NYDFS Releases Revised BitLicense Proposal

On February 4, 2015, the New York State Department of Financial Services ("NYDFS") released a revised version of its proposed virtual currency regulations (commonly referred to as "BitLicense"), originally released in July 2014. Nearly 4,000 formal comment letters were submitted by advocacy groups, financial service providers, law firms, individuals and others on the original proposal.  A 30-day public comment period began upon publication of the revised proposal in the New York State Register on February 25, 2015.  Section I below summarizes significant changes that the revised version of the BitLicense proposal made to the original, and Section II provides an outline of the overall proposed BitLicense regime, as amended.