The adoption of any regulation is just a hypothesis that the regulation will make the world a better place, just as the start of a new business is a hypothesis that the business will make money. Lots of businesses fail, either right away, or over time as circumstances change. Likewise, not every rule is a success. They should be re-evaluated. This rule seems to be an example of a failed hypothesis. 

In its report, the Working Group builds on the core themes of the President's : the overarching goal is to achieve US leadership in technology (and, in this case, in payments).

One of the important "intellectual" leaps that the PWG makes is the recognition that cryptocurrencies are a new asset class, or at least a new product or technology. (Asset class may be too broad a term.) The prior Administration, and particularly the SEC, was limited in its thinking about digital assets…

An egregious failing in SEC rulemaking under the previous administration is the consistently flawed analysis on the costs of proposed rules. Beyond its conclusion that the rulemaking in this case exceeded the SEC's statutory authority, the 11th Circuit Opinion found that "the annual cost of operating the [CAT] system going forward appears likely to exceed the Commission's 2016 estimate by nearly four times."

A main concept underlying the Administrative Procedure Act is that…

A comparison between "America's AI Action Plan," which follows President Trump's EO "Removing Barriers to American Leadership in Artificial Intelligence," and President Biden's EO "Safe, Secure and Trustworthy Development and Use of Artificial Intelligence," (see previous ), illustrates the enormous difference between the mindsets of the two Presidents.

President focuses on "substantial risks," including concerns about "fraud, discrimination, bias, and disinformation; [the…