Mr. Weber:

Thank you for fielding recent correspondence to your office. 

Over the last year, xNY.io has been reviewing NY-DFS' proposed model framework for the creation by a VC Entity of a coin-listing.

xNY.io understands that we may seek to earn "one off approval" for specific usages, such as issuing a NY-DFS Greenlisted "xNY" coin privately.  Furthermore, we seek guidance on issuing NY-DFS (aka State of New York) a SAFT equation to 30% of xNY's maximum supply.  

1. DFS may, in its discretion, add to the Greenlist coins that have been specifically reviewed and approved by DFS for creation and issuance by a VC Entity privately and in a centralized manner.
2. After Step 1 is complete, DFS will announce this on its website. DFS will also note that there will be a six-month waiting period (the “Greenlist Waiting Period”) from the date of such announcement until such time that other VC Entities that have not previously received approval can use the coin (subject to all regulatory, internal approval, and safety and soundness requirements).
3. If, during the Greenlist Waiting Period, a VC Entity delists or stops using the coin under consideration for such Greenlisting, DFS may decide whether or not to continue with the Greenlist Waiting Period based on any information it considers relevant.

DFS may, at any time and in its sole discretion, prohibit or otherwise limit a coin’s use before or after a VC Entity begins using a coin; require that any VC Entity delist, halt, or otherwise limit or curtail activity with respect to any coin; remove any coin from the Greenlist; refrain from placing any coin on the Greenlist; or discontinue the Greenlist process entirely.

Mr. Weber, we see xNY Greenlising (and waiting period) along with SAFT proposal a prime approach to our previous "supervisory letter" memos to NY-DFS. We feel this approach protects xNY.io's legacy interest given the current and/or future virtual currency environment in New York State.  

Please let us know what your office thinks of this innovation concept generally and if we may work with the VC team on a formal proposal submission. 

Sending you the very best regards. 

Thank you, 

Gunnar 
--

Gunnar Larson - xNY.io | Bank.org

MSc - Digital Currency 

MBA - Entrepreneurship and Innovation (ip)

G@xNY.io

+1-646-454-9107

New York, New York 10001