No doubt, there’s been a ton of chatter lately regarding the recently-released BitLicense and Bitcoin regulation proposals from the New York State Department of Financial Services (NYDFS).
Many have seen promise, and others have nothing but questions.
One such entity in the Bitcoin Foundation.
Using New York law that would require a statement of “needs and benefits” for proposed regulation, the Bitcoin Foundation wrote a letter to the NYDFS which includes a request under the New York Freedom of Information Law (FOIL) for “any risk management and cost-benefit analysis (or any other systematic assessment) that is a part of the ‘extensive research and analysis'” the NYDFS alluded to in its proposal (which you can read by clicking here).
In the letter to NYDFS Superintendent Benjamin Lawsky, Bitcoin Foundation Global Policy Counsel Jim Harper wrote:
[blockquote style=”2″]Below we suggest not only that you extend the comment period by more than a nominal period, but also consider conducting hearings on the proposal and adopting an iterative process, in which you issue drafts, take comment, and re-issue drafts until all issues are fully vetted. The Bitcoin community will be able to comment more cogently if you share the research and analysis that underlies the proposal. The community can help you fit regulatory means to public interest ends if they have access to the risks your study of digital currencies identified. The department should use modern tools to conduct a rule-making that benefits the coming era, the Bitcoin era.[/blockquote]
Just hours later, the NYDFS promised to deliver additional information to the Bitcoin Foundation within a twenty-day period.
Bitcoin Foundation Letter to NYDFS
The Bitcoin Foundation, in effort to remain transparent, says they will be publishing all information it receives from the NYDFS for the review of the bitcoin community.
More information on this front as it becomes available.
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bouf 
Zeke Bush 
Sign the BitLicense Petition…
BitLicensePetition.org
I’ve been curious what took a year to draft the proposed rules when the only thing they seemed to do is copy and paste every regulation they could find into a new file called “BTC_Regs.doc”. The NY proposal looks like every rule in the book thrown up on a wall of glue. Not much will fall off the wall. I am not hopeful for an iterative process, but good-lookin-out Foundation with asking for the “research” “methodologies”. Very likely someone in Lawsky’s office is coming up with one right now!
Awsome artical Jonathan, good read! Let me point out the pink elephant in the room here! How can you regulate something thats designed to be de-regulated? The major argument becomes we need to regulate to protect our citizens . However, the bitcoin decentralized technology will protect the citizens better than the NYDFS’s laws, buearacy, redtape, bronze tax… Ijs NYDFS the typical bitcoin end-user is well informed and understand the pros/cons of the technology.