Ordinarily, when a regulator states that it intends to "modernize" rules, that means it intends to adopt more (and more burdensome) rules. Under the new administration, it is reasonable to expect that FINRA will consider where burdens might be reduced without depriving investors of reasonable protections. 

At least in one respect, the MFA's comments do not go far enough. Form PF is an utterly useless document and should be jettisoned. It requires detailed and complex information about an area as to which the regulators are largely uninformed, and mandating the collection of tremendous amounts of largely useless data at significant cost to market participants. (See, e.g. )

The establishment of the Crypto Reserve is among the most trivial of issues. The Executive Order does not authorize the US Government to buy bitcoin. Essentially all it says is that, to the extent that the Government comes into possession of bitcoin, as a result of criminal enforcement activities, the holding of those assets should be centralized and the sale should be conducted in a way to maximize the return to the Government.

This Executive Order is less significant than it appears. As a matter of substance, all it says is that to the extent that the United States Government obtains Bitcoin as a result of bringing enforcement actions, it should have a considered policy as to whether to maintain or dispose of the Bitcoin, and how to dispose of them. In other words, if the Government comes into a big pile of Bitcoin in an enforcement action, it shouldn't dump them all at once and crash the market.