DeathAndTaxes
You bring up a HUGE issue. There is no Regulator at the Federal Level for "money transmitters" the "Money Service Business" category that FinCEN put the bitcoin industry in with the March 18th Guidance.
This is some thing the National Money Transmitter Assocaition is trying to address with upcoming "Industry Symposium for Legislative Action - (ISLA)" February 18, 2014 9:00 AM to 5:00 PM EST in Washington DC.
Carnegie Endowment for International Peace
1779 Massachusetts Avenue NW
Washington, DC 20036-2103
This will be an all-day forum, hosted by the NMTA, that seeks to bring together everyone in the payments services industries to discuss what a National Payments Services Act might look like. Here is why we believe such an Act would be beneficial:
To make the regulation of payments services providers more economical, efficient and effective for both the government and private sectors.
To better protect the United States from financial crime and the funding of terrorism.
To better protect the rights of consumers and ensure a fair, transparent marketplace for payments services.
To provide a national insurance fund for the protection of money transmission consumers.
To provide regulators and law enforcement with a centralized, national database of all those companies licensed to do money transmission in the United States and their agents.
To provide regulators and law enforcement with timely, actionable information.
To establish minimum regulatory standards for all payments services providers serving the US public and to promote greater regulatory consistency across the states.
To allow better communication and coordinated action among the federal government and the various States, in the regulation of payments services providers.
To ensure regulation is consistent, continuous and appropriate across all types of money transmitting industries and all money transmitting business, no matter of what size.
To monitor the orderly banking of payments services providers and provide reasonable access to the banking system for licensed money transmitting companies that are essential to our economy.
To allow non-US providers of payments services with no physical location in the US, to serve the US market and to ensure they meet regulatory standards that are consistent and centrally-administered.
To promote competition and remove unnecessary barriers to interstate trade.
To encourage the healthy development and growth of money transmitting companies and support public confidence in those companies.
To encourage and promote technological innovation in financial services.
To ensure that any US consumer no matter where located, can patronize any licensed US provider of payments services, no matter where that company is located.
To provide a framework within which the payments services industries can regulate themselves to the greatest extent possible.
To ensure that US financial marketplaces remain competitive on the world stage.
To better provide for coordinated action among the US government and foreign governments in the prudential and anti-money laundering regulation of the various payments services industries.
This meeting is for the payment services industries, their trade associations, independent reviewers and legal advisers. This includes not only money transmitters of all kinds, but also money order issuers, check cashers, foreign exchange dealers, web-based transmitters, prepaid access providers, mobile money transfer operators, third party payment services providers and virtual currency dealers.
Attendees are encouraged to address the group, and your written materials will be posted. If you are interested in attending ISLA, please click here to register. Registration is free, lunch is on your own.
Help us hammer out a regulatory framework that will let all US consumers use any licensed provider, and enable the normalized banking of these vital industries.
Regards,
- David Landsman
https://events.r20.constantcontact.com/register/eventReg?oeidk=a07e8ofjkaq22e8c4db&oseq=&c=&ch=
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