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From The News Desk Despite the obvious stress and uncertainty created by the still evolving BitLicense regulatory situation, one positive that has come out of the process has been the public dialogue throughout the lawmaking process.As we’ve covered previously, the New York Department of Financial Services (NYDFS) has taken an open approach to this lawmaking exercise, soliciting feedback and input from crypto-currency entrepreneurs and investors, large retailers, financial services companies, law enforcement, and other regulatory bodies.Earlier today, the NYDFS published the more than 3,700 comments it received over the last four-and-a-half-months.Many, including those by prominent bitcoin organizations like the Bitcoin Foundation, BitPay, Circle, Coinbase, Xapo, Ripple Labs, BTC China, Boost VC and others, have already been published by the companies themselves.But today, for the first time, we get a look into the thoughts and concerns of a number of very large companies, including Walmart, Amazon, and Western Union, that seemingly have nothing to do with virtual currencies.. While each of the above corporate giants have concerns with the initial BitLicense proposal, they come at it from one of two very different perspectives.
Walmart and Amazon’s comments reflect a similar fear that their own captive financial products, like gift cards and closed-loop digital payment solutions, might be caught up in what Amazon describes as the "broad definition” of virtual currency under this proposal.Neither has much concern for the operations of bitcoin-focused startups, or for the risk that virtual currencies might introduce to the financial system.ethereum gtx 1080Walmart was explicit in its request, writing: -- N.Y.cafe accepting bitcoinAbandoned Property Law §103 "Gift certificate" shall mean a written promise or electronic payment device that: (i) is usable at a single merchant or an affiliated group of merchants that share the same name, mark, or logo, or is usable at multiple, unaffiliated merchants or service providers; and (ii) is issued in a specified amount; and (iii) may or may not be increased in value or reloaded; and (iv) is purchased and/or loaded on a prepaid basis for the future purchase or delivery of any goods or services; and (v) is honored upon presentation.mtv bitcoin
So maybe a simple statement that “gift certificates as that term is defined in NY Abandoned Property Law §103 are not considered to be Virtual Currency” tacked on to the part where they call out “affinity or rewards” programs would be perfect.Amazon echoes this request for clarity in the scope of virtual currencies, noting that the BitLicense proposal already contains exemptions for “virtual currency used solely within online gaming platforms and virtual currency used exclusively as part of a customer affinity or rewards program that can only be applied towards purchases from the issuer or designated merchants and cannot be converted into or redeemed for fiat currency.” Western Union, on the other hand, very obviously fears direct competition from bitcoin and other virtual currencies in its core business of money transfer and remittance.bitcoin suisse saNot surprisingly, then, in its comments – which are far and away the longest of the three – the company seeks to ensure that bitcoin businesses are regulated as stringently as possible.wiki bitcoin atm
For example, it asks the NYDFS to include bitcoin ATM “kiosks” under its BitLicense umbrella, writing: At the same time, Western Union would like to ensure that its business is exempt from any further regulation.(It seems the company is hoping the NYDFS ascribes to the “devil you know” school of risk management.)It writes: We urge the DFS to expand this [BitLicense] exemption to include MT Licensees that accept virtual currency as a funding source for money transfers, as described in the following example, and that the DFS has determined have requisite policies and procedures in place to address the risks relating to the acceptance of virtual currency as a funding source for a money transfer ...ethereal harp musicThe DFS would not gain any additional useful information by requiring Western Union to apply for a VC License under proposed section 200.4 for the limited purpose of accepting virtual currency to fund and pay applicable fees for money transfers.bitcoin national geographic
Given the respective business interests of Western Union, Amazon, and Walmart, none of the above responses should be overly surprising.But it's an opportunity for the public to get a glimpse into the political jockeying and power dealing that typically occurs behind the scenes.One thing that stands out in each of the letters is a sense of general entitlement and a matter of fact expectation that these requests will be headed.bitcoin paper wallet iphoneOn the other hand, many of the bitcoin startup comments seem to have a respective sense of fear and uncertainty as to how this process will unfold and how the resulting BitLicense proposal will affect their business.dogecoin appThen again, Coinbase and Circle don’t generate tens of millions in tax revenue or donate hundreds of thousands to political campaigns.Even in the bleeding edge world of virtual currencies, legacy institutions and power dynamics still die hard.