Quote from: HELP.org on June 09, 2013, 06:06:47 PM

Quote from: MSantori on June 09, 2013, 03:34:24 PM

To ACB: Are you working with a local attorney? I think it's great that you are trying to influence the rulemaking process. It's civic participation at its finest; you are rocking the boat, and that's the only way change is made in this country. That said, it looks to me like you are flying solo. Most people who do this don't fly solo. They do it with legal counsel. Without a knowledgeable lawyer at your side, you risk rocking the boat in the wrong direction. As a bitcoiner myself, that concerns me.

In sum, you seem to be lobbying to affect the regulation of an entire industry without someone who knows how the regulations truly work. There must be a local attorney that you can work with in New Jersey that can guide you through this process, help you focus your communications, and aid you in representing the industry in a more effective manner.

I recommended in my original post that if you have a high-stakes issue then definitely get an attorney familiar with Money Services Business/FinCEN issues. In my case it is not high enough stakes to get an attorney. They issued a clarification about mining. I contacted them to explain it informally and they directed me to the formal process so I filed it. I don't claim to represent any industry and I only asked about stuff that involves me (mining and the effect of FinCEN activities on the Bitcoin exchange price). If some else wants to get involved in the issue they are free to send in their own comments, etc. If I am granted a conference and someone else wants to take part and attend I won't object to that. Actually there are other people who would be better at this than me so maybe it will spur others to get involved but without a central authority I am not sure who would do this sort of thing.

I know Bitinstant spent a lot on legal fees and they had posted awhile back that they would share information. I would think that some sort of collaborative approach to reduce legal fees would be the way to go. To do this properly you need someone familiar with FinCEN staff and how they approach things as well as the rules, administrative decisions, and court cases. You would probably need a 6-figure retainer to a DC law firm just to get started.

It's a tough spot, I know. A six-figure retainer is probably overstating it a bit, but you're right: regulatory attorneys aren't cheap. The Bitcoin industry needs a well-funded industry group that can engage the proper legal counsel so that competing individual interests don't sink the whole ship. In any event, good luck!