Regulatory Comment Letters

Apr. 29, 2024 – Public Company Accounting Oversight Board (PCAOB)

Letter on U.S. BIS Proposed Rule on Infrastructure as a Services (Iaas) Products

Apr. 12, 2024 – Public Company Accounting Oversight Board (PCAOB)

Letter on Accounting Initiative Letter to PCAOB on Proof-of-Reserves

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

November 25, 2020- Financial Crimes Enforcement Network

October 2, 2020 – Digital Dollar Project

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

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

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

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

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

Chamber of Digital Commerce Verbal Testimony: McCutcheon v. FEC Notice of Proposed Rulemaking Hearing

December 23, 2014 – Consumer Financial Protection Bureau

Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z)

December 16, 2014 – Conference of State Bank Supervisors

Policy Framework: State Regulatory Requirements for Virtual Currency Activities CSBS Draft Model Regulatory Framework and Request for Public Comment

July 17, 2014 – NY Dept. of Financial Services

Proposed BitLicense Regulatory Framework for Virtual Currency Firms