Comments on: US payment regulation should be more like European payment regulation

By: Paul

Paul — Wed, 04 Jun 2014 23:42:29 +0000

I think the terms “issuer” and “exchanger” are sometimes intermixed in this article. A Bitcoin exchanger does not issue bitcoins, but it does sell or buy bitcoins. There should be more clarity in this matter.

By: peter howitt

peter howitt — Tue, 23 Jul 2013 06:25:12 +0000

Interesting article Dave. Issuing virtual currencies like bitcoin don’t really fall within the EU definitions of a regulated payment service (requires cash or equivalent) or a claim against an issuer for the conversion of funds (e-money). The e-money legal concept under EU law is a strange beast and we are likely to see a merger of the PSD and 2EMD in the future so that the focus is on facilitating payment transfers and the management of payments on account outside of the traditional banking system. Good idea for US State passporting for US companies. KR Peter

By: Simon Deane-Johns

Simon Deane-Johns — Wed, 26 Jun 2013 09:49:31 +0000

Thanks for the mention, Dave! I love the idea of a pan-US passport for EU payment institutions and e-money institutions. No doubt those with 40+ state-by-state money services licences would love one of their own, not to mention an EU passport!

Best wishes
Simon

By: John MacAllister

John MacAllister — Wed, 26 Jun 2013 07:12:03 +0000

Dave, let’s not forget what we’re dealing with here. First, we damn Yankees are lucky we’ve even got a national currency and a Federal banking system; it wasn’t that long ago (in US history terms) that we had 48 of each (AK and HI don’t count). Then there’s the little matter of US TBTF banks that aren’t keen on seeing cyber currency slip into their domain; can’t imagine why FINcen jumped on the Bitcoin game so quickly. Oh, right, protectionism. Finally, there’s the non-trivial matter of the Interstate Commerce clause which pretty much insures that our 50 states do just about anything they damn well please when it comes to squeezing fees and penalties out of out-of-the-box thinkers (ask Dwolla) despite the redundant costs and inherent inefficiencies. Other than these nits, I think your idea is a good one.
John

[Dave Birch] Thanks John. Of course I understand the strange US trajectory in these matters