Last Friday afternoon the Financial Crimes Enforcement Network released a 72-page notice of proposed rulemaking. Coinbase felt compelled to respond immediately. https://blog.coinbase.com/coinbases-response-to-recent-proposed-rulemaking-from-the-u-s-treasury-and-fincen-109dd7477d31
FinCEN asked for comments in just 15 days, spanning Christmas Eve and New Year’s Day, in the middle of a pandemic — leaving few actual working days for comments.
FinCEN also asked for comments on no less than 24 separate questions. Based on our initial review, responding will require Coinbase and many other companies to undertake detailed technical analyses, extensive costs assessments, and complex balancing of privacy interests.
This is not how effective regulation is made.We ask that FinCEN reconsider its haste and provide the typical 60-day period for such significant proposed rulemaking--nothing more, but nothing less.