The Clearing House Association joint comment letter with ICBA provides comments to the New York Department of Financial Services on its proposed “BitLicense Regulations” for virtual currency businesses. In the letter the Associations support the establishment of comprehensive regulations to ensure that virtual currency products and services are subject to oversight comparable to those applicable to traditional, functionally similar payments system and products offered by regulated banking entities. However, the Associations believe that the BitLicense Regulations should focus on those entities and activities that pose consumer and prudential risks due to the absence of comprehensive regulation and supervision. Traditional banking entities already are subject to extensive prudential requirements, and applying the prudential requirements of the proposed BitLicense Regulations to these entities would add duplicative regulatory burdens with no additional benefits to the public.