The New York Department of Financial Services (NYDFS) has 3,746 comments received on the BitLicense proposal. Superintendent Benjamin Lawsky made the revelation via Twitter, adding that a revised proposal should be out later this month:
All 3,746 public comments DFS received on Bitlicense now live on our site. Revised reg should be out later this month
— Ben Lawsky (@BenLawsky)
Until now, we have been more accustomed to comments arguing that the proposal is too restrictive and that it would stifle the advancement of digital currencies. The revealed comments show some alternative viewpoints, and there were some notable commenters of interest:
Western Union: A lengthy 12-page document, signed by its general counsel, argues that virtual currencies can pose additional risks relative to their fiat counterparts. Therefore, they deserve even more cautious treatment in some scenarios, and some rules should be broadened.
In theory, Bitcoin poses a direct threat to the money transmitter, and speculators will argue that such was its ulterior motive behind its submission.
Amazon: Took issue with wording suggesting a broad enough definition of virtual currency that would apply to its products such as closed-loop digital payment methods and prepaid cards.
Walmart: Also took issue with wording which can be applied to its gift cards.
New York Bankers Association: Regulated financial institutions should be exempt from BitLicense regulations, as they are already subject to oversight by multiple regulatory bodies. Also, the broad definition of virtual currency may cover some unintended products such as credit card rewards programs.
Dogecoin Foundation: Emphasizing their charitable work, the foundation argues that regulations adapted from the traditional financial system aren’t suitable for emerging technologies. They may stifle innovation and hamper charitable/nonprofit work.
In total, 23.17% of comments were unsigned by their authors.