The New York State Department of Financial Services (the “NYSDFS”) has released a proposed regulatory framework (the “Proposed Rules”) for New York virtual currency businesses. The Proposed Rules represent a comprehensive regulatory regime that is likely to have wide-ranging effects on the developing industry. Some of the provisions, such as the consumer protection disclosure requirements, raise potentially significant concerns, especially if other states were to adopt different or inconsistent requirements. NYSDFS will be accepting public comments on the Proposed Rules until September 5, 2014. Interested parties should review the Proposed Rules and provide comments to the NYSDFS as this regulatory approach could also serve as a model for other states. We provide a summary of the key provisions of the Proposed Rules.
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