Update (Feb. 4th, 2015) new
Update (Dec. 18th, 2014)
Key Points of Bitlicense Announcement at Today's Event
1) New draft in next 2 days. (Edit: 2 days have passed and it still hasn't been released. It should be released shortly.)
2) There will be a 30 day comment period after release of new draft.
3) Late January is expected timeframe for Bitlicense to go live.
4) Software developers, merchants, miners, consumers and investors are exempt.
5) Required to keep 7 years of records, down from 10 years in the original draft.
6) Not required to keep records for virtual digital currency transactions.
7) Interim 2 year licenses will be prioritized to businesses that may not yet be able to qualify but wish to comply.
Update (Dec. 17th, 2014)
New York Department of Financial Services Superintendent Ben Lawsky on Twitter: We're outlining updates to our BitLicense regulatory framework tomorrow at Bipartisan Policy Event.
Update (Dec. 3rd, 2014)
According to Superintendent Lawsky on Twitter, the revised version of the Bitlicense should be released later this month. Furthermore, all public responses to the Bitlicense are now available online.
All 3,746 public comments DFS received on Bitlicense now live on our site. Revised reg should be out later this month http://t.co/cvkrFrwjMx— Ben Lawsky (@BenLawsky) December 3, 2014
Update (Oct. 21st, 2014)
With the public comment period ending today, here are the next steps the NYDFS plans to take, based on Superintendent Lawsky's comments at the Bitlicense discussion that took place at Cardozo Law School last week:
According to Superintendent Lawsky, the next steps are as follows:
1) NYDFS will read and make public all comments.
2) NYDFS will release redrafted guidelines.
3) NYDFS will open up another public commentary period.
4) NYDFS will release final regulations with 45-60 days for companies to comply.
Update (August 21st, 2014):
The NYDFS has extended the Bitlicense Comment Period by 45 days to October 21st, 2014.
A little less than a month ago, Superintendent Benjamin Lawsky, on behalf of the New York State Department of Financial Services, presented their Bitlicense guidelines. These guidelines are meant to be the model for future federal Bitcoin regulations and are now under a 45 day community review period. Many industry players feel that the review period is too short and request that it be extended in good faith. One thing is for certain, if regulations are too strict, then businesses will move elsewhere.
The estimated total cost to apply for a New York BitLicense for the hypothetical company described above would be $12,000 to $15,000. - Jason Tyra | Bitcoin Tax Blog
Below we have compiled responses from individuals and organizations throughout the industry. This page will be updated as new responses are posted online. If you have a response you would like us to add, email me at email@example.com
Bitlicense Responses w/ Petition Attached
- Industry Extension Request
- Chamber of Digital Commerce Petition
- Open Source Financial Developers Association
- Electronic Frontier Foundation (EFF.org) Bitlicense Response and Petition
Bitlicense Responses with no Petition
- Bitcoin Foundation
- Jeremy Allaire of Circle.com
- Sean Neville of Circle.com
- Bitcoin Foundation Canada
- Chamber of Digital Commerce Full Response
- Joint Response by Chinese Exchanges - BTCChina, OKCoin, & Huobi
- Forked version of Bitlicense Guidelines on Github
- Bruce Fenton
- Sean King
- BitcoinTaxBlog on the numbers behind the Bitlicense Guidelines
- E-Commerce Lawyer Benjamin Wright
- Startup Lawyer Eric Dixon
- Bitcoin Foundation Disappointment with NYSDFS
- Coinbase responds to Bitlicense Guidelines
- Bitcoin Foundation Full Response
- Beware the BitLicense: New York’s Virtual Currency Regulations Invade Privacy and Hamper Innovation (EFF.org)
- Center for Democracy & Technology - NY’s Proposed BitRegs a Threat to Privacy and Innovation
- Full Response by Circle.com (PDF)
- CoinCenter.org Full Response(PDF)
- BitPay Full Response(PDF)
- Bitwage’s Comments on BitLicense: A Payroll Perspective
- EFF, Internet Archive, and reddit Oppose New York’s BitLicense Proposal
- Xapo's full response to Bitlicense Guidelines (PDF)
- Dogecoin Foundation Responds to Bitlicense (PDF)
- Awaiting the Next “BitLicense” Draft, We Still Need the Research, and You
Protests to Bitlicense
You should send your own responses/thoughts on the Bitlicense to NYDFS:
Dana V. Syracuse Office of General Counsel New York Department of Financial Services One State Street New York, NY 10004-1511 Email: firstname.lastname@example.org