The Clearing House Association, joined by the Independent Community Bankers of America (ICBA), submitted a letter to the Conference of State Bank Supervisors regarding the draft model regulatory framework for virtual currency activities. The Associations agree that there is a need for CSBS to provide regulatory guidance in the virtual currency space to ensure that consumer and prudential protections are a priority. However, there should be certain clarifications and additions to the Model Framework where appropriate, including the guarantee that regulated banking entities are not subjected to the burden of unnecessary and duplicative regulation as virtual currency businesses.