On 1/15/2021, FinCEN issued a “Notice of Proposed Rulemaking; Reopening of Comment Period” to allow more time for comments to be received from their December 23, 2020 Notice of Proposed Rulemaking which requested feedback for potential new rules on certain transactions involving convertible virtual currency or digital assets with legal tender status. The comment period is reopened for 15 days for comments on the proposed reporting requirements and for 45 days for comments on the proposed requirements to report counterparty information and the proposed recordkeeping requirements. Written comments are now therefore due with respect to the proposed reporting requirements (except with respect to reporting of counterparty information) on February 1, 2021, and with respect to all other aspects of the proposed rule on March 1, 2021.
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