Madam Superintendent Harris:

xNY.io - Bank.org is concerned NYDFS is ignoring sound betting application
regulation visavie regulator arbitrage between NYDFS and the NYSGC.

*New York betting app regulation and the New York State of Department of
Financial Services:*

*In New York, the primary regulatory body for legal betting apps
(specifically sports wagering and interactive fantasy sports) is the New
York State Gaming Commission (NYSGC). The DFS (Department of Financial
Services) in New York primarily regulates virtual currency businesses and
financial services, not online betting directly.*

   -  xNY.io - Bank.org (working under an abundance of caution and
   plausible deniability) asks you to kindly recuse yourself from
   'third-party' regulation of "betting applications" in New York State.
   - Madam Superintendent, while you are not the direct regulator of
   betting apps in New York State, xNY.io - Bank.org is concerned third party
   matters would not hamper your direct recusal.

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*Crypto’s Most Powerful Regulator Is Here Adrienne Harris, New York’s
financial watchdog, has enormous sway over the industry’s future:*

*Thirteen years after the birth of cryptocurrency, it was supposed to be
time for Washington to rein it in. Instead, the White House punted, and the
Securities and Exchange Commission is still hashing out how it’s going to
oversee the $2 trillion industry. State watchdogs have filled that vacuum,
making Adrienne Harris, the head of the New York State Department of
Financial Services, by default the most powerful crypto regulator in the
country.*

   -
   
https://nymag.com/intelligencer/2022/03/adrienne-harris-is-cryptos-most-powerful-regulator.html

The article goes on to say:

*"It seems Harris did well enough. One real-estate tech company at which
she worked went public last summer, and Harris appears to have cashed out.
Since the disclosures were for 2020, they didn’t include her stake in
Forethought, a private A.I.-based customer-service company that announced
in December that it had attracted such investors as Harris, Ashton Kutcher,
and Gwenyth Paltrow. When I asked her about Forethought, Harris said her
investment in the company predated her time at DFS, that all her
investments are now in a blind trust, and that she would recuse herself
from any dealings with companies she has conflicts with."*

-----(PAGE BREAK)-----

Can NYDFS confirm xNY.io - Bank.org's betting application recusal request
by August 20, 2025 by Noon EST?​

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson
--
*Gunnar Donald Arthur Peter Larson *
*xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>*

MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
-
Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
- Entrepreneurship
and Innovation (ip)

[email protected]
+1-917-580-8053
New York, New York 10001

On Mon, Aug 11, 2025, 6:36 PM Gunnar Larson <[email protected]> wrote:

> Dear Superintendent Adrienne Harris:
>
> This August 11, 2025, xNY.io - Bank.org (working under an abundance of
> caution and plausible deniability) asks you to kindly recuse yourself from
> 'third-party' regulation of "betting applications" in New York State.
>
> Madam Superintendent, while you are not the direct regulator of betting
> apps in New York State, xNY.io - Bank.org is concerned there are third
> party matters that would not hamper your direct recusal if there is no
> wrong doing.
>
> *New York betting app regulation and the New York State of Department of
> Financial Services:*
>
> *In New York, the primary regulatory body for legal betting apps
> (specifically sports wagering and interactive fantasy sports) is the New
> York State Gaming Commission (NYSGC). The DFS (Department of Financial
> Services) in New York primarily regulates virtual currency businesses and
> financial services, not online betting directly.*
>
>    - On March 30, 2022, New York Magazine profiled you and recusals.
>    - Can NYDFS confirm xNY.io - Bank.org's betting application recusal
>    request by August 15, 2025 by Noon EST?​
>
> *Crypto’s Most Powerful Regulator Is Here Adrienne Harris, New York’s
> financial watchdog, has enormous sway over the industry’s future:*
>
> *Thirteen years after the birth of cryptocurrency, it was supposed to be
> time for Washington to rein it in. Instead, the White House punted, and the
> Securities and Exchange Commission is still hashing out how it’s going to
> oversee the $2 trillion industry. State watchdogs have filled that vacuum,
> making Adrienne Harris, the head of the New York State Department of
> Financial Services, by default the most powerful crypto regulator in the
> country.*
>
>    -
>    
> https://nymag.com/intelligencer/2022/03/adrienne-harris-is-cryptos-most-powerful-regulator.html
>
> The article goes on to say:
>
> *"It seems Harris did well enough. One real-estate tech company at which
> she worked went public last summer, and Harris appears to have cashed out.
> Since the disclosures were for 2020, they didn’t include her stake in
> Forethought, a private A.I.-based customer-service company that announced
> in December that it had attracted such investors as Harris, Ashton Kutcher,
> and Gwenyth Paltrow. When I asked her about Forethought, Harris said her
> investment in the company predated her time at DFS, that all her
> investments are now in a blind trust, and that she would recuse herself
> from any dealings with companies she has conflicts with."*
>
> -----(PAGE BREAK)-----
>
>    - *Madam Superintendent, xNY.io - Bank.org is concerned you are aware
>    of the illicit finances of New York betting applications. These potential
>    illicit finances have impacted xNY.io - Bank.org with professional sports
>    teams.*
>    - Madam Superintendent, speaking on Bloomberg during an October 23,
>    2024 interview, you discuss market manipulation and illicit finance.
>    - Madam Superintendent, during the tail end of your interview with
>    Bloomberg, you discuss regulation of livery insurers.
>
> *NY Dept of Financial Services Superintendent Adrienne Harris | Bloomberg
> Talks:*
>
> *New York Department of Financial Services Superintendent Adrienne Harris
> speaks from the DC Fintech Week conference in Washington with hosts Sonali
> Basak and Tim Stenovec.*
>
>    - https://youtu.be/S7LZuIW7Q-4?si=GrgV5p169u71H4KP
>
> Judge Says Insurer Must Face $100M Biz Interruption Claim
> <https://www.law360.com/insurance/articles/2374797?nl_pk=347c5954-47a8-495c-bfa1-d8ec8f6144fe&utm_source=newsletter&utm_medium=email&utm_campaign=insurance&utm_content=2025-08-11&read_main=1&nlsidx=0&nlaidx=0>
>
> By Ganesh Setty
>
> A chemicals manufacturer accusing a reinsurer of failing to fully cover
> its roughly $100 million business interruption claim over a chemical plant
> explosion can still pursue its coverage claims, a Texas federal court
> ruled, finding the Texas Supreme Court would likely adopt the same holding.
>
>  Order attached | Read full article »
> <https://www.law360.com/insurance/articles/2374797?nl_pk=347c5954-47a8-495c-bfa1-d8ec8f6144fe&utm_source=newsletter&utm_medium=email&utm_campaign=insurance&utm_content=2025-08-11&read_more=1&nlsidx=0&nlaidx=0>
>  | Save to favorites »
> <https://www.law360.com/insurance/articles/2374797?nl_pk=347c5954-47a8-495c-bfa1-d8ec8f6144fe&utm_source=newsletter&utm_medium=email&utm_campaign=insurance&utm_content=2025-08-11&read_later=1&nlsidx=0&nlaidx=0>
> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>
> Thank you,
>
> Gunnar Larson
> --
> *Gunnar Donald Arthur Peter Larson *
> *xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
>  -
> Digital Currency
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
>  - Entrepreneurship
> and Innovation (ip)
>
> [email protected]
> +1-917-580-8053
> New York, New York 10001
>

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