On February 4, 2015, the New York Department of Financial Services (“NYDFS”) issued for public comment a revised proposed rule to implement a “BitLicense” regulatory regime (the “2015 Proposal”). As discussed below, the 2015 Proposal differs in material respects from the July 2014 proposal (the “2014 Proposal”), on which we previously reported.

In addition, the Conference of State Bank Supervisors (“CSBS”) has issued for comment a draft model regulatory framework on virtual currency activities. The summary below identifies certain key differences between the CSBS proposal and the NYDFS proposal.