Super interesting read if you're into Bitcoin or other cryptocurrencies (or retail banking regulation). I fully support Square's position but I think their mother/daughter gifting analogy is a little shaky.

For example, under this Proposal — if a Square customer’s mother gifts her daughter $4,000 in physical cash and the daughter deposits those funds in a bank, the bank would have no obligation to collect information on the customer’s mother. Under the Proposal, if this same transaction were completed in cryptocurrency, the bank would have to reach beyond its customer relationship and intrude upon the mother’s private information in order for the daughter to successfully deposit and freely access her gift.

If Square is acting as the custodian of the daughter's cryptocurrency wallet, wouldn't a closer analogy have the mother attempting to go to the daughter's bank and anonymously deposit the $4,000 into her daughter's account? I'm pretty sure that wouldn't fly.