FALSE: Our bill increased the regulatory burden on dealers.
In fact, our bill substantially reduced the regulatory burden by limiting or eliminating certain requirements of the MBCDL. For example, we eliminated background check and registration requirements for employees who deal with customers solely for administrative purposes and salespeople who deal exclusively with customers outside of Minnesota. We also eliminated the requirement to routinely file background checks with the regulator.
FALSE: Our bill expands the list of products covered by the law, which increases the number of dealers subject to the law.
In fact, the Department of Commerce had determined that the MBCDL already covered these products (i.e., bars, rounds, and ingots, and platinum products). Specifying these products in our bill was simply a clarification, not a change in how the law is enforced.
FALSE: Our bill reduces the number of small dealers who qualify under the coin show exemption.
In fact, we expanded the exemption. The MBCDL exempted dealers who conduct transactions at “occasional” coin shows. No one knew what “occasional” meant, so many dealers, especially out-of-state dealers, stopped attending Minnesota shows. At various times regulators said “occasional” meant two, three, or as many as six shows. Our bill removed this uncertainty and expanded the exemption by raising the number of exempted shows to 12 per year and excluding out-of-state shows from the 12-show count.
Our bill is not perfect, but it’s a vast improvement over the MBCDL. We’ve developed a good working relationship with Minnesota regulators, who now have a better understanding of our business and know that the vast majority of us are reputable business people. This will benefit dealers who make good-faith efforts to comply with the Minnesota law.
ICTA invested more than $160,000 in passing this legislation. Many dealers who benefit have not yet contributed to this effort.
I urge you to do so now and to become a member of ICTA.
Philip Diehl is vice chairman of the Industry Council for Tangible Assets. He is a former director of the United States Mint and chief of staff of the U.S. Treasury.