Subject: S7-04-23: Webform Comments from HexCatholic
From: HexCatholic
Affiliation: HEX crypto supporter

Oct. 28, 2023

CC:PA:LPD:PR (REG–122793–19)

Room 5203

Internal Revenue Service

P.O. Box 7604

Ben Franklin Station

Washington, DC 20044

Subject: Comments on Proposed Regulations - Gross Proceeds and Basis
Reporting by Brokers and Determination of Amount Realized and Basis
for Digital Asset Transactions

Dear Internal Revenue Service and Treasury Department,

I have reviewed the PDF document titled Gross Proceeds and Basis
Reporting by Brokers and Determination of Amount Realized and Basis
for Digital Asset Transactions and would like to provide my comments
and concerns regarding the proposed regulations. Specifically, I am
focusing my concerns on the following topics:

1. Privacy: I am concerned about the privacy and safety implications
associated with allowing so many third parties to have access to
sensitive financial data and social security numbers. It seems that
the proposed regulations would require a significant amount of
personal information to be shared, which raises concerns about
potential data breaches and misuse of this information.

2. Identity Theft: I am worried that the proposed regulations will
force participants in DeFi (Decentralized Finance) to collect user
information, which may not be adequately safeguarded. This could
create attractive targets for identity thieves who might exploit the
stored taxpayer information under the guise of tax reporting. It is
important to ensure that proper precautions are in place to protect
against this type of threat.

3. Confusion: The proposed regulations introduce reporting
requirements for various participants in DeFi, which may result in
multiple and inconsistent reports being generated for the same
transaction. This could cause confusion and make it challenging for
individuals and businesses to comply with the regulations accurately.
It would be beneficial to streamline and standardize the reporting
process to minimize confusion and potential errors.

4. Timeliness: I am concerned that the proposed regulations are being
implemented without giving companies and protocols enough time to
adjust and accommodate the new requirements. Rushing the
implementation could lead to compliance challenges and potential
disruptions within the digital asset ecosystem. It is essential to
provide sufficient transition periods to ensure a smooth adjustment
for all stakeholders.

5. Impact Abroad: The proposed regulations do not appear to
sufficiently limit reporting requirements for protocols run outside
the US and users located outside the US. This lack of restriction
could result in unnecessary compliance burdens for international
participants and potentially hinder innovation and adoption beyond US
borders. It is crucial to consider the global nature of digital assets
and address any international impact appropriately.

6. Poorly Defined Terms: I have noticed that the proposed regulations
use undefined terms like "platform," which can lead to
multiple interpretations and confusion. Additionally, the provided
definitions for terms such as "wallet," "smart
contracts," and "validator" do not align with their
technical meanings, resulting in potential misunderstandings. It would
be beneficial to refine and clarify these terms to avoid any
ambiguity.

7. Crypto Centralization: Lastly, I am concerned about the potential
centralization of power to manage and manipulate crypto prices. It is
important to consider the impact of regulations on the decentralized
nature of cryptocurrencies and ensure that any regulations do not
favor or enable undue influence by a select few. Promoting a fair and
transparent market should be a priority.

Thank you for considering my concerns and comments. I believe it is
crucial to address these issues in order to develop regulations that
support both compliance and the continued growth and innovation of the
digital asset ecosystem. I appreciate the opportunity to provide input
and trust that you will carefully consider these concerns.

Sincerely,

HexCatholic