Today, BitPay submitted our response to the New York Department of Financial Services' (NYDFS) proposed regulations for virtual currency business activities, and we would like to share our themes and full response.

Our first theme suggests that the NYDFS be innovative, whether being open to new ideas similar to the Consumer Financial Protection Bureau's plan to consider No-Action Letters or new supervisory methods such as blockchain-based proof-of-solvency. We also want to ensure that the proposed rules do not create an unlevel playing field with other payment systems or disregard existing local, national, and international anti-money laundering frameworks that could be utilized rather than replaced by bitcoin-technology specific rules. Lastly, there are many non-money transmission or exchange services that are being built on the bitcoin protocol that should not be covered by regulations, and therefore, the industry needs clarity to ensure further innovation is possible.

BitPay has been, and continues to be, a strong advocate for the Bitcoin ecosystem. We are living in the initial years of Bitcoin ecosystem growth, and – like the growth of the internet in the early 1990's – we expect far more innovation in the coming years. We remain excited about the future, for us and for the ecosystem at large.

For further discussion, please see BitPay's full response to the BitLicense proposal.

If you have not submitted your comments to the NYDFS during this comment-period, we strongly suggest you do so during the next comment-period, as every voice represents a bitcoin-related entrepreneur, industry, or innovation.

Tim Byun
Chief Compliance Officer