The New York Department of Financial Services (NYDFS) has published all comments the departments received regarding the BitLicense proposal. In general, the NYDFS received over 3,740 comments from individuals and some notable companies as well.
Such giants as Walmart, Western Union and Amazon have also provided their comments on BitLicense. Some foreign companies have also written to NYDFS, among others BTC China, Huobi and OkCoin.
In its comments, Western Union revealed concerns over the security of bitcoin ATMs users and asked to clarify the differences between the existing Money Transmission License and the new Virtual Currency License. The company wrote: “We are concerned, however, that the approach suggested in the Notice does not clearly address the interaction of VC (virtual currency) Licensees with New York money transmitted licensees (each, a “MT Licensee”) or provide enough clarity regarding select requirements applicable to VC Licensees, including the AML requirements.”
Western Union wanted to ensure it is not required to have a BitLicense even if the company works with bitcoin firms or with bitcoin. In its turn, the company suggested that every biotcoin ATM should have a license.
Meantime, Amazon requested the definition of payment methods that do not provoke the risks of money laundering (like the virtual currencies). It ‘s statement reads: “Amazon respectfully requests that the DFS expressly clarify that the following products are excluded from the definition of “virtual currency” in its final rulemaking: (1) “closed-loop” digital payment methods; and (2) prepaid access, stored value cards, or prepaid cards denominated in fiat currency.”
Walmart expressed asked to explain the BitLicense’s take on gift cards. The firm’s representative wrote: “As I mentioned, Walmart is concerned that the proposed language, as written, could be construed to capture gift cards… So maybe a simple statement that “gift certificates as that term is defined in NY Abandoned Property Law §103 are not considered to be Virtual Currency” tacked on to the part where they call out “affinity or rewards” programs would be perfect.”
New York Senator John Bonacic and assemblyman Kevin Cahill expressed concerns for non-profit organizations in the New York State, asking to exempt them. In its comments, the New York Bankers Association stated that the BitLicense should exempt regulated financial institutions. They feared that certain credit card reward points might be affected by the regulation.
The NYDFS superintendent and the creator of BitLicense, Benjamin Lawsky, is in plans to leave the agency next year.
The new BitLicense draft is planned to be issued in January, 2015.