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1/ FinCEN is now accepting public comments on its proposal to extend AML regulation to non-custodial wallets.
The deadline is January 4. We have an unfairly (maybe illegally) short time for this, so we have to use it wisely.
Here's your ultimate guide on submitting a comment
The deadline is January 4. We have an unfairly (maybe illegally) short time for this, so we have to use it wisely.
Here's your ultimate guide on submitting a comment
2/ I'll link to the comment form at the end of the thread, but I really want you to read through this first.
Writing a bad comment is worse than none at all. If you don't have time to take this seriously, use a pre-filled form instead (also linked below). https://twitter.com/NeerajKA/status/1341806323931951105?s=20
Writing a bad comment is worse than none at all. If you don't have time to take this seriously, use a pre-filled form instead (also linked below). https://twitter.com/NeerajKA/status/1341806323931951105?s=20
3/ First, let me assure you that public comments do matter.
A LOT.
Agencies have to read & respond to the substance of every single one. Your voice will be heard. It might change minds on the other side. Even if not, it still might slow them down.
This is worth your time.
A LOT.
Agencies have to read & respond to the substance of every single one. Your voice will be heard. It might change minds on the other side. Even if not, it still might slow them down.
This is worth your time.
4/ Here are five tips for writing a clear & effective comment.
TIP 1: BE RESPECTFUL.
This is really a requirement, not a tip. Be firm, but polite. Don't write anything you wouldn't say to your mother. Don't use insults or profanity. Focus on the rule, not the people behind it.
TIP 1: BE RESPECTFUL.
This is really a requirement, not a tip. Be firm, but polite. Don't write anything you wouldn't say to your mother. Don't use insults or profanity. Focus on the rule, not the people behind it.
5/ TIP 2: DO YOUR RESEARCH.
Make sure you fully understand the rule & its impact. Your comment will be easy to disregard if you get the facts wrong. I'll link more resources below to help with this, but you can start with my last thread & the rule itself: https://twitter.com/jchervinsky/status/1340135041746300932?s=20
Make sure you fully understand the rule & its impact. Your comment will be easy to disregard if you get the facts wrong. I'll link more resources below to help with this, but you can start with my last thread & the rule itself: https://twitter.com/jchervinsky/status/1340135041746300932?s=20
6/ TIP 3: MAKE IT PERSONAL.
Start by saying who you are & how you know what you're talking about. Then focus on how the rule would affect you personally, or how it would affect your company or business. Stick to what you know. Leave the complex legal arguments to the lawyers.
Start by saying who you are & how you know what you're talking about. Then focus on how the rule would affect you personally, or how it would affect your company or business. Stick to what you know. Leave the complex legal arguments to the lawyers.
7/ TIP 4: BE SPECIFIC.
Give concrete, detailed examples of how the rule would affect you. Don't just complain generally about how you don't like it. You can also share your thoughts on the process surrounding the rule, such as if you'd like more than 15 days to write a comment.
Give concrete, detailed examples of how the rule would affect you. Don't just complain generally about how you don't like it. You can also share your thoughts on the process surrounding the rule, such as if you'd like more than 15 days to write a comment.
8/ TIP 5: KEEP IT SIMPLE.
A few clear & sharp paragraphs is plenty. Use plain & straightforward language. You don't have to write a whole book or a fancy poem. Don't bother with logic puzzles, rhetorical questions, or hypotheticals.
Finally, don't forget Tip 1: be respectful!
A few clear & sharp paragraphs is plenty. Use plain & straightforward language. You don't have to write a whole book or a fancy poem. Don't bother with logic puzzles, rhetorical questions, or hypotheticals.
Finally, don't forget Tip 1: be respectful!
9/ I also want to share some resources to help you learn about the rule & the arguments that others have made about it.
To start, the @coincenter team is all over this, as always. Check out their great blog post & detailed comment letter in this thread: https://twitter.com/jerrybrito/status/1341427003615031298?s=20
To start, the @coincenter team is all over this, as always. Check out their great blog post & detailed comment letter in this thread: https://twitter.com/jerrybrito/status/1341427003615031298?s=20
10/ Many other industry groups & leaders have also shared their views. Here's a non-exhaustive list for inspiration:
@blockchainassn here: https://theblockchainassociation.org/wp-content/uploads/2020/12/Blockchain-Association-Letter-to-the-Treasury-December-2020-3.pdf
@eff here: https://twitter.com/EFF/status/1341169696305909760?s=20
@gus_co here: https://twitter.com/g_co/status/1341020932555550722
@katie_haun here: https://twitter.com/katie_haun/status/1340521235264860161?s=20
@blockchainassn here: https://theblockchainassociation.org/wp-content/uploads/2020/12/Blockchain-Association-Letter-to-the-Treasury-December-2020-3.pdf
@eff here: https://twitter.com/EFF/status/1341169696305909760?s=20
@gus_co here: https://twitter.com/g_co/status/1341020932555550722
@katie_haun here: https://twitter.com/katie_haun/status/1340521235264860161?s=20
11/ Continued:
@sidleylaw here: https://www.sidley.com/en/insights/newsupdates/2020/12/fincen-proposes-tracking-and-reporting-virtual-currency
@stellarorg here: https://twitter.com/StellarOrg/status/1340352163592228872?s=20
@brian_armstrong here: https://twitter.com/brian_armstrong/status/1331744884856741888?s=20
@jerallaire here: https://twitter.com/jerallaire/status/1340785282979913734?s=20
@msantoriesq here: https://twitter.com/msantoriESQ/status/1341079957364240388?s=20
@thebluematt here: https://twitter.com/TheBlueMatt/status/1341084526123102208?s=19
@sidleylaw here: https://www.sidley.com/en/insights/newsupdates/2020/12/fincen-proposes-tracking-and-reporting-virtual-currency
@stellarorg here: https://twitter.com/StellarOrg/status/1340352163592228872?s=20
@brian_armstrong here: https://twitter.com/brian_armstrong/status/1331744884856741888?s=20
@jerallaire here: https://twitter.com/jerallaire/status/1340785282979913734?s=20
@msantoriesq here: https://twitter.com/msantoriESQ/status/1341079957364240388?s=20
@thebluematt here: https://twitter.com/TheBlueMatt/status/1341084526123102208?s=19
12/ Okay, that should be all you need to get started.
When you're ready, go to https://www.regulations.gov/document?D=FINCEN_FRDOC_0001-0121 & click "Comment Now!" in the upper right corner. Write in your comment & submit.
If this all seems overwhelming to you, don't worry, there's another option to make it easier.
When you're ready, go to https://www.regulations.gov/document?D=FINCEN_FRDOC_0001-0121 & click "Comment Now!" in the upper right corner. Write in your comment & submit.
If this all seems overwhelming to you, don't worry, there's another option to make it easier.
13/ If you aren't up for writing your own comment or don't have time, you can start with & personalize the pre-filled language in a template form.
@fightfortheftr has a great one, focused on how the rule would infringe financial privacy & property rights. https://www.stopfinancialsurveillance.org/
@fightfortheftr has a great one, focused on how the rule would infringe financial privacy & property rights. https://www.stopfinancialsurveillance.org/
14/ @coincenter also has an awesome template that you can use to send an email directly to Secretary Mnuchin, urging him to remove the most problematic parts of the rule.
You can & should do this *in addition to* submitting a public comment to FinCEN. https://twitter.com/jerrybrito/status/1341427005691191298?s=20
You can & should do this *in addition to* submitting a public comment to FinCEN. https://twitter.com/jerrybrito/status/1341427005691191298?s=20
15/ Please, please, please take some time to submit a comment.
This is the most serious policy fight we've had in a long time. It's truly important that we show up in force -- with both volume & quality -- to claim victory when Secretary Mnuchin moves along on January 20.
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This is the most serious policy fight we've had in a long time. It's truly important that we show up in force -- with both volume & quality -- to claim victory when Secretary Mnuchin moves along on January 20.
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ps/ If the comment link above isn't working for you, use this: https://beta.regulations.gov/document/FINCEN-2020-0020-0001
