From: Robert Brueggeman

To: All PNG Member-Dealers

June 19, 2014

RE: Operation Choke Point

There is a U.S. Justice Department initiative that has the potential to shut down every coin dealer — PNG member and non-PNG member alike — in the United States as well as curtail business by overseas dealers who use US-based banks. Read that again: the potential to shut down every coin dealer.

The threat is real, and this urgent email is sent to make sure every PNG member is aware of this profession-killing peril, and to encourage members to promptly take appropriate action.

The coin market menace is called “Operation Choke Point” and it literally has the potential to choke your business to death by pressuring banks and other financial institutions to close your accounts. Why?  Because, according to the Justice Department, you are engaged in a business with a high risk for fraud.

A May 29, 2014 report by the U.S. House Committee on Oversight and Government Reform stated: “Operation Choke Point has forced banks to terminate relationships with a wide variety of entirely lawful and legitimate merchants….  Acting in coordination with Operation Choke Point, bank regulators labeled a wide range of lawful merchants as high-risk including coin dealers….”

The concept of innocent until proven guilty apparently no longer applies to professional numismatists.  The Federal Deposit Insurance Corporation (FIDC) now includes coin dealers in the same risk category as ammunition sales, drug paraphernalia, credit card repair services, debt consolidation scams, escort services, online gambling, payday loan companies, Ponzi schemes and pornography.

Coin dealers are specifically mentioned on pages 1 and 8 of the House Committees report, and you can read the full report here: http://oversight.house.gov/wp-content/uploads/2014/05/Staff-Report-Operation-Choke-Point1.pdf

So, what can you do?  First, support the recently-launched efforts by the Industry Council For Tangible Assets (https://owa.kuenker.de/owa/redir.aspx?C=7zkLxXenDUiG0rFxmJK8hFMEMaDfX9EIR_uWAVTcp_LQuJ-nnJmCen_CD-AmTr0XEOevKtAuCN4.&URL=http%3a%2f%2fwww.ictaonline.org%2f) and the Gold & Silver Political Action Committee (http://www.goldandsilverpac.com) to oppose the unreasonable and unfair actions by the Justice Department.  ICTA and G&SPAC are on the front lines of fighting for legislative matters on behalf of professional numismatists.

Second, personally contact your local member of the United States House of Representatives and your state two U.S. Senators to strongly urge them to vigorously oppose the frightening, sweeping generalizations of Operation Choke Hold as outlined in the eye-opening May 29 report of the House Committee on Oversight and Government Reform.  (There are 40 members on that committee; perhaps your local Congressman/Congresswoman is one of them. Here's a list of members: http://oversight.house.gov/subcommittee/full-committee)

Earlier this month, a trade organization representing payday loan businesses filed a federal lawsuit (https://owa.kuenker.de/owa/redir.aspx?C=7zkLxXenDUiG0rFxmJK8hFMEMaDfX9EIR_uWAVTcp_LQuJ-nnJmCen_CD-AmTr0XEOevKtAuCN4.&URL=http%3a%2f%2fcfsaa.com%2fPortals%2f0%2flegal%2flawsuit%2fcfsa_complaint.pdf) against the FDIC, the Federal Reserve System Board and the Office of the Comptroller of the Currency. PNG’s Legal Counsel Armen Vartian will be following the progress of that complaint and PNG may file a friend of the court brief.

If you think your business has been harmed by bank actions arising from Operation Choke Hold, please contact me immediately.

Robert Brueggemann