Request for Input on Crypto-Asset Mechanics and Markets, 64563-64566 [2018-27167]
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Federal Register / Vol. 83, No. 241 / Monday, December 17, 2018 / Notices
proposed take as a percentage of stock
abundance that are high compared to
actual take that will occur. This is the
case with the resident stocks of killer
whale and harbor seal (Lynn Canal/
Stephens Passage stock).
As reported, a small number of harbor
seals, most of which reside in Taiya
Inlet year-round, will be exposed to
construction activities for three months.
The total population estimate in the
Lynn Canal/Stephens Passage stock is
9,478 animals over 1.37 million acres
(5,500 km2) of area in their range, which
results in an estimated density of 36
animals within Taiya Inlet. The largest
Level B harassment zone within the
inlet occupies 17.9 km2, which
represents less than 0.4 percent of the
total geographical area occupied by the
stock. The great majority of these
exposures will be to the same animals
given their residency patterns.
Based on the analysis contained
herein of the proposed activity
(including the proposed mitigation and
monitoring measures) and the
anticipated take of marine mammals,
NMFS preliminarily finds that small
numbers of marine mammals will be
taken relative to the population size of
the affected species or stocks.
whenever we propose to authorize take
for endangered or threatened species.
NMFS is proposing to authorize take
of the Steller sea lion western DPS and
humpback whale Mexico DPS, which
are listed under the ESA. On November
29, 2018, the NMFS Office of Protected
Resources has requested initiation of
section 7 consultation with the Alaska
Regional Office for the issuance of this
IHA. NMFS will conclude the ESA
consultation prior to reaching a
determination regarding the proposed
issuance of the authorization.
Unmitigable Adverse Impact Analysis
and Determination
We request comment on our analyses,
the proposed authorization, and any
other aspect of this Notice of Proposed
IHA for the proposed action. We also
request comment on the potential for
renewal of this proposed IHA as
described in the paragraph below.
Please include with your comments any
supporting data or literature citations to
help inform our final decision on the
request for MMPA authorization.
On a case-by-case basis, NMFS may
issue a second one-year IHA without
additional notice when (1) another year
of identical or nearly identical activities
as described in the Specified Activities
section is planned or (2) the activities
would not be completed by the time the
IHA expires and a second IHA would
allow for completion of the activities
beyond that described in the Dates and
Duration section, provided all of the
following conditions are met:
• A request for renewal is received no
later than 60 days prior to expiration of
the current IHA.
• The request for renewal must
include the following:
(1) An explanation that the activities
to be conducted beyond the initial dates
either are identical to the previously
analyzed activities or include changes
so minor (e.g., reduction in pile size)
that the changes do not affect the
previous analyses, take estimates, or
There are no relevant subsistence uses
of the affected marine mammal stocks or
species implicated by this action. The
proposed project will occur near but not
overlap with the subsistence area used
by the villages of Hoonah and Angoon
(Wolfe et al. 2013; N. Kovaces, Skagway
Traditional Council, personal
communication). Harbor seals and
Steller sea lions are available for
subsistence harvest in this area (Wolfe
et al. 2013). Therefore, NMFS has
preliminarily determined that the total
taking of affected species or stocks
would not have an unmitigable adverse
impact on the availability of such
species or stocks for taking for
subsistence purposes.
amozie on DSK3GDR082PROD with NOTICES1
Endangered Species Act
Section 7(a)(2) of the Endangered
Species Act of 1973 (ESA: 16 U.S.C.
1531 et seq.) requires that each Federal
agency insure that any action it
authorizes, funds, or carries out is not
likely to jeopardize the continued
existence of any endangered or
threatened species or result in the
destruction or adverse modification of
designated critical habitat. To ensure
ESA compliance for the issuance of
IHAs, NMFS consults internally, in this
case with the Alaska Regional Office,
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Proposed Authorization
As a result of these preliminary
determinations, NMFS proposes to issue
an IHA to WP&YR for conducting the
Railroad Dock dolphin installation
project in Skagway, Alaska from
February 1, 2019 through April 30,
2019, provided the previously
mentioned mitigation, monitoring, and
reporting requirements are incorporated.
A draft of the IHA itself is available for
review in conjunction with this notice
at https://www.fisheries.noaa.gov/
national/marine-mammal-protection/
incidental-take-authorizationsconstruction-activities
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mitigation and monitoring
requirements.
(2) A preliminary monitoring report
showing the results of the required
monitoring to date and an explanation
showing that the monitoring results do
not indicate impacts of a scale or nature
not previously analyzed or authorized.
• Upon review of the request for
renewal, the status of the affected
species or stocks, and any other
pertinent information, NMFS
determines that there are no more than
minor changes in the activities, the
mitigation and monitoring measures
remain the same and appropriate, and
the original findings remain valid.
Dated: December 12, 2018.
Donna S. Weiting,
Director, Office of Protected Resources,
National Marine Fisheries Service.
[FR Doc. 2018–27258 Filed 12–14–18; 8:45 am]
BILLING CODE 3510–22–P
COMMODITY FUTURES TRADING
COMMISSION
Request for Input on Crypto-Asset
Mechanics and Markets
Commodity Futures Trading
Commission.
ACTION: Request for input.
AGENCY:
Request for Public Comments
PO 00000
64563
The Commodity Futures
Trading Commission (‘‘Commission’’ or
‘‘CFTC’’) in furtherance of the LabCFTC
initiative is seeking public comment
and feedback on this Request for Input
(‘‘RFI’’) in order to better inform the
Commission’s understanding of the
technology, mechanics, and markets for
virtual currencies beyond Bitcoin,
namely here Ether and its use on the
Ethereum Network. The Commodity
Exchange Act (‘‘CEA’’) grants the
Commission regulatory authority over
the commodity futures markets. The
Commission is seeking public feedback
in furtherance of oversight of these
markets and regulatory policy
development. The input from this
request will advance the CFTC’s
mission of ensuring the integrity of the
derivatives markets as well as
monitoring and reducing systemic risk
by enhancing legal certainty in the
markets. The RFI seeks to understand
similarities and distinctions between
certain virtual currencies, including
here Ether and Bitcoin, as well as Etherspecific opportunities, challenges, and
risks. The Commission welcomes all
public comments on these and related
issues.
SUMMARY:
Comments must be received on
or before February 15, 2019.
DATES:
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Federal Register / Vol. 83, No. 241 / Monday, December 17, 2018 / Notices
You may submit comments,
identified by the title, ‘‘Virtual Currency
RFI,’’ by any of the following methods:
• CFTC website: https://
comments.cftc.gov. Follow the
instructions to Submit Comments
through the website.
• Mail: Send to Christopher
Kirkpatrick, Secretary of the
Commission, Commodity Futures
Trading Commission, Three Lafayette
Centre, 1155 21st Street NW,
Washington, DC 20581.
• Hand Delivery/Courier: Same as
Mail, above.
Please submit comments by only one
of these methods.
All comments should be submitted in
English or accompanied by an English
translation. Comments will be posted as
received to https://www.cftc.gov. You
should submit only information that
you wish to make available publicly. If
you wish the Commission to consider
information that may be exempt from
disclosure under the Freedom of
Information Act (‘‘FOIA’’), a petition for
confidential treatment of the exempt
information may be submitted according
to the procedures established in the
Commission’s regulations at 17 CFR
145.9.1 The Commission reserves the
right, but shall have no obligation, to
review, prescreen, filter, redact, refuse,
or remove any or all of your submission
from https://www.cftc.gov that it may
deem to be inappropriate for
publication, such as obscene language.
All submissions that have been redacted
or removed that contain comments on
the merits of the RFI will be retained in
the public comment file and will be
considered as required under the
Administrative Procedure Act and other
applicable laws, and may be accessible
under the FOIA.
FOR FURTHER INFORMATION CONTACT:
Daniel Gorfine, Director of LabCFTC
and Chief Innovation Officer, (202) 418–
5625; Bianca M. Gomez, Counsel on
FinTech and Innovation, Office of
General Counsel, (202) 418–5627; or
LabCFTC@cftc.gov.
SUPPLEMENTARY INFORMATION:
ADDRESSES:
I. Background
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A. Introduction
The CEA grants the Commission
regulatory authority over the commodity
futures markets.2 LabCFTC was
launched by the Commission in order to
further the CFTC’s goal of evolving as a
21st century regulator and keeping pace
1 17 CFR 145.9. All Commission regulations cited
herein are set forth in chapter I of Title 17 of the
Code of Federal Regulations.
2 See, e.g., 7 U.S.C. 5(b).
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with technological innovation. LabCFTC
is dedicated to facilitating marketenhancing financial technology
(‘‘FinTech’’) innovation, informing
policy, and ensuring that we have the
regulatory and technological tools and
understanding to keep pace with
changing markets. LabCFTC is designed
to make the CFTC more accessible to all
innovators and to inform the
Commission’s understanding of
emerging technologies and their
regulatory implications. One such area
of emerging innovation involves virtual
currencies.
In further advancing its mission,
LabCFTC published a primer on the
topic of virtual currencies in October
2017 (the ‘‘Primer’’) in order to help
educate the public on potential
applications and use-cases, the CFTC’s
role and jurisdictional oversight, and
potential risks and challenges that
investors and users may face involving
virtual currencies.3
In December 2017, the Chicago
Mercantile Exchange Inc. (‘‘CME’’) and
the CBOE Futures Exchange (‘‘CFE’’)
self-certified and began offering new
contracts for bitcoin futures products
following discussions with Commission
staff regarding compliance with the CEA
and Commission rules and regulations.
In line with Chairman Giancarlo’s
repeated statements 4 regarding the
unique nature and risks of virtual
currency-related products, the CFTC’s
Division of Market Oversight (‘‘DMO’’)
and Division of Clearing and Risk
(‘‘DCR’’) issued on May 21, 2018 a joint
staff advisory 5 that gives exchanges and
clearinghouses registered with the CFTC
guidance on certain enhancements
when listing a derivative contract based
on virtual currency pursuant to
Commission regulations. The input
being sought here will better inform the
Commission and its operating divisions
as the market evolves and potentially
seeks to list new virtual currency based
futures and derivatives products.
B. Bitcoin as a Virtual Currency
In its October 2017 Primer, LabCFTC
cited the IRS to define a virtual currency
as ‘‘a digital representation of value that
3 ‘‘A CFTC Primer on Virtual Currencies,’’ (Oct.
17, 2017), https://www.cftc.gov/sites/default/files/
idc/groups/public/documents/file/labcftc_
primercurrencies100417.pdf.
4 See, e.g., Testimony of Chairman J. Christopher
Giancarlo before the Senate Committee On
Appropriations Subcommittee on Financial
Services and General Government (June 5, 2018),
https://www.cftc.gov/PressRoom/SpeechesTest
imony/opagiancarlo47.
5 CFTC Staff Advisory No. 18–14 (May 21, 2018),
https://www.cftc.gov/sites/default/files/idc/groups/
public/%40lrlettergeneral/documents/letter/201805/18-14_0.pdf.
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functions as a medium of exchange, a
unit of account, and/or a store of value
. . . [but that] does not have legal
tender status.’’ 6 The Primer further
noted key characteristics of Bitcoin,
including that it:
D Is ‘‘pseudonymous’’ (or partially
anonymous) in that an individual is
identified by an alpha-numeric public
key/address;
D Relies on cryptography (and unique
digital signatures) for security based on
public and private keys and complex
mathematical algorithms;
D Runs on a decentralized peer-topeer network of computers and
‘‘miners’’ that operate on open-source
software and do ‘‘work’’ to validate and
irrevocably log transactions on a
permanent public distributed ledger
visible to the entire network;
D Solves the lack of trust between
participants who may be strangers to
each other on a public ledger through
the transaction validation work noted in
the bullet above; and
D Enables the transfer of ownership
without the need for a trusted, central
intermediary.
The Primer noted potential
applications or use cases of a virtual
currency like Bitcoin, including that it
may serve as a store of value, be used
for trading, enable payments and value
transfers, power applications built upon
the virtual currency network, and
facilitate money transfers or
international remittances. The Primer
further highlighted a range of potential
risks around virtual currencies,
including technology, operational,
cybersecurity, speculative, and fraud
and manipulation risks.
C. Ether as a Virtual Currency
In June 2018, the Director of the
Securities and Exchange Commission’s
(‘‘SEC’’) Division of Corporation
Finance, Bill Hinman, delivered a
speech which conveyed Mr. Hinman’s
personal views. In the speech, he
addressed the question of whether ‘‘a
digital asset that was originally offered
in a securities offering [could] ever be
later sold in a manner that does not
constitute an offering of a security.’’ He
explained among other factors that since
the network on which Bitcoin operates
appears to be decentralized and there is
no central third party whose efforts are
6 See Primer, supra note 3, at 4 (citing IRS Notice
2014–21, available at https://www.irs.gov/
businesses/small-businesses-self-employed/virtualcurrencies). See also Proposed Interpretation on
Virtual Currency ‘‘Actual Delivery’’ in Retail
Transactions (Dec. 15, 2017), 82 FR 60335 (Dec. 20,
2017), https://www.cftc.gov/sites/default/files/idc/
groups/public/@lrfederalregister/documents/file/
2017-27421a.pdf.
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Federal Register / Vol. 83, No. 241 / Monday, December 17, 2018 / Notices
a key determining factor in the success
of Bitcoin, ‘‘[a]pplying the disclosure
regime of the federal securities laws to
the offer and resale of Bitcoin would
seem to add little value.’’ He further
stated that, in addition to Bitcoin,
‘‘based on my understanding of the
present state of Ether, the Ethereum
network and its decentralized structure,
current offers and sales of Ether are not
securities transactions.’’ Finally, he
stated that ‘‘[o]ver time, there may be
other sufficiently decentralized
networks and systems where regulating
the tokens or coins that function on
them as securities may not be
required.’’ 7
Ether is a virtual currency that was
launched on the Ethereum Network in
2015. It is an open network that
currently relies on a proof of work
consensus mechanism, but developers,
including through the Ethereum
Foundation, have plans to shift the
protocol to a proof of stake consensus
model in order, at least in part, to
reduce energy consumption required to
validate the ledger.8 The Ethereum
Network is often viewed as a platform
that permits ready creation and use of
smart contracts that can power
decentralized applications or
organizations. In this way, Ether is used
as ‘‘fuel’’ to compensate miners for
maintaining a public ledger for such
networks.9 To date, Ether has typically
been one of the top three virtual
currencies by market capitalization.
II. Request for Input
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The Commission is seeking public
feedback namely on Ether and the
Ethereum Network in order to better
understand these technologies given
Ether’s size in the market and
potentially unique attributes relative to
Bitcoin. The Commission is issuing this
RFI in order to gather public feedback
on a range of questions related to the
underlying technology, opportunities,
risks, mechanics, use cases, and
markets, related to Ether and the
Ethereum Network. The requested
information will inform the work of
LabCFTC and the Commission as a
whole. The Commission welcomes any
relevant comments, including related
topics that may not be specifically
7 ‘‘Digital Asset Transactions: When Howey Met
Gary (Plastic),’’ Remarks of William Hinman,
Director, Division of Corporation Finance, SEC at
the Yahoo Finance All Markets Summit: Crypto
(June 14, 2018), https://www.sec.gov/news/speech/
speech-hinman-061418.
8 See Ethereum Foundation, Frequently Asked
Questions, available at https://www.ethereum.org/
ether (last visited Aug. 22, 2018).
9 See id.
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mentioned but which a commenter
believes should be considered.
Specific Questions for Input
In addition to any general input, the
Commission is interested in responses
to the following questions:
Purpose and Functionality
1. What was the impetus for
developing Ether and the Ethereum
Network, especially relative to Bitcoin?
2. What are the current functionalities
and capabilities of Ether and the
Ethereum Network as compared to the
functionalities and capabilities of
Bitcoin?
3. How is the developer community
currently utilizing the Ethereum
Network? More specifically, what are
prominent use cases or examples that
demonstrate the functionalities and
capabilities of the Ethereum Network?
4. Are there any existing or
developing commercial enterprises that
are using Ether to power economic
transactions? If so, how is Ether
recorded for accounting purposes in a
comprehensive set of financial
statements?
5. What data sources, analyses,
calculations, variables, or other factors
could be used to determine Ether’s
market size, liquidity, trade volume,
types of traders, ownership
concentration, and/or principal ways in
which the Ethereum Network is
currently being used by market
participants?
6. How many confirmations on the
Ethereum blockchain are sufficient to
wait to ensure that the transaction will
not end up on an invalid block?
Technology
7. How is the technology underlying
Ethereum similar to and different from
the technology underlying Bitcoin?
8. Does the Ethereum Network face
scalability challenges? If so, please
describe such challenges and any
potential solutions. What analyses or
data sources could be used to assess
concerns regarding the scalability of the
underlying Ethereum Network, and in
particular, concerns about the network’s
ability to support the growth and
adoption of additional smart contracts?
9. Has a proof of stake consensus
mechanism been tested or validated at
scale? If so, what lessons or insights can
be learned from the experience?
10. Relative to a proof of work
consensus mechanism does proof of
stake have particular vulnerabilities,
challenges, or features that make it
prone to manipulation? In responding
consider, for example, that under a
proof of stake consensus mechanism,
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64565
the chance of validating a block may be
proportional to staked wealth.
11. There are reports of disagreements
within the Ether community over the
proposed transition to a proof of stake
consensus model. Could this transition
from a proof of work to a proof of stake
verification process result in a
fragmented or diminished Ether market
if the disagreements are not resolved?
12. What capability does the
Ethereum Network have to support the
continued development and increasing
use of smart contracts?
Governance
13. How is the governance of the
Ethereum Network similar to and
different from the governance of the
Bitcoin network?
14. In light of Ether’s origins as an
outgrowth from the Ethereum Classic
blockchain, are there potential issues
that could make Ether’s underlying
blockchain vulnerable to future hard
forks or splintering?
Markets, Oversight and Regulation
15. Are there protections or
impediments that would prevent market
participants or other actors from
intentionally disrupting the normal
function of the Ethereum Network in an
attempt to distort or disrupt the Ether
market?
16. What impediments or risks exist
to the reliable conversion of Ether to
legal tender? How do these
impediments or risks impact regulatory
considerations for Commission
registrants with respect to participating
in any transactions in Ether, including
the ability to obtain or demonstrate
possession or control or otherwise hold
Ether as collateral or on behalf of
customers?
17. How would the introduction of
derivative contracts on Ether potentially
change or modify the incentive
structures that underlie a proof of stake
consensus model?
18. Given the evolving nature of the
Ether cash markets underlying potential
Ether derivative contracts, what are the
commercial risk management needs for
a derivative contract on Ether?
19. Please list any potential impacts
on Ether and the Ethereum Network that
may arise from the listing or trading of
derivative contracts on Ether.
20. Are there any types of trader or
intermediary conduct that has occurred
in the international Ether derivative
markets that raise market risks or
challenges and should be monitored
closely by trading venues or regulators?
21. What other factors could impact
the Commission’s ability to properly
oversee or monitor trading in derivative
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Federal Register / Vol. 83, No. 241 / Monday, December 17, 2018 / Notices
contracts on Ether as well as the
underlying Ether cash markets?
22. Are there any emerging best
practices for monitoring the Ethereum
Network and public blockchains more
broadly?
Cyber Security and Custody
III. Conclusion
The Commission appreciates your
time and effort responding to this RFI
on Crypto-asset Mechanics and Markets.
The information provided by
stakeholders will help us refine our
understanding of this area of innovation
and better inform the work of the
Commission, including the evaluation
of potential derivatives contracts. More
broadly, the input from this request will
further aid the Commission in
identifying FinTech trends and related
opportunities, challenges, and risks. In
that respect, we look forward to
continuing to engage proactively with
the innovator community and market
participants in order to help facilitate
market-enhancing innovation and
ensure market integrity.
amozie on DSK3GDR082PROD with NOTICES1
Issued in Washington, DC, on December
11, 2018, by the Commission.
Christopher Kirkpatrick,
Secretary of the Commission.
Appendix to Request for Input on
Crypto-asset Mechanics and Markets—
Commission Voting Summary
On this matter, Chairman Giancarlo and
Commissioners Quintenz, Behnam, Stump,
and Berkovitz voted in the affirmative. No
Commissioner voted in the negative.
[FR Doc. 2018–27167 Filed 12–14–18; 8:45 am]
BILLING CODE 6351–01–P
19:17 Dec 14, 2018
[Docket No. CFPB–2018–0041]
Agency Information Collection
Activities: Comment Request
Bureau of Consumer Financial
Protection.
ACTION: Notice and request for comment.
AGENCY:
23. Are there security issues peculiar
to the Ethereum Network or Ethereumsupported smart contracts that need to
be addressed?
24. Are there any best practices for the
construction and security of Ethereum
wallets, including, but not limited to,
the number of keys required to sign a
transaction and how access to the keys
should be segregated?
25. Are there any best practices for
conducting an independent audit of
Ether deposits?
In providing your responses, please be
as specific as possible, and offer
concrete examples where appropriate.
Please provide any relevant data to
support your answers where
appropriate. The Commission
encourages all relevant comments on
related items or issues; commenters
need not address every question.
VerDate Sep<11>2014
BUREAU OF CONSUMER FINANCIAL
PROTECTION
Jkt 247001
In accordance with the
Paperwork Reduction Act of 1995
(PRA), the Bureau of Consumer
Financial Protection (Bureau) is
requesting to renew the Office of
Management and Budget (OMB)
approval for an existing information
collection, titled Interstate Land Sales
Full Disclosure Act (Regulations J, K &
L) 12 CFR 1010, 1011, 1012.
DATES: Written comments are
encouraged and must be received on or
before February 15, 2019 to be assured
of consideration.
ADDRESSES: You may submit comments,
identified by the title of the information
collection, OMB Control Number (see
below), and docket number (see above),
by any of the following methods:
• Electronic: Go to https://
www.regulations.gov. Follow the
instructions for submitting comments.
• Email: FederalRegisterComments@
cfpb.gov. Include Docket No. CFPB–
2018–0041 in the subject line of the
message.
• Mail: Comment Intake, Bureau of
Consumer Financial Protection
(Attention: PRA Office), 1700 G Street
NW, Washington, DC 20552.
• Hand Delivery/Courier: Comment
Intake, Bureau of Consumer Financial
Protection (Attention: PRA Office), 1700
G Street NW, Washington, DC 20552.
Please note that comments submitted
after the comment period will not be
accepted. In general, all comments
received will become public records,
including any personal information
provided. Sensitive personal
information, such as account numbers
or Social Security numbers, should not
be included.
FOR FURTHER INFORMATION CONTACT:
Documentation prepared in support of
this information collection request is
available at www.regulations.gov.
Requests for additional information
should be directed to Darrin King, PRA
Officer, at (202) 435–9575, or email:
CFPB_PRA@cfpb.gov. If you require this
document in an alternative electronic
format, please contact CFPB_
Accessibility@cfpb.gov. Please do not
submit comments to these email boxes.
SUPPLEMENTARY INFORMATION:
SUMMARY:
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Title of Collection: Interstate Land
Sales Full Disclosure Act (Regulations J,
K & L) 12 CFR 1010, 1011, 1012.
OMB Control Number: 3170–0012.
Type of Review: Renewal without
change of an existing information
collection.
Affected Public: Businesses and other
for-profit entities.
Estimated Number of Respondents:
197.
Estimated Total Annual Burden
Hours: 3,411.
Abstract: The Interstate Land Sales
Full Disclosure Act (ILSA) requires land
developers to register subdivisions of
100 or more non-exempt lots or units
and to provide each purchaser with a
disclosure document designated as a
property report, 15 U.S.C. 1703–1704.
ILSA was enacted in response to a
nation-wide proliferation of developers
of unimproved subdivisions who made
elaborate and often fraudulent, claims
about their land to unsuspecting lot
purchasers. Information is submitted to
the Bureau of Consumer Financial
Protection (Bureau) to assure
compliance with ILSA and the
implementing regulations. The Bureau
also investigates developers who are not
in compliance with the regulations.
Request for Comments: Comments are
invited on: (a) Whether the collection of
information is necessary for the proper
performance of the functions of the
Bureau, including whether the
information will have practical utility;
(b) The accuracy of the Bureau’s
estimate of the burden of the collection
of information, including the validity of
the methods and the assumptions used;
(c) Ways to enhance the quality, utility,
and clarity of the information to be
collected; and (d) Ways to minimize the
burden of the collection of information
on respondents, including through the
use of automated collection techniques
or other forms of information
technology. Comments submitted in
response to this notice will be
summarized and/or included in the
request for OMB approval. All
comments will become a matter of
public record.
Dated: December 11, 2018.
Darrin A. King,
Paperwork Reduction Act Officer, Bureau of
Consumer Financial Protection.
[FR Doc. 2018–27262 Filed 12–14–18; 8:45 am]
BILLING CODE 4810–AM–P
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Agencies
[Federal Register Volume 83, Number 241 (Monday, December 17, 2018)]
[Notices]
[Pages 64563-64566]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-27167]
=======================================================================
-----------------------------------------------------------------------
COMMODITY FUTURES TRADING COMMISSION
Request for Input on Crypto-Asset Mechanics and Markets
AGENCY: Commodity Futures Trading Commission.
ACTION: Request for input.
-----------------------------------------------------------------------
SUMMARY: The Commodity Futures Trading Commission (``Commission'' or
``CFTC'') in furtherance of the LabCFTC initiative is seeking public
comment and feedback on this Request for Input (``RFI'') in order to
better inform the Commission's understanding of the technology,
mechanics, and markets for virtual currencies beyond Bitcoin, namely
here Ether and its use on the Ethereum Network. The Commodity Exchange
Act (``CEA'') grants the Commission regulatory authority over the
commodity futures markets. The Commission is seeking public feedback in
furtherance of oversight of these markets and regulatory policy
development. The input from this request will advance the CFTC's
mission of ensuring the integrity of the derivatives markets as well as
monitoring and reducing systemic risk by enhancing legal certainty in
the markets. The RFI seeks to understand similarities and distinctions
between certain virtual currencies, including here Ether and Bitcoin,
as well as Ether-specific opportunities, challenges, and risks. The
Commission welcomes all public comments on these and related issues.
DATES: Comments must be received on or before February 15, 2019.
[[Page 64564]]
ADDRESSES: You may submit comments, identified by the title, ``Virtual
Currency RFI,'' by any of the following methods:
CFTC website: https://comments.cftc.gov. Follow the
instructions to Submit Comments through the website.
Mail: Send to Christopher Kirkpatrick, Secretary of the
Commission, Commodity Futures Trading Commission, Three Lafayette
Centre, 1155 21st Street NW, Washington, DC 20581.
Hand Delivery/Courier: Same as Mail, above.
Please submit comments by only one of these methods.
All comments should be submitted in English or accompanied by an
English translation. Comments will be posted as received to https://www.cftc.gov. You should submit only information that you wish to make
available publicly. If you wish the Commission to consider information
that may be exempt from disclosure under the Freedom of Information Act
(``FOIA''), a petition for confidential treatment of the exempt
information may be submitted according to the procedures established in
the Commission's regulations at 17 CFR 145.9.\1\ The Commission
reserves the right, but shall have no obligation, to review, prescreen,
filter, redact, refuse, or remove any or all of your submission from
https://www.cftc.gov that it may deem to be inappropriate for
publication, such as obscene language. All submissions that have been
redacted or removed that contain comments on the merits of the RFI will
be retained in the public comment file and will be considered as
required under the Administrative Procedure Act and other applicable
laws, and may be accessible under the FOIA.
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\1\ 17 CFR 145.9. All Commission regulations cited herein are
set forth in chapter I of Title 17 of the Code of Federal
Regulations.
FOR FURTHER INFORMATION CONTACT: Daniel Gorfine, Director of LabCFTC
and Chief Innovation Officer, (202) 418-5625; Bianca M. Gomez, Counsel
on FinTech and Innovation, Office of General Counsel, (202) 418-5627;
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or LabCFTC@cftc.gov.
SUPPLEMENTARY INFORMATION:
I. Background
A. Introduction
The CEA grants the Commission regulatory authority over the
commodity futures markets.\2\ LabCFTC was launched by the Commission in
order to further the CFTC's goal of evolving as a 21st century
regulator and keeping pace with technological innovation. LabCFTC is
dedicated to facilitating market-enhancing financial technology
(``FinTech'') innovation, informing policy, and ensuring that we have
the regulatory and technological tools and understanding to keep pace
with changing markets. LabCFTC is designed to make the CFTC more
accessible to all innovators and to inform the Commission's
understanding of emerging technologies and their regulatory
implications. One such area of emerging innovation involves virtual
currencies.
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\2\ See, e.g., 7 U.S.C. 5(b).
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In further advancing its mission, LabCFTC published a primer on the
topic of virtual currencies in October 2017 (the ``Primer'') in order
to help educate the public on potential applications and use-cases, the
CFTC's role and jurisdictional oversight, and potential risks and
challenges that investors and users may face involving virtual
currencies.\3\
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\3\ ``A CFTC Primer on Virtual Currencies,'' (Oct. 17, 2017),
https://www.cftc.gov/sites/default/files/idc/groups/public/documents/file/labcftc_primercurrencies100417.pdf.
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In December 2017, the Chicago Mercantile Exchange Inc. (``CME'')
and the CBOE Futures Exchange (``CFE'') self-certified and began
offering new contracts for bitcoin futures products following
discussions with Commission staff regarding compliance with the CEA and
Commission rules and regulations. In line with Chairman Giancarlo's
repeated statements \4\ regarding the unique nature and risks of
virtual currency-related products, the CFTC's Division of Market
Oversight (``DMO'') and Division of Clearing and Risk (``DCR'') issued
on May 21, 2018 a joint staff advisory \5\ that gives exchanges and
clearinghouses registered with the CFTC guidance on certain
enhancements when listing a derivative contract based on virtual
currency pursuant to Commission regulations. The input being sought
here will better inform the Commission and its operating divisions as
the market evolves and potentially seeks to list new virtual currency
based futures and derivatives products.
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\4\ See, e.g., Testimony of Chairman J. Christopher Giancarlo
before the Senate Committee On Appropriations Subcommittee on
Financial Services and General Government (June 5, 2018), https://www.cftc.gov/PressRoom/SpeechesTestimony/opagiancarlo47.
\5\ CFTC Staff Advisory No. 18-14 (May 21, 2018), https://www.cftc.gov/sites/default/files/idc/groups/public/%40lrlettergeneral/documents/letter/2018-05/18-14_0.pdf.
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B. Bitcoin as a Virtual Currency
In its October 2017 Primer, LabCFTC cited the IRS to define a
virtual currency as ``a digital representation of value that functions
as a medium of exchange, a unit of account, and/or a store of value . .
. [but that] does not have legal tender status.'' \6\ The Primer
further noted key characteristics of Bitcoin, including that it:
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\6\ See Primer, supra note 3, at 4 (citing IRS Notice 2014-21,
available at https://www.irs.gov/businesses/small-businesses-self-employed/virtual-currencies). See also Proposed Interpretation on
Virtual Currency ``Actual Delivery'' in Retail Transactions (Dec.
15, 2017), 82 FR 60335 (Dec. 20, 2017), https://www.cftc.gov/sites/default/files/idc/groups/public/@lrfederalregister/documents/file/2017-27421a.pdf.
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[ssquf] Is ``pseudonymous'' (or partially anonymous) in that an
individual is identified by an alpha-numeric public key/address;
[ssquf] Relies on cryptography (and unique digital signatures) for
security based on public and private keys and complex mathematical
algorithms;
[ssquf] Runs on a decentralized peer-to-peer network of computers
and ``miners'' that operate on open-source software and do ``work'' to
validate and irrevocably log transactions on a permanent public
distributed ledger visible to the entire network;
[ssquf] Solves the lack of trust between participants who may be
strangers to each other on a public ledger through the transaction
validation work noted in the bullet above; and
[ssquf] Enables the transfer of ownership without the need for a
trusted, central intermediary.
The Primer noted potential applications or use cases of a virtual
currency like Bitcoin, including that it may serve as a store of value,
be used for trading, enable payments and value transfers, power
applications built upon the virtual currency network, and facilitate
money transfers or international remittances. The Primer further
highlighted a range of potential risks around virtual currencies,
including technology, operational, cybersecurity, speculative, and
fraud and manipulation risks.
C. Ether as a Virtual Currency
In June 2018, the Director of the Securities and Exchange
Commission's (``SEC'') Division of Corporation Finance, Bill Hinman,
delivered a speech which conveyed Mr. Hinman's personal views. In the
speech, he addressed the question of whether ``a digital asset that was
originally offered in a securities offering [could] ever be later sold
in a manner that does not constitute an offering of a security.'' He
explained among other factors that since the network on which Bitcoin
operates appears to be decentralized and there is no central third
party whose efforts are
[[Page 64565]]
a key determining factor in the success of Bitcoin, ``[a]pplying the
disclosure regime of the federal securities laws to the offer and
resale of Bitcoin would seem to add little value.'' He further stated
that, in addition to Bitcoin, ``based on my understanding of the
present state of Ether, the Ethereum network and its decentralized
structure, current offers and sales of Ether are not securities
transactions.'' Finally, he stated that ``[o]ver time, there may be
other sufficiently decentralized networks and systems where regulating
the tokens or coins that function on them as securities may not be
required.'' \7\
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\7\ ``Digital Asset Transactions: When Howey Met Gary
(Plastic),'' Remarks of William Hinman, Director, Division of
Corporation Finance, SEC at the Yahoo Finance All Markets Summit:
Crypto (June 14, 2018), https://www.sec.gov/news/speech/speech-hinman-061418.
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Ether is a virtual currency that was launched on the Ethereum
Network in 2015. It is an open network that currently relies on a proof
of work consensus mechanism, but developers, including through the
Ethereum Foundation, have plans to shift the protocol to a proof of
stake consensus model in order, at least in part, to reduce energy
consumption required to validate the ledger.\8\ The Ethereum Network is
often viewed as a platform that permits ready creation and use of smart
contracts that can power decentralized applications or organizations.
In this way, Ether is used as ``fuel'' to compensate miners for
maintaining a public ledger for such networks.\9\ To date, Ether has
typically been one of the top three virtual currencies by market
capitalization.
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\8\ See Ethereum Foundation, Frequently Asked Questions,
available at https://www.ethereum.org/ether (last visited Aug. 22,
2018).
\9\ See id.
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II. Request for Input
The Commission is seeking public feedback namely on Ether and the
Ethereum Network in order to better understand these technologies given
Ether's size in the market and potentially unique attributes relative
to Bitcoin. The Commission is issuing this RFI in order to gather
public feedback on a range of questions related to the underlying
technology, opportunities, risks, mechanics, use cases, and markets,
related to Ether and the Ethereum Network. The requested information
will inform the work of LabCFTC and the Commission as a whole. The
Commission welcomes any relevant comments, including related topics
that may not be specifically mentioned but which a commenter believes
should be considered.
Specific Questions for Input
In addition to any general input, the Commission is interested in
responses to the following questions:
Purpose and Functionality
1. What was the impetus for developing Ether and the Ethereum
Network, especially relative to Bitcoin?
2. What are the current functionalities and capabilities of Ether
and the Ethereum Network as compared to the functionalities and
capabilities of Bitcoin?
3. How is the developer community currently utilizing the Ethereum
Network? More specifically, what are prominent use cases or examples
that demonstrate the functionalities and capabilities of the Ethereum
Network?
4. Are there any existing or developing commercial enterprises that
are using Ether to power economic transactions? If so, how is Ether
recorded for accounting purposes in a comprehensive set of financial
statements?
5. What data sources, analyses, calculations, variables, or other
factors could be used to determine Ether's market size, liquidity,
trade volume, types of traders, ownership concentration, and/or
principal ways in which the Ethereum Network is currently being used by
market participants?
6. How many confirmations on the Ethereum blockchain are sufficient
to wait to ensure that the transaction will not end up on an invalid
block?
Technology
7. How is the technology underlying Ethereum similar to and
different from the technology underlying Bitcoin?
8. Does the Ethereum Network face scalability challenges? If so,
please describe such challenges and any potential solutions. What
analyses or data sources could be used to assess concerns regarding the
scalability of the underlying Ethereum Network, and in particular,
concerns about the network's ability to support the growth and adoption
of additional smart contracts?
9. Has a proof of stake consensus mechanism been tested or
validated at scale? If so, what lessons or insights can be learned from
the experience?
10. Relative to a proof of work consensus mechanism does proof of
stake have particular vulnerabilities, challenges, or features that
make it prone to manipulation? In responding consider, for example,
that under a proof of stake consensus mechanism, the chance of
validating a block may be proportional to staked wealth.
11. There are reports of disagreements within the Ether community
over the proposed transition to a proof of stake consensus model. Could
this transition from a proof of work to a proof of stake verification
process result in a fragmented or diminished Ether market if the
disagreements are not resolved?
12. What capability does the Ethereum Network have to support the
continued development and increasing use of smart contracts?
Governance
13. How is the governance of the Ethereum Network similar to and
different from the governance of the Bitcoin network?
14. In light of Ether's origins as an outgrowth from the Ethereum
Classic blockchain, are there potential issues that could make Ether's
underlying blockchain vulnerable to future hard forks or splintering?
Markets, Oversight and Regulation
15. Are there protections or impediments that would prevent market
participants or other actors from intentionally disrupting the normal
function of the Ethereum Network in an attempt to distort or disrupt
the Ether market?
16. What impediments or risks exist to the reliable conversion of
Ether to legal tender? How do these impediments or risks impact
regulatory considerations for Commission registrants with respect to
participating in any transactions in Ether, including the ability to
obtain or demonstrate possession or control or otherwise hold Ether as
collateral or on behalf of customers?
17. How would the introduction of derivative contracts on Ether
potentially change or modify the incentive structures that underlie a
proof of stake consensus model?
18. Given the evolving nature of the Ether cash markets underlying
potential Ether derivative contracts, what are the commercial risk
management needs for a derivative contract on Ether?
19. Please list any potential impacts on Ether and the Ethereum
Network that may arise from the listing or trading of derivative
contracts on Ether.
20. Are there any types of trader or intermediary conduct that has
occurred in the international Ether derivative markets that raise
market risks or challenges and should be monitored closely by trading
venues or regulators?
21. What other factors could impact the Commission's ability to
properly oversee or monitor trading in derivative
[[Page 64566]]
contracts on Ether as well as the underlying Ether cash markets?
22. Are there any emerging best practices for monitoring the
Ethereum Network and public blockchains more broadly?
Cyber Security and Custody
23. Are there security issues peculiar to the Ethereum Network or
Ethereum-supported smart contracts that need to be addressed?
24. Are there any best practices for the construction and security
of Ethereum wallets, including, but not limited to, the number of keys
required to sign a transaction and how access to the keys should be
segregated?
25. Are there any best practices for conducting an independent
audit of Ether deposits?
In providing your responses, please be as specific as possible, and
offer concrete examples where appropriate. Please provide any relevant
data to support your answers where appropriate. The Commission
encourages all relevant comments on related items or issues; commenters
need not address every question.
III. Conclusion
The Commission appreciates your time and effort responding to this
RFI on Crypto-asset Mechanics and Markets. The information provided by
stakeholders will help us refine our understanding of this area of
innovation and better inform the work of the Commission, including the
evaluation of potential derivatives contracts. More broadly, the input
from this request will further aid the Commission in identifying
FinTech trends and related opportunities, challenges, and risks. In
that respect, we look forward to continuing to engage proactively with
the innovator community and market participants in order to help
facilitate market-enhancing innovation and ensure market integrity.
Issued in Washington, DC, on December 11, 2018, by the
Commission.
Christopher Kirkpatrick,
Secretary of the Commission.
Appendix to Request for Input on Crypto-asset Mechanics and Markets--
Commission Voting Summary
On this matter, Chairman Giancarlo and Commissioners Quintenz,
Behnam, Stump, and Berkovitz voted in the affirmative. No
Commissioner voted in the negative.
[FR Doc. 2018-27167 Filed 12-14-18; 8:45 am]
BILLING CODE 6351-01-P