statement for the Record – “Understanding Stablecoins Role in Payments & the Need for Legislation”
April 18, 2023 – House Committee on Financial Services
Statement for the Record – Hearing entitled, “Oversight of the Securities and Exchange Commission”
April 12, 2023 – State of Texas
Letter to Texas Lieutenant Governor
March 28, 2023 – State of Illinois
Fintech-Digital Asset Bill; Financial Protection Bill
March 22, 2023 – California Senate Banking and Finance Committee
SB 401 (Límon): Cryptocurrency Kiosks
March 9, 2023 – House Committee on Financial Services
Statement to Subcommittee on Digital Assets, Financial Technology and Inclusion
March 3, 2023 – White House Office of Science & Technology Policy
Digital Assets Research & Development – Request for Information
February 22, 2023 – U.S. SEC v. Wahi
The Chamber of Digital Commerce’s Motion for Leave to File Brief of Amicus Curiae
December 15, 2022 – Financial Stability Board
Addressing the Regulatory, Supervisory, and Oversight Challenges Raised by Crypto-Asset Activities and Markets, and Global Stablecoin Arrangements
November 28, 2022 – U.S. Dept. of Energy
Response to Request for Information on Bipartisan Infrastructure Law
November 4, 2022 – U.S. Dept. of Treasury
Response to Request for Comment on Illicit Finance and National Security Risks
September 21, 2022 – Letter to California Gov. Newsom
Comments on Assembly Bill No. 2269
September 14, 2022 – Ripple v. SEC
Notice of Motion for Leave to File Amicus Curiae Brief
August 8, 2022 – U.S. Dept. of Treasury
Ensuring Responsible Development of Digital Assets; Request for Comment
July 5, 2022 – U.S. Dept. of Commerce
Notice and Request for Comment on Developing a Framework on Competitiveness of Digital Asset Technologies
May 25, 2022 – Federal Reserve
Request for Information Regarding Central Bank Digital Currencies
May 9, 2022 – Office of Science Technology Policy (OSTP)
Notice of Request for Information on the Energy & Climate Implications of Digital Assets
April 29, 2022 – OECD
Comment Letter: Crypto Tax Policy
February 25, 2022 – U.S. House Committee on Financial Services
Policy Recommendations for Digital Assets, Blockchain Technology & Decentralized Finance
February 14, 2022 – Financial Crimes Enforcement Network (FinCEN)
Information Response: “Review of Bank Secrecy Act Regulations and Guidance”
February 9, 2022 – U.S. Senate Committee on Agriculture, Nutrition & Forestry
Examining Digital Assets: Risks, Regulation, and Innovation
December 3, 2021 – International Organization of Securities Commissions
Consultative Report: Application of the Principles for Financial Market Infrastructures to Stablecoin Arrangements
Oct 18, 2021 – President’s Working Group on Financial Markets
Regulatory Framework to Address the Growth and Promise of Stablecoin Payments Systems
September 27, 2021 – U.S. Senate Committee on Banking, Housing, and Community Affairs
Request for Information on Clarifying Laws Around Cryptocurrency and Blockchain Technologies
September 22, 2021 – Financial Accounting Standards Board
September 20, 2021 – Basel Committee on Banking Supervision:
Comments in Response to the Consultative Document on the Prudential Treatment of Cryptoasset Exposures
July 27, 2021 – U.S. Senate Judiciary Committee
Hearing on “America Under Cyber Siege: Preventing and Responding to Ransomware Attacks”
July 16, 2021 – Federal Deposit Insurance Commission
Request for Information and Comment on Digital Assets
April 20, 2021 – Financial Action Task Force
April 5, 2021 – U.S. Securities & Exchange Commission
March 29, 2021 – Financial Crimes Enforcement Network
January 4, 2021- Financial Crimes Enforcement Network
- Comments to FinCEN NPRM: Recordkeeping and Reporting Involving Self-hosted Wallets Used in CVC and LTDA Transactions
November 25, 2020- Financial Crimes Enforcement Network
- Comments to FinCEN NPRM: Amending the Funds Travel Rule to Include Virtual Currency and Reducing Recordkeeping Threshold
October 2, 2020 – Digital Dollar Project
- Response of the Chamber of Digital Commerce to “The Digital Dollar Project: Exploring a US CBDC”
August 3, 2020 – Office of the Comptroller of the Currency
July 15, 2020 – Bank For International Settlements – Financial Stability Board
Addressing the Regulatory, Supervisory, and Oversight Challenges Raised by Global Stablecoin Arrangements
July 2, 2020 – Organisation for Economic Co-Operation & Development
June 1, 2020 – U.S. Securities & Exchange Commission
Comments to SEC Consultation on Capital Formation:
April 6, 2020 – Internal Revenue ServiceInformation Reporting for Digital Asset Transactions
March 31, 2020- Financial Crimes Enforcement Network
- Comments to FinCEN Guidance: Update on InterVASP Messaging Standard; Follow up Perspectives on Funds Travel and Transfer Rules; and Next Horizon Issues
March 13, 2020 – Basel Committee on Banking Supervision:
Designing a Prudential Treatment for Cryptoassets (December 2019)
March 4, 2020 – U.S. House Committee on Small Business
- Testimony for the U.S. House Committee on Small Business Building Blocks of Change: The Benefits of Blockchain Technology for Small Business Chamber of Digital Commerce Letter of Support
January 21, 2020 – U.S. District Court – Southern District of New York
Amicus Brief Advocating for a Predictable Legal Environment for the Blockchain Industry requesting the Court to apply the correct analytical framework in reaching its decision on a preliminary injunction in the SEC v. Telegram case.
November 26, 2019- Financial Crimes Enforcement Network
- Comments to FinCEN Guidance: “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies,” FIN-2019-G001 (May 9, 2019)
May 16, 2019 – IFRS Interpretations Committee
Comments on the accounting treatment of digital assets
May 15, 2019 – Joint Canadian Securities Administrators & the Investment Industry Regulatory Organization of Canada
Comments on Consultation Paper 21-402 – Proposed Framework for Crypto-Asset Trading Platforms
April 8, 2019 – Financial Action Task Force
Comments to the Financial Action Task Force (“FATF”):
August 9, 2019 – Department of Finance Canada
Comments on legislative proposals released May 17, 2019 to treat virtual currency as a financial instrument for GST/HST purposes
July 30, 2019 – U.S. Senate Committee on Banking, Housing, and Community Affairs
Hearing on “Examining Regulatory Frameworks for Digital Currency and Blockchain”
July 29, 2019 – International Organization of Securities CommissionsPublic Comment on Issues, Risks, and Regulatory Considerations Relating to Crypto-Asset Trading Platforms
February 18, 2019 – Dept. of Finance, Canada
Ontario Spring Budget Consultation 2019
- Chamber Comments
February 18, 2019 – U.S. Consumer Financial Protection Bureau
Encourage agency to foster blockchain innovation and permit the introduction of new financial products based on blockchain technologies.
February 18, 2019 – U.S. Commodity Futures Trading Commission
Request for Input on Crypto-Asset Mechanics and Markets; Virtual Currency RFI.
October 13, 2018 – Global Financial Innovation Network
Comments on GFIN’s Consultation Document dated August 2018
September 7, 2018 – Dept. of Finance, Canada
Comments to Government of Canada: Regulations Amending Certain Regulations Made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, 2018 (the “Proposed Regulations“) published in the Canada Gazette on June 9, 2018
March 20, 2018 – U.S. Commodity Futures Trading Commission
Retail Commodity Transactions Involving Virtual Currency; Proposed Interpretation and Request for Comment (RIN 3038-AE62)
November 28, 2017 – U.S. Senate Judiciary Committee
Hearing on “S. 1241: Modernizing AML Laws to Combat Money Laundering and Terrorist Financing”
October 12, 2017 – U.S. Securities & Exchange Commission
Comments to SEC Investor Advisory Committee Meeting
July 17, 2017 – UK Financial Conduct Authority
Chamber of Digital Commerce Response to the UK FCA’s Discussion Paper on Distributed Ledger Technology
July 17, 2017 – Uniform Law Commission
Uniform Regulation of Virtual Currency Businesses Act
June 15, 2017 – European Commission
Comments on Consultation Document: FinTech – A More Competitive and Innovative European Financial Sector
June 8, 2017 – Financial Accounting Standards Board
March 31, 2017 – Financial Industry Regulatory Authority
Comments on FINRA’s Report on Distributed Ledger Technology: Implications of Blockchain for the Securities Industry
January 18, 2017 – Illinois Dept. of Financial & Professional Regulation
Comments on the proposed IDFPR Digital Currency Regulatory Guidance
January 17, 2017 – Office of the Comptroller of the Currency
November 15, 2016 – Uniform Law Commission
Comments on the October 2016 Draft of the Regulation of Virtual Currency
September 12, 2016 – U.S. House Energy & Commerce Committee
H.Res.835 – Expressing the sense of the House of Representatives that the United States should adopt a national policy for technology to promote consumers’ access to financial tools and online commerce to promote economic growth and consumer empowerment
September 2, 2016 – European Securities & Markets Authority
Comments in response to its discussion paper titled “The Distributed Ledger Technology Applied to Securities Markets“
June 29, 2016 – Washington State Dept. of Financial Institutions
Comments on the June 30, 2016 Draft Amendments to the Uniform Money Services Act
May 31, 2016 – Office of the Comptroller of the Currency
Comments in Response to the Publication entitled Supporting Responsible Innovation in the Federal Banking System
May 12, 2016 – Uniform Law Commission
Comments on the April 18, 2016 Draft of the Regulation of Virtual Currency Businesses Act
March 16, 2016 – U.S. House Energy & Commerce Committee
Hearing, Disrupter Series: Digital Currency and Blockchain
February 25, 2015 – NY Dept. of Financial Services
Revised BitLicense Regulatory Framework
February 11, 2015 – Federal Elections Commission
December 23, 2014 – Consumer Financial Protection Bureau
December 16, 2014 – Conference of State Bank Supervisors
July 17, 2014 – NY Dept. of Financial Services
Proposed BitLicense Regulatory Framework for Virtual Currency Firms