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Model Regulatory Framework 



To support the CSBS Policy on State Regulation of Virtual Currency and to promote consistent state regulation of virtual currency activities, CSBS has developed a Model Regulatory Framework ("Model Framework") for state virtual currency regulatory regimes.


Model Regulatory Framework

The Model Regulatory Framework was issued September 15, 2015.

The Model Regulatory Framework is available online here.


CSBS Policy on State Virtual Currency Regulation

The Conference of State Bank Supervisors (“CSBS”) formed the CSBS Emerging Payments Task Force (“Task Force”) to examine the intersection between state supervision, state law and payments developments, and to identify areas for consistent regulatory approaches among states. This effort included an assessment of virtual currency activities and extensive outreach with a broad range of stakeholders. After engagement with industry participants, state and federal regulators, and other stakeholders, CSBS concluded that activities involving third party control of virtual currency, including for the purposes of transmitting, exchanging, holding, or otherwise controlling virtual currency, should be subject to state licensure and supervision.

Contact Information

For questions, please email Margaret Liu



Draft Model Regulatory Framework

The Draft Framework was issued on December 16, 2014 with a 60-day comment period.

The Draft Model Regulatory Framework and questions for public comment is available here.


Public Comments

American Bankers Association Comment Letter

Bitnet Comment Letter

Bitpay Comment Letter

Card Coalition Comment Letter

CATO Institute Comment Letter

Circle Internet Financial, Inc. Comment Letter

Clearing House and Independent Community Bankers of America Comment Letter

COEPTIS Comment Letter

Coinbase Comment Letter 

Coin Center Comment Letter

Coin Corp. Comment Letter

Consumers Union and National Consumer Law Center Comment Letter

Cross River Bank Comment Letter

Debevoise & Plimpton Comment Letter

Epiphyte Comment Letter

New Hampshire Banking Department Comment Letter

Ripple Labs Comment Letter

The Money Services Round Table Comment Letter

Xapo Comment Letter

Additional Comments 

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