MTBiz is for you if you are looking for contemporary information on business, economy and especially on banking industry of Bangladesh. You would also find periodical information on Global Economy and Commodity Markets.
Smart Contracts in Financial Services: Getting from Hype to Reality. Reporteraser Juan José Calderón
Smart Contracts in Financial Services: Getting from Hype to Reality.
Executive Summary
The potential of smart contracts – programmable contracts that automatically execute when pre-defi ned conditions are met – is the subject of much debate and discussion in the fi nancial services industry.
Smart contracts, enabled by blockchain or distributed ledgers, have been held up as a cure for many of the problems associated with traditional fi nancial contracts, which are simply not geared up for the digital age. Reliance on physical documents leads to delays, ineffi ciencies and increases exposure to errors and fraud. Financial intermediaries, while providing interoperability for the fi nance system and reducing risk, create overhead costs for and increase compliance requirements.
In this report, we aim to cut through the speculation and hype around the potential of smart contracts. We have conducted detailed discussions with fi nancial services industry professionals, prominent smart contract startups, and academics (see Research Methodology at the end of this paper). Our study confi rms that smart contract adoption will lead to reduced risks, lower administration and service costs, and more effi cient business processes across all major segments of the fi nancial services industry. These benefi ts will accrue from technology, process redesign as well as from fundamental changes in operating models, as they require a group of fi rms to share a common view of the contract between trading parties. Consumers will benefi t from more competitive products, such as mortgage loans and insurance policies, along with simpler processes that are free of many of the hassles of today’s customer experience.
FirstPartner's 2016 Blockchain Ecosystem Market Map helps to decrypt the blockchain landscape with a visual overview of the emerging ecosystem, players, technologies and trends. It clearly summarises three main areas of focus emerging around the core blockchain or distributed ledger protocols:
1) Bitcoin and Cryptocurrencies: Providing an alternative to centrally managed "fiat" currencies, this sector includes Bitcoin exchanges, Bitcoin wallets, miners and cryptocurrency payment processors. The map illustrates how these companies interact and features some leading players including Coinbase, Circle, Kraken and 21 Inc.
2) The Financial Services Blockchain: This has been the main area of focus over the last 12 months as attention shifts from Bitcoin to Financial Services applications. An increasing number of players are focussing on commercialising blockchain technologies for banks, securities, derivatives and asset markets and institutional investors - and are attracting VC funding to do so. Ripple and Ethereum are leading candidate protocols for payment processing and smart contracts and players including Ripple, Chain and Digital Asset Holdings are gaining traction with Financial Institutions. The Map highlights leading technology companies and some of the banks, card schemes and processors who are investing in or evaluating distributed ledger technologies.
3) Other Use Cases: The distributed ledger concept and its ability to support transparent and tamper-proof asset registration, proof of ownership and asset transfer transactions makes it potentially applicable to multiple non financial use cases. The Map highlights a number of candidate use cases including publishing, legal, distributed data storage, document management and IoT. Some of the pioneering initiatives and companies exploring these applications are included.
Crucially the Map also provides a clear pictorial explanation and summary of the leading protocols at the heart of the ecosystem and concepts including coloured coins and smart contracts that supplement them to make a number of the proposed services possible.
A printable version of the map can be downloaded from www.firstpartner.net.
Hoy traemos a este espacio esta infografía de Capgemini Consulting , titulada Smart Contracts in Financial Services: Getting from Hype to Reality , y que nos presentan así:
The potential of smart contracts – programmable contracts that automatically execute when pre-defined conditions are met – is the subject of much debate and discussion in the financial services industry. Smart contracts, enabled by blockchain or distributed ledgers, have been held up as a cure for many of the problems associated with traditional fi nancial contracts, which are simply not geared up for the digital age. Reliance on physical documents leads to delays, inefficiencies and increases exposure to errors and fraud. Financial intermediaries, while providing interoperability for the finance system and reducing risk, create overhead costs for and increase compliance requirements.
Same Day ACH Allows Payments to Move FasterLexisNexis
For the millions of Americans who receive electronic payments directly into their bank accounts, a new system is about to go into place that will allow those payments to be made faster than ever. For banking executives and the legal counsel who advise them, the stakes are very high for successful compliance with this new system.
MTBiz is for you if you are looking for contemporary information on business, economy and especially on banking industry of Bangladesh. You would also find periodical information on Global Economy and Commodity Markets.
Smart Contracts in Financial Services: Getting from Hype to Reality. Reporteraser Juan José Calderón
Smart Contracts in Financial Services: Getting from Hype to Reality.
Executive Summary
The potential of smart contracts – programmable contracts that automatically execute when pre-defi ned conditions are met – is the subject of much debate and discussion in the fi nancial services industry.
Smart contracts, enabled by blockchain or distributed ledgers, have been held up as a cure for many of the problems associated with traditional fi nancial contracts, which are simply not geared up for the digital age. Reliance on physical documents leads to delays, ineffi ciencies and increases exposure to errors and fraud. Financial intermediaries, while providing interoperability for the fi nance system and reducing risk, create overhead costs for and increase compliance requirements.
In this report, we aim to cut through the speculation and hype around the potential of smart contracts. We have conducted detailed discussions with fi nancial services industry professionals, prominent smart contract startups, and academics (see Research Methodology at the end of this paper). Our study confi rms that smart contract adoption will lead to reduced risks, lower administration and service costs, and more effi cient business processes across all major segments of the fi nancial services industry. These benefi ts will accrue from technology, process redesign as well as from fundamental changes in operating models, as they require a group of fi rms to share a common view of the contract between trading parties. Consumers will benefi t from more competitive products, such as mortgage loans and insurance policies, along with simpler processes that are free of many of the hassles of today’s customer experience.
FirstPartner's 2016 Blockchain Ecosystem Market Map helps to decrypt the blockchain landscape with a visual overview of the emerging ecosystem, players, technologies and trends. It clearly summarises three main areas of focus emerging around the core blockchain or distributed ledger protocols:
1) Bitcoin and Cryptocurrencies: Providing an alternative to centrally managed "fiat" currencies, this sector includes Bitcoin exchanges, Bitcoin wallets, miners and cryptocurrency payment processors. The map illustrates how these companies interact and features some leading players including Coinbase, Circle, Kraken and 21 Inc.
2) The Financial Services Blockchain: This has been the main area of focus over the last 12 months as attention shifts from Bitcoin to Financial Services applications. An increasing number of players are focussing on commercialising blockchain technologies for banks, securities, derivatives and asset markets and institutional investors - and are attracting VC funding to do so. Ripple and Ethereum are leading candidate protocols for payment processing and smart contracts and players including Ripple, Chain and Digital Asset Holdings are gaining traction with Financial Institutions. The Map highlights leading technology companies and some of the banks, card schemes and processors who are investing in or evaluating distributed ledger technologies.
3) Other Use Cases: The distributed ledger concept and its ability to support transparent and tamper-proof asset registration, proof of ownership and asset transfer transactions makes it potentially applicable to multiple non financial use cases. The Map highlights a number of candidate use cases including publishing, legal, distributed data storage, document management and IoT. Some of the pioneering initiatives and companies exploring these applications are included.
Crucially the Map also provides a clear pictorial explanation and summary of the leading protocols at the heart of the ecosystem and concepts including coloured coins and smart contracts that supplement them to make a number of the proposed services possible.
A printable version of the map can be downloaded from www.firstpartner.net.
Hoy traemos a este espacio esta infografía de Capgemini Consulting , titulada Smart Contracts in Financial Services: Getting from Hype to Reality , y que nos presentan así:
The potential of smart contracts – programmable contracts that automatically execute when pre-defined conditions are met – is the subject of much debate and discussion in the financial services industry. Smart contracts, enabled by blockchain or distributed ledgers, have been held up as a cure for many of the problems associated with traditional fi nancial contracts, which are simply not geared up for the digital age. Reliance on physical documents leads to delays, inefficiencies and increases exposure to errors and fraud. Financial intermediaries, while providing interoperability for the finance system and reducing risk, create overhead costs for and increase compliance requirements.
Same Day ACH Allows Payments to Move FasterLexisNexis
For the millions of Americans who receive electronic payments directly into their bank accounts, a new system is about to go into place that will allow those payments to be made faster than ever. For banking executives and the legal counsel who advise them, the stakes are very high for successful compliance with this new system.
While innovative new technologies have been very efficient in combating traditional fraud, our research has found that digital technologies are also giving rise to new types of digital tax fraud: the increase in the number of e-filings of tax returns across geographies is driving new types of fraud using identity theft as the basis.
Another type of fraud taking shape is Zapping – using software programs to automatically skim cash from electronic cash registers (ECR) or point of sale systems.
Similarly, the growing usage of third-party payroll processors is opening up a whole new avenue of fraud where unscrupulous processors siphon off taxes due to the state.
Our analysis of these new digital tax frauds shows that inaction is not an option for tax authorities. We have modelled the evolution of tax fraud, taking into account new incidents of fraud enabled by digital technologies. Our findings are sobering for tax authorities. In a scenario where tax authorities continue to fight new tax fraud with conventional tools, we estimate digital tax fraud in the US will rise from $32 billion to $49 billion by 2020.
To combat this staggering scale of fraud, conventional methods are too slow for the digital age. Tax authorities must move away from an incremental, piecemeal approach to a much more comprehensive transformative line of attack with a long-term vision, roadmap and multifaceted solutions involving people, processes and technology.
What is the impact of inaction of tax authorities to rein in new types of digital tax fraud? How can analytics be used as an effective weapon to fight against digital tax fraud.
"FinTech and E-Payment" classes for Chulalongkorn University, Master of Law Program in Finance and Tax Laws and Master of Arts Program in Economic Law, (2018)
B11: Central IP & IT Court | FinTech: Legal and Regulatory Challenges (7 Aug ...Kullarat Phongsathaporn
"Special seminar on Memorial Day for Thailand's Father of Law" by Central IP & IT Court, Panelist for "FinTech: Legal and Regulatory Challenges" (7 Aug 2019)
B12: AMLO | FinTech Situation in Thailand and Offshore and Money Laundering R...Kullarat Phongsathaporn
"AMLO Seminar and Workshop regarding new types of financial transactions: FinTech and Financial Inclusion" by AMLO, Panelist for "FinTech Situation in Thailand and Offshore and Money Laundering Risks" (4 Jul 2019)
B17: U.S. Chamber of Commerce, the Thai Chamber of Commerce, and AmCham Thail...Kullarat Phongsathaporn
"The New Digital Economy: Creating Thailand-U.S. Commercial Opportunities Conference" by U.S. Chamber of Commerce, the Thai Chamber of Commerce, and AmCham Thailand, Panelist for "Blockchain - Implications for Thailand and Other Emerging Markets " (24 Sep 2018)
While innovative new technologies have been very efficient in combating traditional fraud, our research has found that digital technologies are also giving rise to new types of digital tax fraud: the increase in the number of e-filings of tax returns across geographies is driving new types of fraud using identity theft as the basis.
Another type of fraud taking shape is Zapping – using software programs to automatically skim cash from electronic cash registers (ECR) or point of sale systems.
Similarly, the growing usage of third-party payroll processors is opening up a whole new avenue of fraud where unscrupulous processors siphon off taxes due to the state.
Our analysis of these new digital tax frauds shows that inaction is not an option for tax authorities. We have modelled the evolution of tax fraud, taking into account new incidents of fraud enabled by digital technologies. Our findings are sobering for tax authorities. In a scenario where tax authorities continue to fight new tax fraud with conventional tools, we estimate digital tax fraud in the US will rise from $32 billion to $49 billion by 2020.
To combat this staggering scale of fraud, conventional methods are too slow for the digital age. Tax authorities must move away from an incremental, piecemeal approach to a much more comprehensive transformative line of attack with a long-term vision, roadmap and multifaceted solutions involving people, processes and technology.
What is the impact of inaction of tax authorities to rein in new types of digital tax fraud? How can analytics be used as an effective weapon to fight against digital tax fraud.
"FinTech and E-Payment" classes for Chulalongkorn University, Master of Law Program in Finance and Tax Laws and Master of Arts Program in Economic Law, (2018)
B11: Central IP & IT Court | FinTech: Legal and Regulatory Challenges (7 Aug ...Kullarat Phongsathaporn
"Special seminar on Memorial Day for Thailand's Father of Law" by Central IP & IT Court, Panelist for "FinTech: Legal and Regulatory Challenges" (7 Aug 2019)
B12: AMLO | FinTech Situation in Thailand and Offshore and Money Laundering R...Kullarat Phongsathaporn
"AMLO Seminar and Workshop regarding new types of financial transactions: FinTech and Financial Inclusion" by AMLO, Panelist for "FinTech Situation in Thailand and Offshore and Money Laundering Risks" (4 Jul 2019)
B17: U.S. Chamber of Commerce, the Thai Chamber of Commerce, and AmCham Thail...Kullarat Phongsathaporn
"The New Digital Economy: Creating Thailand-U.S. Commercial Opportunities Conference" by U.S. Chamber of Commerce, the Thai Chamber of Commerce, and AmCham Thailand, Panelist for "Blockchain - Implications for Thailand and Other Emerging Markets " (24 Sep 2018)
Blockchain would be the most likely and viable solution of Anti Money Laundering problems. Banking, financial as well as non financial industries along with regulators can benefit from this tecchnology
An insightful and information packed White Paper on Cloud Security. A must read for ALL C-level business leaders. Moving to the Cloud does not change the responsibility back to the business, but it does change your risk profile.
Next Wave of Fintech: Redefining Financial Services through TechnologyRobin Teigland
The Stockholm School of Economics and PA Consulting present The Next wave of Fintech, a sequel to the 2015 Stockholm Fintech Report, focusing on the new InsurTech and RegTech segments. The report, which describes and quantifies the Swedish market for these segments, contains valuable insights and recommendations for decision makers at banks, incubators, startup companies, public authorities and investors.
Distributed Ledgers: Possibilities and Challenges in Capital Markets Applicat...Cognizant
Distributed ledgers - blockchain technology - stands to make numerous financial services activities more secure, autonomous, and efficient. Here's a walk-through of a range of potential use cases: IPO issuance, trade agreements and settlements, confirmations, etc. and a strategy for transition.
Blockchain Technology in Banking Services - A ReviewGokul Alex
My session for IIM Bengaluru for the Executive Leaders of Public Sector Banks in India about the principles, paradigms, platforms, protocols and potentials of Blockchain Technology in 2020.
ASU Law Blockchain & Energy Policy Introduction & AZTC Fintech Policy 1/16/19Mark Goldstein
I introduced and moderated the ASU O’Connor College of Law’s Center for Law, Science and Innovation luncheon on January 16th, 2019 themed Blockchain and Energy Policy Forum in Downtown Phoenix with details at http://events.asucollegeoflaw.com/blockchain/energy-policy/.
Here’s my brief introductory presentation and the luncheon agenda along with the Arizona Tech Council’s State & Federal Fintech policy brief for 2019 FYI. You can access the complete Public Policy Guide at https://www.aztechcouncil.org/arizona-technology-council-public-policy-guide/.
The luncheon series will continue with programs on February 20th (Blockchain: Smart Contracts, Real Estate, and Supply Chain), March 20th (Blockchain and Healthcare) & April 17 (Blockchain: Privacy and Identity). Details at http://events.asucollegeoflaw.com/blockchain/.
Best Hadoop Institutes : kelly tecnologies is the best Hadoop training Institute in Bangalore.Providing hadoop courses by realtime faculty in Bangalore.
Blockchain Smart Contracts - getting from hype to reality Capgemini
The potential of smart contracts – programmable contracts that automatically execute when pre-defined conditions are met – is the subject of much debate and discussion in the financial services industry. Smart contracts, enabled by blockchain or distributed ledgers, have been held up as a cure for many of the problems associated with traditional financial contracts, which are simply not geared up for the digital age. Reliance on physical documents leads to delays, inefficiencies and increases exposure to errors and fraud. Financial intermediaries, while providing interoperability for the
finance system and reducing risk, create overhead costs for and increase compliance requirements.
In this report, we aim to cut through the speculation and hype around the potential of smart contracts. We have conducted detailed discussions with financial services industry professionals, prominent smart contract startups and academics (see Research Methodology at the end of this paper). Our study confirms that smart contract adoption will lead to reduced risks, lower administration and service costs, and more efficient business processes across all major segments of the financial services industry. These benefits will accrue from technology, process redesign as well as from fundamental changes in operating models, as they require a group of firms to share a common view of the contract between trading parties. Consumers will benefit from more competitive products, such as mortgage loans and insurance policies, along with simpler processes that are free of many of the hassles of today’s customer experience.
Distributed Ledger Technology as Financial Market InfrastructureTim Swanson
Keynote first presented at "The Future of Financial Payment Services Driven by Technology Innovation" on November 22, 2016 from Korea Finance Telecommunications & Clearings Institute (KFTC) 30th Anniversary Seminar in Seoul, South Korea.
The emergence of m commerce promises great benefits, but also poses significa...Keith Adams
Paper discussing the emergence of mobile commerce in the United States and comparing development in the US with more advanced adopters of the technology across the globe.
Similar to Digital Asset Transfer Authority Comments to Conference of State Bank Supervisors (20)
Latino Buying Power - May 2024 Presentation for Latino CaucusDanay Escanaverino
Unlock the potential of Latino Buying Power with this in-depth SlideShare presentation. Explore how the Latino consumer market is transforming the American economy, driven by their significant buying power, entrepreneurial contributions, and growing influence across various sectors.
**Key Sections Covered:**
1. **Economic Impact:** Understand the profound economic impact of Latino consumers on the U.S. economy. Discover how their increasing purchasing power is fueling growth in key industries and contributing to national economic prosperity.
2. **Buying Power:** Dive into detailed analyses of Latino buying power, including its growth trends, key drivers, and projections for the future. Learn how this influential group’s spending habits are shaping market dynamics and creating opportunities for businesses.
3. **Entrepreneurial Contributions:** Explore the entrepreneurial spirit within the Latino community. Examine how Latino-owned businesses are thriving and contributing to job creation, innovation, and economic diversification.
4. **Workforce Statistics:** Gain insights into the role of Latino workers in the American labor market. Review statistics on employment rates, occupational distribution, and the economic contributions of Latino professionals across various industries.
5. **Media Consumption:** Understand the media consumption habits of Latino audiences. Discover their preferences for digital platforms, television, radio, and social media. Learn how these consumption patterns are influencing advertising strategies and media content.
6. **Education:** Examine the educational achievements and challenges within the Latino community. Review statistics on enrollment, graduation rates, and fields of study. Understand the implications of education on economic mobility and workforce readiness.
7. **Home Ownership:** Explore trends in Latino home ownership. Understand the factors driving home buying decisions, the challenges faced by Latino homeowners, and the impact of home ownership on community stability and economic growth.
This SlideShare provides valuable insights for marketers, business owners, policymakers, and anyone interested in the economic influence of the Latino community. By understanding the various facets of Latino buying power, you can effectively engage with this dynamic and growing market segment.
Equip yourself with the knowledge to leverage Latino buying power, tap into their entrepreneurial spirit, and connect with their unique cultural and consumer preferences. Drive your business success by embracing the economic potential of Latino consumers.
**Keywords:** Latino buying power, economic impact, entrepreneurial contributions, workforce statistics, media consumption, education, home ownership, Latino market, Hispanic buying power, Latino purchasing power.
What price will pi network be listed on exchangesDOT TECH
The rate at which pi will be listed is practically unknown. But due to speculations surrounding it the predicted rate is tends to be from 30$ — 50$.
So if you are interested in selling your pi network coins at a high rate tho. Or you can't wait till the mainnet launch in 2026. You can easily trade your pi coins with a merchant.
A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the telegram contact of my personal pi vendor to trade with.
@Pi_vendor_247
Poonawalla Fincorp and IndusInd Bank Introduce New Co-Branded Credit Cardnickysharmasucks
The unveiling of the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card marks a notable milestone in the Indian financial landscape, showcasing a successful partnership between two leading institutions, Poonawalla Fincorp and IndusInd Bank. This co-branded credit card not only offers users a plethora of benefits but also reflects a commitment to innovation and adaptation. With a focus on providing value-driven and customer-centric solutions, this launch represents more than just a new product—it signifies a step towards redefining the banking experience for millions. Promising convenience, rewards, and a touch of luxury in everyday financial transactions, this collaboration aims to cater to the evolving needs of customers and set new standards in the industry.
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
Currently pi network is not tradable on binance or any other exchange because we are still in the enclosed mainnet.
Right now the only way to sell pi coins is by trading with a verified merchant.
What is a pi merchant?
A pi merchant is someone verified by pi network team and allowed to barter pi coins for goods and services.
Since pi network is not doing any pre-sale The only way exchanges like binance/huobi or crypto whales can get pi is by buying from miners. And a merchant stands in between the exchanges and the miners.
I will leave the telegram contact of my personal pi merchant. I and my friends has traded more than 6000pi coins successfully
Tele-gram
@Pi_vendor_247
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
what is the future of Pi Network currency.DOT TECH
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
If you are looking for a pi coin investor. Then look no further because I have the right one he is a pi vendor (he buy and resell to whales in China). I met him on a crypto conference and ever since I and my friends have sold more than 10k pi coins to him And he bought all and still want more. I will drop his telegram handle below just send him a message.
@Pi_vendor_247
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
The secret way to sell pi coins effortlessly.DOT TECH
Well as we all know pi isn't launched yet. But you can still sell your pi coins effortlessly because some whales in China are interested in holding massive pi coins. And they are willing to pay good money for it. If you are interested in selling I will leave a contact for you. Just telegram this number below. I sold about 3000 pi coins to him and he paid me immediately.
Telegram: @Pi_vendor_247
Digital Asset Transfer Authority Comments to Conference of State Bank Supervisors
1.
DATA CSBS COMMENTS 1
February 20, 2015
Attn: Emerging Payments Task Force
Conference of State Bank Supervisors
1129 20th Street NW, 9th Floor
Washington, D.C. 20036
Re: Proposed Regulatory Framework: Virtual Currency
Dear Members of the Task Force:
This letter is submitted on behalf of the Digital Asset Transfer Authority (“DATA”)
in response to the proposed Draft Model Regulatory Framework and Policy
Statement on Virtual Currency Regulation issued by the Conference of State
Bank Supervisors (“CSBS”) on December 16, 2014 (collectively, the “Proposed
Model Framework”).
Background
DATA is a global non-profit trade association established in July 2013 focused
on digital assets, including distributed ledger technologies such as Bitcoin.1
DATA was founded to (1) act as a conduit and feedback mechanism between
the digital asset business community and policymakers and subject matter
experts; (2) to inspire confidence in such products by spearheading the
development of best practices across AML, data security, consumer protection
and privacy; and (3) to evolve in compliance with applicable laws and regulation
governing digital currencies including decentralized ledger technologies such as
the Bitcoin protocol (referred to collectively herein as “digital assets”). Our
members represent a broad range of digital asset businesses including
currencies, exchanges, administrators, and payment platforms, as well as
service providers such as established law firms that are actively engaged in the
digital asset space.
General Comments
We appreciate the opportunity to provide comments to the Proposed Model
Framework. We are encouraged by the efforts of the CSBS and its Emerging
Payments Task Force to establish a model regulatory regime for digital
1
More information available at www.datauthority.org.
2.
DATA CSBS COMMENTS 2
currency2
firms. We applaud the collaborative approach taken by the CSBS and
hope to continue to have the ability to offer industry input into the process. We
believe that the proposal offers a positive starting point in developing a
regulatory framework that can protect consumers while also allowing this
important technology to evolve and thrive.
Several DATA member companies are registered as a money service business
at the federal level and are seeking state licenses. These companies face
uncertainty as the current regulatory framework for digital currency firms has not
been established. Several states have attempted to place digital currency firms
under existing money transmitter laws while the New York Department of
Financial Services (“NYDFS”) has proposed a separate regulatory regime for
digital currency firms. A few states like Texas and Kansas have issued guidance
on how digital currency applies to current laws. More guidance and uniformity
in a state regulatory framework is needed to allow these companies to operate
efficiently across state lines.
Listed below are some general comments on the Proposed Model Framework
followed by responses to the specific questions posed by the CSBS.
1. The definition of virtual currency is too broad
The Proposed Model Framework appropriately focuses on activities based
regulations. The framework, however, should offer a narrower interpretation of
regulated activities. Digital currency firms have diverse business models,
including exchanges, wallets services, ATMs, security services, software
services, and payment processors. It is appropriate to regulate those firms that
exchange digital currency or hold the currency as a custodian due to the
heightened risks to consumers of those activities. However, we believe that
payment processors or “facilitators” of digital currency transactions should be
exempt from the rules.
2. Smaller firms should be treated differently under the framework
The Proposed Model Framework should exempt (or limit oversight over) smaller
start-ups to allow them the ability to enter the market without the licensing costs
and compliance burdens. These smaller firms pose less risk and should be
allowed to operate without the liabilities and costs associated with full licensure.
DATA believes there is a need to create a tiered, risk-based onramp to an
2
For purposes of this letter, we use “digital currency” and “virtual currency” as interchangeable
terms.
3.
DATA CSBS COMMENTS 3
otherwise high barrier licensing regime, including a safe harbor provision that: (1)
takes into account the rapidly evolving technologies and business models; and
(2) ensures that regulatory requirements correspond to actual risk to the
consumer and are balanced against the net public benefit of the technology. At
a minimum, this safe harbor should allow small startups to operate with
minimum thresholds and clear guidance on correspondingly low safety and
soundness requirements, with at least six months to apply for a license once
thresholds are crossed.
3. Regulations should be principles-based
Regulation of digital currency firms should focus on high-risk areas and should
not establish rules that are overly burdensome. In striking the correct balance,
regulators should consider principles-based guidelines rather than detailed
prescriptive rules. Prescriptive rules and a check the box approach may be
ineffective, especially in a fast moving industry like digital currency. Prescriptive
rules could have a chilling effect on technological innovation and the ability of
consumers to realize the benefits of digital currency. Regulators can achieve
the same objectives by offering principles that need to be addressed and
allowing industry to create programs to comply with these risk areas. Groups
like DATA, and other industry representatives, have been taking a proactive
approach toward establishing best practices to satisfy these types of criteria. In
a principles-based regime, state supervisors still maintain examination authority
to hold firms accountable and determine whether further prescriptive rules are
needed.
4. The Proposed Model Framework needs to be adopted across all states
in a consistent manner
DATA requests that the CSBS create a framework that will be adopted by all
states and eliminates the current uncertainty in the marketplace. We request
that any model rule eliminate the need for multiple licenses for digital currency
firms that may also be conducting more traditional money transfer services.
While we encourage the CSBS to make the rules flexible, we also caution that
providing state supervisors excessive discretion, it could lead to disparities on
the application of the rules. Also, we encourage the CSBS to ensure a level
playing field by establishing similar guidelines for both digital currency firms and
other money transmitters. DATA members would also like to see a more
streamlined process in terms of applications and ongoing oversight. All states
4.
DATA CSBS COMMENTS 4
should be mandated to utilize NMLS and certain forms and procedures should
be standardized to the extent possible.
5. The recordkeeping rules are unnecessary
We believe the AML rules set by FinCEN in the March 2013 guidance is an
appropriate level of regulation for digital currency firms. The AML requirements
in the Proposed Model Framework propose recordkeeping rules that require
gathering personal information for all parties related to digital currency
transactions. This requirement is not aligned with federal rules making it
impractical when it comes to collecting counterparty information. We cannot
identify a public policy aim that justifies the collection of PII for every de minimus
transaction for it presents little net gain to reducing AML risks, additional burden
to the licensee, and increased privacy risk to the consumer. At a minimum,
CSBS should eliminate the requirement for PII collection of non-customer of the
licensee and indicate a minimum transaction threshold for identity verification
(e.g., conduct proper risk/benefit calculation). As the recent massive data
breaches at Target, Home Depot, Kmart and JP Morgan show,3
the continued
practice of unsecured personal data collection to process transactions—a
practice that originated in a brick-and-mortar world—presents serious dangers
to consumer privacy and control of personal identities even for large, global
companies. These dangers will be exacerbated where proposed rules seek to
require smaller, less sophisticated businesses that accept digital assets as
payment to safeguard personal data in their corporate records. We further
request that the CSBS clarify that any records for counterparties be kept to the
extent practical.
Responses to Questions for Public Comment
1. Policy Implementation – Entities engaged in virtual currency activities
might not be engaged in traditional money transmitter activities involving
only fiat, government-backed currencies. Similarly, traditional money
transmitters might not be engaged in virtual currency activities.
a. Within the umbrella of state money transmitter regimes, how can state
regulators appropriately tailor licensing and supervision to each set of
licensees?
3
Jake Swearingen, “Why the JP Morgan Data Breach Is Like No Other”, The Atlantic, October 3,
2014, available at http://www.theatlantic.com/business/archive/2014/10/why-the-jp-morgan-data-
breach-is-like- no-other/381098/.
5.
DATA CSBS COMMENTS 5
DATA believes that any framework should avoid creating a disparity among
digital currency firms and traditional money transmitters. We believe that
licensing, examination and oversight questions/requirements should be
expanded to capture all types of activities for money transmitters and/or digital
currency businesses. Depending on the business model, some of these
requirements may or may not be applicable to digital currency institutions.
Examiners should be trained on specific risk areas and examination manuals
can be expanded to request the required information to assess risks.
b. In order to properly tailor licensing and regulatory regimes to virtual
currency activities, should states consider a virtual currency-specific
“amendment” or “endorsement” to a traditional money transmitter
license?
DATA believe that states should attempt to govern digital currency firms through
current money transmitter laws and treat these entities as money transmitters
offering a specific type of service. This approach may be challenging due to the
language in current statutes and therefore could require legislative changes. If
CSBS chooses to create an entirely separate framework for digital currency
firms, regulators should avoid requiring multiple licenses for digital currency
businesses.
2. Licensing Process
a. Though states largely have the same licensing requirements, there is not
a common implementation process. Please comment on the functionality
of the NMLS or other licensing systems.
NMLS has streamlined the application process, but there are several efficiencies
and enhancements that can be made to this process. Uniformity in applications
would improve the process and reduce costs.
b. Would a common application and guide to licensure enhance the
efficiency of the licensing system?
A common application seems appropriate as most states have similar
requirements. This application should be comprehensive enough to capture any
state specific requirements. One other issue is that nearly all states that accept
money transmitter license applications through NMLS require additional
6.
DATA CSBS COMMENTS 6
materials to be submitted in hard copy which negates the benefits of a
streamlined online process.
c. Obtaining required criminal background checks has been flagged as an
administrative challenge in the licensing process. What procedures can
states uniformly adopt to facilitate obtaining criminal background checks
as part of the licensing process?
The differences in the fingerprinting procedures for various states increases
costs and places burdens on firms. If all states were to accept FBI standard
fingerprint cards completed by a police department or an approved third party
vendor, individuals could complete all necessary fingerprinting at once.
d. Credentialing business entity key personnel can be a hands-on process,
but has proved indispensable for financial services licensing. Are there
alternative means of credentialing that may facilitate the process?
In addition to the fingerprinting process and the credit checks run through
NMLS, many states require officers and directors of applicants to complete
extensive forms covering information such as employment and residential
history even though such information is provided through the NMLS MU2 filings.
The need for these forms could be eliminated by simply expanding the scope of
the MU2 filing on NMLS to cover all relevant information.
3. Training and Education – Educating regulators about virtual currency
business activities and business models is an important part of building a
responsive and robust regulatory structure.
a. What education may be necessary for state regulators to aid in the
licensing
process?
Due to the complexity of digital currency, regulators should ensure that training
takes place to understand the technology and regulators have staff and
resources to properly oversee digital currency firms. Training should be
provided on blockchain technology and digital currency transactions.
b. What resources are available to explain technology and business models
across the virtual currency industry?
7.
DATA CSBS COMMENTS 7
The CSBS and state regulators can utilize groups like DATA and industry trade
associations to get a broad perspective on the technology and related business
models. Also, groups like the Bitcoin Foundation would helpful based on their
mission to oversee the core development of Bitcoin.
4. Technological Innovations – What changes and innovations have been
seen and/or can be anticipated in the technological aspects of virtual
currencies and the resulting marketplace?
New products and services are emerging in an attempt to disrupt current
payment systems. Many companies are trying to make digital currency easier to
use by consumers and merchants and to create products to directly address the
risks associated with digital currency. Blockchain technologies may shift the
policy goalposts and traditional mechanisms that, when applied to these
technologies, may produce unintended negative consequences.
Blockchain technologies enable companies, regulators and auditors to conduct
real-time risk analysis of transactions with immutable data collection and
auditability, which was previously technologically impossible. Furthermore,
emerging innovations and practices in the ecosystem such as multisignature
(segregation in controls, granularity in corporate and treasury duties,
impossibility of internal fraud, real-time transparency and auditability), the
advent of proof-of-reserves methods (users can verify their balances online at
platforms in real-time), and “continuous real-time accounting” may aid CSBS in
their policy goals. Innovations in areas such as Big Data and the Internet of
Things are facilitated by blockchain technologies, which utilize smart contracts
enabling automated interactions without human intervention, reducing
transaction costs, and offer secure, efficient communication and payment
networks.4
These emerging innovations also directly bear on CSBS policy goals and CSBS
should work with organizations like DATA to better understand the capabilities
of these technologies. Working with the industry to understand these
technologies may change CSBS evaluation of the policy tradeoffs and the
mechanisms used to achieve CSBS policy goals, including facilitating safety and
soundness of licensees, and enabling more consumer choice and control. It is
essential that policymakers understand that Internet and p2p technologies
4
See IBM ADEPT White Paper using blockchain to show proof-of-concept for machine-to-
machine interaction in the Internet of Things, available at
http://www.computerweekly.com/news/2240238627/IBM-uses-Bitcoin-technology-to-build-
internet-of-things-platform.
8.
DATA CSBS COMMENTS 8
present unique challenges to oversight regimes historically based on centralized
systems and gatekeepers, and that emerging technologies exacerbate the
governance gap. Therefore, multi-stakeholder collaboration is necessary in
building the correct frameworks, and there are many organizations and
individuals who are willing to assist CSBS in understanding the risks and
benefits of these emerging innovations. Regulations should be flexible enough
to deal with these changes and also evolve to address emerging risks.
5. Denomination of Capital, Permissible Investments, and Bond Coverage –
Capital, permissible investments, and surety bond requirements exist to
create financial security in the event of failed transactions or a failed
business. For financial services companies dealing in virtual currencies,
should these safety funds be denominated in the applicable virtual
currency or in dollars?
In addition to holding reserves, digital currency firms maintain minimum capital,
surety bonds, and in some cases private insurance against theft of assets, to
further protect customer funds. Like any other money transmitter, state
supervisors have the authority to require firms maintain additional levels of
protection. In this context, DATA believes it is appropriate for digital currency to
be held as permissible investment.
6. Distressed or Failed Companies – Certain requirements in the Draft
Framework are designed to provide regulators with tools for dealing with
distressed or failed companies. Please comment on the practical issues
and challenges facing regulators in the case of a distressed or failed
company. What other tools should regulators have for resolving a failed
virtual currency company, minimizing consumer harm and market impact?
Digital currency firms have a duty to protect client funds. As a result, firms have
full reserves for these assets and are subject to capital requirements and other
rules around risk controls. State regulators can protect against failures by
ensuring that digital currency companies operate in a safe and sound manner
and have adequate safeguards over client funds. Regulators can guarantee
safeguards are in place through licensing, reporting and examinations. State
regulators should also consider resolution procedures that ensure customer
funds receive priority in the event a failure.
7. Consumer Protections – What consumer remedies should policy makers
consider for virtual currency financial activities and transactions?
9.
DATA CSBS COMMENTS 9
Digital currency firms have a fiduciary duty to protect client funds. Regulators
must therefore ensure these funds are protected at the front end and remedies
are established in the event of a loss. In terms of controls, consumers must be
given adequate disclosures to understand transactions, including the risks and
liability. Digital currency firms should have security protocols in place to ensure
funds are not lost. If there is a loss, funds should be protected or reserved for in
a manner in which the customer can recoup funds with minimal exposure. There
should be resolution procedures for digital currency companies to be able to
handle customer complaints.
8. State Insurance or Trust Funds – Some states have laws that create a
trust or insurance fund for the benefit of instrument holders (i.e., holders of
checks, money orders, drafts, etc.) in the event that a licensed money
transmitter defaults on its obligation or is otherwise unable to make
payment on the instrument. Is it appropriate to allow holders of
instruments denominated in virtual currency access to such insurance or
trust funds?
Yes. We believe that the holders of digital currency assets are holding value
similar to holders of other negotiable instruments and therefore should be
provided these additional protections.
9. BSA/AML – Fraud and illicit activities monitoring are increasingly
technology based and proprietary, especially for virtually currency
companies. Are state and federal exam procedures current with regards to
new methods of detecting BSA/AML activity?
We believe that current state and federal exam procedures provide a starting
point for a general framework to oversee digital currency firms. Existing
guidelines for money transmitters, along with the March 2013 FinCEN guidance,
provide details on who should be regulated and how. As the industry develops,
exam procedures need to be updated to reflect specific risks and controls being
used by digital currency businesses. Companies in this area have developed
new ways to detect fraud and illicit activity. Regulators need to have the
expertise and be made aware of these methods.
10. Customer Identification – The Draft Framework includes maintaining
records on the identification of virtual currency owners. Credentialing
consumers for identification purposes can be accomplished to varying
degrees, from basic account information to verified personal identification.
What is the appropriate level of identification?
10.
DATA CSBS COMMENTS 10
DATA believe that the determining the appropriate level customer identification
information required should be based on risks presented. At a minimum, digital
currency firms should have KYC procedures for non-de minimus transactions to
ensure that they understand the identity and risks for each customer. CSBS
should consider a de minimus threshold that exempts certain de minimus
transactions from data collection (which presents clear privacy risks) but would
require more rigorous KYC procedures as the risk increases with transaction
amount and volume. Firms should screen customers against sanction party lists
and should conduct enhanced due diligence in scenarios where higher risks are
presented. Ultimately, firms need to gather enough data to demonstrate they
understand the risks presented.
11. Regulatory Flexibility – The Draft Framework stresses regulatory
flexibility to accommodate different activity levels and business models
and to avoid inhibiting innovation.
a. Given the rapidly evolving nature of virtual currencies, what should be
the nature of any necessary flexibility?
Regulators should consider a principles-based approach instead of prescriptive
rules, which may quickly become outdated given the fast-changing
technology. There should be flexibility within the regulations for digital currency
firms to be able to comply with the spirit, as well as the letter, of the law.
Regulators should grant a level of flexibility to supervisors, but too much
discretion could lead to excessive differences between state regulators. CSBS
should implement a transparent appeals process to ensure that discretion is not
improperly exercised because of an individual regulator’s lack of education
about the business model or technology.
b. How can laws and regulations be written to strike a balance between
setting clear rules of the road and providing regulatory flexibility?
Regulators can achieve their objectives through establishing clear principles that
establish areas of risk that need to be addressed. Implementing safe harbor
provisions will also provide regulatory certainty and flexibility for these nascent
technologies. As mentioned, regulators can hold firms accountable and adjust
criteria based on ongoing examinations and reviews.
12. Reporting Requirements – Most states require money transmitter
licensees to submit periodic reports of business activities.
11.
DATA CSBS COMMENTS 11
a. For licensed virtual currency companies, what types of information and
data should be included in periodic reports?
Periodic reporting for digital currency companies should mirror reporting by
other money transmitters. This information may include financial data, risk
profile metrics and other major business changes.
b. What technology solutions exist to mitigate regulatory reporting
requirements?
Regulators can leverage the blockchain to audit and review digital currency
firms and related transactions. In addition, regulators can place some level of
reliance on independent third party assessments. The industry is working on
ways to further leverage the blockchain and the core technology associated with
Bitcoin and other cyptocurrency to provide further transparency.
13. Technological Solutions to Improve Supervision – State exams and
reporting requirements reflect an institution at a point in time. Conversely,
operational standards and internal compliance audits increasingly offer the
opportunity for real time data collection, interacting with transmission data
to ensure adequate funding, anti-money laundering compliance, fraud
protection, and consumer protection. What technology solutions can
regulators and licensees deploy to close information gaps in a manner that
makes the supervisory process more efficient and “real time?”
Blockchain technologies enable companies, regulators and auditors to conduct
real-time risk analysis of transactions with immutable data collection and
auditability, which was previously technologically impossible. Furthermore,
emerging innovations and practices in the ecosystem such as multisignature
(segregation in controls, granularity in corporate and treasury duties,
impossibility of internal fraud, real-time transparency and auditability), the
advent of proof-of-reserves methods (users can verify their balances online at
platforms in real-time), and “continuous real-time accounting” may aid CSBS in
their policy goals. CSBS should work with organizations like DATA to better
understand the capabilities of these technologies which may change the
mechanisms used to achieve policy goals, and facilitate safety and soundness
of licensees, and enable more consumer choice and control.
While state examinations are point in time, state supervisors may rely on audits
and internal compliance reviews to get some insight into the ongoing operations
12.
DATA CSBS COMMENTS 12
of digital currency firms. Supervisors can also use internal and external data
points to have continued insight into firms, including periodic reporting and
reviews of customer complaints with the federal and state regulators.
14. Cyber Risk Insurance. Companies have begun looking to insurance to
help manage cyber risks, and there are a growing number of companies
offering cyber liability insurance. What role should cyber risk insurance
have in a licensed virtual currency entity's approach to managing cyber
risks? Please discuss the potential costs and benefits for virtual currency
companies securing cyber risk insurance.
With the fall of Mt. Gox and issues at other digital currency exchanges,
regulators and consumers have expressed concern over the safety of digital
assets held by firms. Cyber Risk Insurance is another level of protection for
customer funds beyond what is in place involving security controls, surety
bonds, capital requirements, etc. On one hand, it is encouraging that the
industry has been able to create this market opportunity and provide more
protection for the consumer. However, on the other, at this early stage, the
costs are high for this type of coverage and the carriers are selective on who
they will insure, but there are a lot of benefits. Therefore the requirement of
cyber risk insurance at present would present a barrier to entry for
entrepreneurs and smaller firms. We would expect these coverages to evolve
and expand over time. The current coverage protects against the theft of digital
assets.
15. Commercial Fund Transfer Liability – Article 4A of the Uniform
Commercial Code establishes liability for wire transfers, relying on
definitions strictly applicable to banks. Are provisions like those in Article
4A necessary for commercial transfers denominated in virtual currencies?
If so, is the Article 4A construct an appropriate model to be adapted in a
manner that is not bank-centric?
Digital currency has some unique characteristics that should be contemplated in
determining some type of Article 4A liability. These transactions are anonymous
and are not subject to chargeback. Some elements of Article 4A may be used
as a guideline for creating a regime to address these issues, but more analysis is
needed to determine what is appropriate for these types of transactions and
what type of rules could provide protections without significantly interfering with
the beneficial nature of the transactions.
13.
DATA CSBS COMMENTS 13
16. Banking Services for Virtual Currency Companies – Banking
arrangement information is necessary for evaluating the safety and
soundness of a licensee. However, virtual currency businesses are not
immediately understood by most banks that provide traditional money
services accounts. What are the risks facing banks that consider banking
virtual currency companies, and how can those risks be mitigated?
DATA members continue to have issues finding banking partners willing to
assume the risk of working with a digital currency business. Most banks
continue to de-risk entire legitimate business models (e.g., money services
businesses) due to regulatory and business pressures.
In considering whether to offer banking services to a digital currency firm, banks
should take a risk-based approach and treat these firms similar to any other
MSB. Providing regulatory certainty as to relevant risk metrics and exempt
business models would better enable banks to make reliable business decisions
for accounts. Banks should evaluate the risk management program as a whole,
including staff, policies, procedures and controls. Banks should perform due
diligence and look at the highest risk areas, such as financial crimes and
security and determine whether controls are adequate in these areas. Banks
that do business with digital currency firms should monitor activity on an
ongoing basis and seek to get reports from digital currency firms. For their part,
digital currency firms seeking banking partners should conduct a
comprehensive risk assessment to outline and rank risks and then create
appropriate controls.
17. Merchant-Acquirer Activities – Companies processing credit card
payments between a buyer’s bank and a seller’s bank (Merchant-
Acquirers) have historically been presumably exempt from money services
businesses statutes because of their nexus to the highly regulated banking
system. A company processing virtual currency payments for merchants
who accept virtual currency as payment for goods and/or services may
exchange virtual currency to dollars, which can then be transferred to the
merchant’s bank account. Is this activity akin to the activities of traditional
Merchant-Acquirers, or is it the exchange and subsequent transmission of
value that is typically regulated by the states?
Most payment processor activity is similar to the activities of traditional
Merchant-Acquirers and therefore should be treated separately for regulatory
purposes. Furthermore, blockchain technologies reduce former risks and
increases transparency associated with similar service providers. As previously
14.
DATA CSBS COMMENTS 14
discussed, DATA believes that facilitators should be exempt from the Proposed
Model Framework.
18. Cost – State regulators are cognizant of the costs associated with
licensure and ongoing compliance. What processes can be implemented to
reduce these costs, including any shared services or technology-based
reporting?
DATA members are varied in terms of costs associated with licensure and
compliance. We believe that the regulatory framework needs to strike the right
balance and weigh benefits against costs and burdens. Digital asset firms are
leveraging technology and third party resources to comply with laws. We believe
this is appropriate as long as proper diligence is performed and the licensed
entity maintains control and responsibility over systems.
19. Escheatment – How should virtual currency be treated under state
escheatment laws?
Virtual currency should be treated as any other asset under state escheatment
laws and abandoned funds should be treated accordingly.
Conclusion
DATA is encouraged by the Proposed Model Framework and look forward to
working with the CSBS in finalizing this proposal. Regulatory clarity is needed
for businesses to deliver this important technology to mainstream consumers.
If you have any questions, please feel free to contact me at 202-530-4821 or
chris.mitchell@datauthority.org.
Sincerely,
Christopher Mitchell
Executive Director