Oct. 16, 2023
Dear Securities and Exchange Commission, Thank you for re-opening public comments on the proposed cryptocurrency regulations. I appreciate the opportunity to share additional perspectives. As an active investor in the cryptocurrency market, I have some concerns about the potential impacts of certain aspects of the proposed regulations. While I understand the desire for oversight and security precautions, some of the new reporting requirements seem excessive. Requiring detailed personal information to be collected and reported for all cryptocurrency transactions over $10 goes too far in my opinion. This would be a clear invasion of privacy for many investors and raises significant data security concerns. I am also worried about the expanded definition of "broker" to include cryptocurrency platforms. This would put undue compliance burdens on these services which could limit consumer access to cryptocurrency markets and cede innovation overseas. Driving companies away through excessive regulation may cause the U.S. to lose leadership in this space. Furthermore, requiring basis reporting on all coin-to-coin trades would be nearly impossible to implement. Tracking basis across frequent trading of assets is not realistic. Overly strict rules could push some activity into unregulated markets, undermining financial transparency. I am particularly concerned about impacts on decentralized finance (DeFi) which has great potential for expanding financial access. However, excessive regulation of cryptocurrency transactions could significantly hinder DeFi innovation in the U.S. Blanketly categorizing all cryptocurrencies as securities has no legal precedent. Crypto should not be treated as securities until specific assets are deemed as such by courts. Overly intricate rules often have unintended consequences or loopholes. The U.S. risks falling behind other countries if regulatory stance is too restrictive. Targeted, proportional policies would be a better strategy than broad rules. I hope these perspectives provide value as you refine the regulatory approach to protect consumers while fostering responsible innovation. Please feel free to contact me with any questions. Thank you for your consideration.