The New York Department of Financial Services (NYDFS) has received an explanation from the Chamber of Digital Commerce (CDC) on the subject of exemption for BitLicense.
Perianne Boring is former Forbes participant and now – president of lobbying group founded in July in Washington, which purpose is the expansion bitcoin policy in the US through smart regulation for maintenance of the digital currency industry.
According to the provided CDC full analysis of the proposal NYDFS was offered to reconsider its interpretation of ‘virtual currency’ and ‘virtual currency business activities’ in avoidance so-called “egregious act of regulatory overreach”.
Also NYDFS was suggested to grant safety zones for startups, to release small businesses from regulation, to use the operating regulation more effectively and to prolong time period for comments (now it’s 45 days) thus that the industry had so much time, how many for it it is necessary for the full answer to the proposal.
As help option the CDC is ready to give all necessary information to the department’s members for proposal revision. Also the CDC hopes that it’s explanation will be useful to other society.
As told Boring for providing comments to the NYDFS were involved many beautiful words for the industry. Besides on their website are laid out The Digital Chamber’s explanations, which can be used by the industry if necessary.
Small business privilege
This way small businesses were protected by the CDC first of all because according to the New York law small business is defined as enterprise which has in the staff 100 people or less for stay outside the law. However Boring believe that it is necessary to exempt from observance and those companies which adhere to a certain quantity of assets.
Boring disagrees and says, that startups are greenhouse for innovation. Often they lead in a string larger players due to granting better products at lower prices. There should be no artificial barriers
for an entrance on the market, because they constrain development of interest to the market, also increase impudence of existing players and by that cause a significant damage to consumers.
The NYDFS is filing states and adapting small businesses by means of writing rules and provides them the mandate by Section 202-B of the New York Administrative Procedures Law.
Invest and innovate free!
At Section 200.8(b), which also got under a sight the CDC, contains information about maintenance bitcoin companies their profits and earnings in permissible investments estimated in US dollars. And the CDC means that on condition of maintenance by the businesses of full stocks it has to put investments beyond all bounds.
Certificates of deposit, money market funds, state or municipal bonds and US government securities – it’s everything that include permissible investments according to the proposal.
Also section 200.10 has to be reconsidered. In this section it is said that bitcoin businesses can start new products, render services or carry out any activity only from the written consent from the NYDFS.
Boring doubts about existence at NYDFS ingenuity in technical and business sense for adoption of lightning and exact decisions in respect of product development.
Also she noted that in the presence of the regulator operating the market, different harm of the industry will be done, and consumers won’t be protected.