bradwheeler
commented
10 years ago From 200.2(m)
Virtual Currency shall be broadly construed to include digital units of exchange that (i) have a centralized repository or administrator;
Is there a rigorous or generally recognized definition of "centralized administrator" in similar contexts? Would this clause include the code released by an author who set key parameters at program creation?
(ii) are decentralized and have no centralized repository or administrator; or
"Centralized Repository" in such a context would be a repository of digital units. This does not make sense using internet protocol, as data are instructions to adjust local copies of consensus ledger in a decentralized system.
(iii) may be created or obtained by computing or manufacturing effort.
This is broad language and should be more specific. It seems to cover proof of work systems. However "computing effort" is somewhat open to interpretation and might cover any packet of data addressed/allocated/transmitted over a network.
Virtual Currency shall not be construed to include digital units that are used solely within online gaming platforms with no market
Does this by implication require non-licensees to police potential marketmaking activities and schemes with their "exempted" virtual currencies?
or application outside of those gaming platforms, nor shall Virtual Currency be construed to include digital units that are used exclusively as part of a customer affinity or rewards program, and can be applied solely as payment for purchases with the issuer and/or other designated merchants, but cannot be converted into, or redeemed for, Fiat Currency;.
My Coke Rewards is a good example of a rewards program that would not be a "virtual currency" yet some of the items redeemed for the points can then be converted to fiat via a secondary marketplace like eBay.
Definition of "virtual currency" includes non-monetary uses of crypto-currency units of account. Should be narrowly tailored to monetary uses.