Back in August, the New York Department of Financial Services pushed back the deadline for public commentary on its proposed BitLicenses.

That deadline, October 21, is here.

In the last few days, two big names in the Bitcoin community, BitPay and the Electronic Frontier Foundation, have made public statements about how their organizations perceive the state’s proposed regulations.

On Monday, payment processing service BitPay submitted a letter to New York’s superintendent of financial services, Benjamin Lawsky, expressing concern over the regulations as they were laid out this summer.

Benjamin Lawsky

“[T]he proposed regulation,” BitPay Chief Compliance Officer Tim Byun wrote, “significantly misses the mark in four key areas:

  1. Lacks Innovative Rule-Making That Will Unfortunately Deter Jobs & Innovation,
  2. Creates an Unlevel Playing Field with Other Payment Methods,
  3. Disregards Existing Local/National/International AML Frameworks, and
  4. Lacks Clarity Whether Ancillary Bitcoin Activities Are Covered by Regulations.

“BitPay believes that given the potential use cases and services that are just being built out by the Bitcoin ecosystem, the proposed regulations would stifle growth of jobs and innovation, rather than promote such.”

Byun asked Lawsky in the letter to take into consideration the possibility that regulations would stifle innovations, to work with the AML regulations already in place, to clarify whether the abovementioned ancillary Bitcoin activities (such as software development and data backup services) would fall under the NYDFS’s proposed regulatory umbrella, and to ensure that job-creation isn’t hindered by the regulations.

Cointelegraph reported in mid-October that Lawsky has already said that software developers would not need a BitLicense.

“If you have not submitted your comments to the NYDFS during this comment-period,” Byun wrote in a post on Monday on the BitPay blog, “we strongly suggest you do so during the next comment-period, as every voice represents a Bitcoin-related entrepreneur, industry, or innovation.”

[Editor’s note: here is the link for comment submission]

Alternatively, the Electronic Frontier Foundation — which has ongoing campaigns aimed at ending NSA mass spying and secret transnational copyright trade deals — recently launched a campaign called “Stop the BitLicense.”

You can also copy/paste their prepared letter addressed to Lawsky and simply sign your name to express reservations about the proposed regulations. had a piece Monday quoting Rainey Reitman, director of the EFF’s activism team, who said that the NYDFS’s published proposal was far off from what she had originally anticipated would be a position sympathetic to the Bitcoin community, particularly in regards to anonymity and innovation.

“I was appalled by how broad it was,” Reitman told

Update: Other companies across the Bitcoin landscape have also submitted their comments on the eve of the deadline such as Circle and the Bitcoin advocacy organization, Coin Center, which you can view here.

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