1/ There’s a reason the regulatory rulemaking process provides 30-60 days for notice & comment. So that those outside govt - consumers, industry, public interest orgs, academics, etc - have a meaningful opportunity to weigh in & provide viewpoints govt may not have considered

2/ In fact, agencies are encouraged to consider a longer comment period for complex areas. The global and distributed nature of crypto is nothing if not complex. The reason for this amount of time is simple: it’s about due process. The opportunity to be meaningfully heard.

3/ Late yesterday, instead of following that process, @stevenmnuchin1 slashed the ordinary comment period to just 15 days, on a Friday before the holidays no less, for crypto regulations that to us @a16z and others in the crypto space don’t make much sense

4/ Not only those in the crypto industry think this. Many with decades of law enforcement & natl security experience have shared that the proposed rules won't really help their mission of stopping illicit finance, and worse, only threaten to put the US behind in crypto innovation

5/ In fact, the current legacy financial system fails to prevent illicit finance & money laundering 99.9% of the time https://www.judiciary.senate.gov/imo/media/doc/Cassara%20Testimony.pdf. https://www.wsj.com/articles/is-anti-money-laundering-working-no-its-failing-1511262616. As @ChuckGrassley put it, the system is just one decimal point away from total failure

6/ And even where the legacy system “works” and financial institutions flag suspected illicit conduct, the govt is often still not particularly effective at stopping it (as the recent FinCEN files fiasco demonstrates) https://www.buzzfeednews.com/fincen-files 

7/ For these reasons & others we’ll detail publicly before the comment period closes Jan 4, we @a16z oppose the proposed regs & urge against their adoption (needless to say we also take issue w/the process for this midnight rulemaking, though makes it more amenable to challenge)