What happened. On October 1 the New York State Department of Financial Services (DFS) and the Wyoming Division of Banking announced a memorandum of understanding to coordinate oversight of entities engaged in virtual currency and digital asset activities in both states. DFS Acting Superintendent Kaitlin Asrow and Wyoming Banking Commissioner Jeremiah Bishop announced it.
The licensing and chartering provisions cover entities already licensed or chartered in one state, and entities applying in both states at the same time. The regulators will share analysis, subject matter reviews and historical examination data to simplify the application process. For supervision, they will coordinate examination schedules and work toward joint examinations of entities that operate in both states. The MOU also sets protocols for sharing supervisory reports, market trend data and notifications about potential enforcement actions.
“Interstate collaboration is essential for the virtual currency space,” said Asrow. “This MOU will add to the resources and information available to each regulator, helping to facilitate responsible innovation in the market while protecting consumers across our respective jurisdictions.”
Why it matters. DFS says it set up the nation’s first comprehensive virtual currency regulatory framework, the BitLicense, in 2015. The two agencies now have a formal channel for firms that sit under both. The release does not name any firm or say how many firms are affected.
Our read. This section is our analysis. For a company holding authorizations in both states, the practical test is whether duplicated information requests fall. Joint examinations are described as a goal (“work toward”), so the benefit depends on how often the two agencies actually schedule them together. Compliance teams at firms with licenses in both states should ask each regulator how the MOU will change exam timing and document requests. The broader pattern of rule-writing agency by agency is covered in our piece on stablecoin regulation filling in agency by agency, and our report on US and UK regulators writing crypto rules around custody follows the same theme across borders.
