On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014 issuance of a draft Model Regulatory Framework (“Draft Framework”). The CSBS issued the Final Framework “to assist those states seeking to develop and implement state regulatory regimes for virtual currency activities.” (Of course, one state has already finalized its regulatory regime, so the CSBS’s goal of “consistent regulatory approaches among states” will remain elusive.)

The Final Framework includes a definition of “Virtual Currency,” a general policy statement, a statement of covered and excluded activities, and a set of nine regulatory requirements.