State Virtual Currency Regulatory Developments

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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.

Please see full alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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