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The New York State Department of Financial Services ("NYDFS") granted a virtual currency and money transmission license to a subsidiary of the New York Digital Investment Group ("NYDIG"). The authorization permits NYDIG to offer trade execution and related custody services in virtual currencies, including Bitcoin, Bitcoin Cash, Ether, XRP and Litecoin.

The Federal Reserve Board ("FRB") is considering upgrading the U.S. payment system to provide payment-by-payment interbank settlements in real time ( i.e., real-time gross settlement or "RTGS"). The request for comments was published in the Federal Register. Comments on the FRB's potential actions must be submitted by December 14, 2018. As previously covered, the FRB is requesting comments on (i) the adoption of an RTGS settlement service, which would enable settlement on a 24/7/365 basis, and (ii) whether the FRB or the private sector should provide a liquidity management tool in support of

SIFMA recommended clarifications of proposed guidance in relation to (i) the posting of bids-wanted on trading platforms and (ii) "pennying." ( See generally MSRB Requests Comment on Agency Execution Procedures.) In comments submitted to the MSRB, SIFMA called for clearer definitions and guidance. SIFMA said that "pennying" should be defined as the "persistent or pattern of internalization of orders for which the dealer internalized at prices that are only nominally better than the cover bids." SIFMA said "nominal" should be defined and determined by a "facts and circumstances analysis." SIFMA

Christian Larson Commentary by Christian Larson

The Financial Crimes Enforcement Network ("FinCEN") reissued a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases. The reissued GTO applies when a legal entity purchases residential real estate in specified areas, the purchase price is $300,000 or more, and the transaction does not involve a bank loan or similar external financing. Previously, the purchase amount threshold varied by city. The new GTO adds Boston, Chicago, and Las Vegas to the list of specified areas, which also includes