Mr. Benjamin M. Lawsky Superintendent of Financial Services New York Department of Financial Services One State Street New York, NY 10004-1511

July 22nd, 2014

Dear Mr. Lawsky,

The undersigned companies, organizations, and individuals are interested in providing financial services & software products that use or leverage bitcoin and virtual currencies to citizens in the state of New York.

We seek to have all members of the bitcoin community play an active part in submitting thoughtful comments in response to the New York Department of Financial Services rulemaking under Title 23, Part 200: Virtual Currencies or “BitLicense.” Having reviewed the proposal, the undersigned hereby request a minimum 45-day extension to the deadline for filing public comment on the proposed Department of Financial Services rules expected to be published in the New York Registrar on July 23rd, 2014 pursuant to the published guidelines on the NY Department of State website requiring a statutory minimum of 45 or 60 days with additional 30 day period when substantial changes are required.

We believe an extension is necessary if stakeholders and interested parties are to have adequate opportunity to provide constructive feedback on both the broad scope and detailed components of the proposed rules materially impacting an entire nascent industry. Many of us are individuals or small startups operating on limited budgets without access to extensive legal resources. This imposes a substantial burden as we seek to understand the proposed rules and their current and future impacts on our businesses, open-source projects, and educational research.

The Department of Financial Services is requesting comments within the statutory minimum 45 days on 40 pages of focused, detailed, and highly technical company-specific issues. For instance, comments will be required to clarify the inconsistent statements of applicability on the face of the proposed rules to firms that "receiv[e] Virtual Currency for transmission or transmit the same" [Section 200.2(n)(1)] and the apparent exception for merchant and consumers that utilize virtual currency for the “sale of goods or services” [Section 200.3(c)(2)].

On the other hand, the proposal seeks comments on numerous broad, complex macro-level issues. For example, members of the bitcoin community will need to provide clarity to the opaqueness of the proposed definition of “virtual currency business activity" and what that might mean for a business or product/service line [Section 200.3].

The NYDFS has demonstrated a willingness to partner with the bitcoin and virtual currency community by making a good-faith effort of publicly engaging the community to collaboratively draft these rules and regulations that will support commerce & innovation while still providing strong consumer protections for those residing in New York and beyond. It would be a natural extension of this approach to extend the public comment period to allow the bitcoin community to provide sound, reasoned, and concrete feedback to the proposed rules.

Thank you for your consideration of this request and we would be happy to discuss these issues at your convenience.

Sincerely,