2024 Q3
Tuesday, October 1, 2024
Section: 2024




Association News

2025 Membership Renewal Now Open

The 2025 memberships are open for renewal as of October 1, 2024. If you are a Concerned Collectors Coalition member, your membership will automatically renew on January 1, 2025.

For paid members, your current membership will expire December 31, 2024.

New! We now offer an automatic option for hassle-free membership renewal. Learn more about this convenient feature here and sign up when you renew this year. Click here to renew your membership online. Alternatively, you can send your invoice and payment by mail to

National Coin & Bullion Association
PO Box 237
Dacula, GA 30019

Renew before November 1, 2024, for a chance to win a complimentary membership renewal for 2026. The winner will be announced in an upcoming newsletter. Congratulations to Andrew Reiber of A.R.I., Merrillville, Indiana, last year’s winner of a free membership renewal for 2025!

Explore your membership benefits and consider upgrading to a higher tier. Learn more at Membership Benefits.

Renew Your Membership Now: Renew Membership.

The National Coin & Bullion Association is grateful for your support.


Welcome New Members

(And thank you, referrers!)

The following joined NCBA between July 1 and September 30, 2024:

Copper
  • Douglas Ryder, B & J Coins (VA)
  • Louis Ginsburg, Glines & Rhodes (MA)
Basic
  • Nancy Metropoulos, Americana Coin Exchange (NJ)
  • Maria Armijos, Ameritrust Gold and Metals Group (FL)
  • MERINNA MAY-WESELY, Calaveras Coins (CA)
  • Ron Jorgensen, Houston Gold & Silver (TX)
  • LANCE SCHOENBERGER, River Valley Gold & Silver (MN)
  • Jon Felz, RZM Fine Arts & Antiques (NY)
Concerned Collectors Coalition
  • Shimon Nussbaum (NY)


Message from executive director David Crenshaw

As we approach the end of the year, we want to extend our sincere gratitude for your unwavering support as a member of the National Coin & Bullion Association (NCBA). Your involvement has been crucial in advancing our mission to support the numismatic community and has made a significant impact.

The 2025 membership renewal period has officially begun, and we are excited to offer a new, convenient feature: auto-renewal! This hassle-free option ensures that your membership remains active without the need for manual renewals each year. Sign up for this feature when you renew this fall, and never have to worry about renewing again. To learn more about this feature and how it can simplify your renewal process, click here

Your membership dues are vital to our continued success and support NCBA’s initiatives:
  • Advocacy—We are actively engaged in maintaining sales-tax exemptions in 45 states, while also advocating against regulations that could hinder the growth of our industry.
  • Legislative Vigilance—Our dedicated team closely monitors legislative developments related to coins, currency, and precious metals at all levels of government.
  • Community Unity—We bring dealers and collectors together to address legal challenges that impact our hobby, exemplified by our involvement in the SCOTUS South Dakota v. Wayfair decision.
In addition to these crucial activities, your membership offers a range of benefits:
  • Educational Resources—Gain access to exclusive quarterly newsletters and members-only white papers and seminar videos offering valuable industry insights.
  • Cost Savings—Enjoy discounts on information kits from NCBA and other deals with esteemed partner associations and businesses, including ANACS, ICG, NGC, PCGS, and CAC Grading.
  • Enhanced Visibility—Showcase your affiliation through event signage, advertisements, and priority listings in our membership directory, fostering connections within the numismatic community.
We encourage you to renew your membership for another year to continue enjoying these benefits and support our ongoing efforts. The renewal process is simple; just follow this link to settle your invoice: Renew Membership

As an added incentive, members who renew by November 1, 2024, will be entered into a drawing to win a complimentary membership renewal for 2026. The winner will be announced in an upcoming newsletter.

Thank you once again for your dedication and support. We look forward to another year of collaboration and success with you.
 

Message from chair Patrick I. Perez

As 2024 continues to fly by, NCBA has seen a steady stream of wins. Most recently, the state of New Jersey enacted a sales-tax exemption on investment coins and bullion, effective January 1, 2025. This victory is the result of significant efforts by NCBA and the local coalition, who worked tirelessly to push this legislation across the finish line. Now, it’s up to all of our members to spread the word and emphasize the importance of the work NCBA is doing. If you’re a New Jersey resident, please share information about this new law with every collector you know. This is also an excellent opportunity to help grow the ranks of our Concerned Collectors Coalition, which is completely free to join and provides a great way for individuals to become more engaged with the association and more aware of local policy issues that affect them. Encourage your friends and clients to join with us as Concerned Collectors Coalition members.

On the topic of engagement, our renewal period for the coming year is upon us. We’ve had strong renewal rates over the past two years, which is a testament to you—our members—and your commitment to our mission. This support has placed us in a healthy financial position, but we won’t rest on past successes. Please remember to submit your renewals early and encourage any colleagues who aren’t yet members to join NCBA. As always, thank you for your continued support!
 

Welcome Aboard, Gary Knaus (Knaus & Associates)!

We are excited to welcome Gary Knaus as the newest member of our volunteer staff! His exceptional service and expertise, particularly in Federal Anti-Money Laundering Regulations and broker/cash reporting, have been invaluable to our association over the years. Gary’s insightful columns in our quarterly newsletter, his seminars at coin shows, and his steadfast support in answering member questions have helped keep us informed and AML-compliant. You can see some of his work for NCBA in the recent white papers clarifying IRS reporting requirements for precious-metals dealers, which have proven to be an essential resource for our community.

We are thrilled to officially recognize Gary’s contributions. Visit Our Staff to learn more about him and his work!
 

NCBA Honors Outstanding Members at Annual Awards Ceremony

On August 7, 2024, the National Coin & Bullion Association (NCBA) held its annual Membership Dinner and Update at Gibsons Steakhouse in Rosemont, Illinois, coinciding with the American Numismatic Association’s World’s Fair of Money. The event celebrated the achievements of several distinguished members who have made significant contributions to the numismatic community and legislative efforts.

Gary Knaus of Knaus & Associates received the 2024 Outstanding Service Award for his exceptional volunteer work, particularly in federal anti-money laundering regulations. His guidance through compliance issues has been invaluable.

The ceremony also honored Wisconsin’s success in passing Assembly Bill 29, which exempts precious-metal bullion from sales and use tax. Andy Kimmel, Michelle Voecks-Griesbach, Mark Ferguson, Clifford Mishler, and Patrick Heller were recognized for their roles in this legislative victory, with Heller receiving the Diane Piret Memorial Outstanding Service Award.

In Kentucky, the enactment of a sales-tax exemption on currency and bullion, effective August 1, was highlighted. Byrd Saylor III, Jeff Garrett, Jonathan Kern, Eddie Bruner, and Patrick Heller were celebrated for their advocacy, with Saylor receiving the Diane Piret Memorial Outstanding Service Award.

These awards reflect the collective perseverance and dedication of NCBA members in advancing the numismatic industry. For more details on the awards and the achievements celebrated, read the full story here.
 

NCBA Scholarship Recipients Reflect on Their 2024 ANA Summer Seminar Experiences

At the beginning of the year the National Coin & Bullion Association (NCBA) awarded scholarships for the 2024 American Numismatic Association (ANA) Summer Seminar to three outstanding young numismatists.

Eva, Matthew, and Paul have kindly shared their reflections on the invaluable experiences they gained through the attending program. Their experiences exemplify the profound impact the ANA Summer Seminar can have on young collectors, not only as an educational resource but also as a hub for lifelong connections and inspiration. Through NCBA’s Young Numismatist Scholarship, these scholars have gained skills, confidence, and friendships that will continue to shape their futures in the numismatic world.

For more information on the NCBA Young Numismatist Scholarship and how you can apply or support future scholars, please visit the NCBA website [here](https://www.ncbassoc.org/yn-scholarship).

Eva Pate: Building Knowledge and Connections
For Eva Pate, the Summer Seminar was more than just an educational event—it was a pivotal experience that helped her grow as both a numismatist and an individual. “Summer Seminar is one of the few adult education programs offered,” she says, noting how the seminar has become a cornerstone event for people of all skill levels in the numismatic world.

This year, Eva’s second attending the program, she took a class on world counterfeit currency led by Joe Boling, which expanded her understanding of printing methods and counterfeit detection. “Going into the class with little to no knowledge on world currency, by the end I had learned enough to comfortably tell which printing methods were used to make a note.”

This year was particularly special, as she had the chance to reconnect with the friends and mentors she made during her first year attending. She also shared memorable moments bonding with her new roommate, another young woman who shares her passion for numismatics. “I’m usually one of the few young women in a numismatic setting, so when I see another girl my age, it makes me really excited.”

Eva’s experiences have solidified her commitment to the Summer Seminar, and she aspires to return as a Young Numismatist counselor in the future, giving back to the program that has opened so many doors for her.

Matthew Jackson: A Hunger for Lifelong Learning
For Matthew Jackson, his second year at the ANA Summer Seminar was nothing short of extraordinary. “The 2024 Summer Seminar did not disappoint!” he shares, thanking NCBA for the scholarship opportunity.

A highlight of Matthew’s seminar experience was the sense of community. “From the moment I arrived, everyone was so nice. It was great being around so many people who share the same interest as me.” Reuniting with old friends and making new connections also enhanced the experience for him, reinforcing the importance of camaraderie in the numismatic world.

But what stood out most for Matthew was the deep commitment to learning. “The main thing I took away was never stop learning. I gained so much knowledge, and it made me hungry to learn even more.” Matthew encourages anyone interested in numismatics to attend the Summer Seminar, praising the quality of the instructors and the value of the experience.

Looking ahead, Matthew is eager to continue attending the seminar for years to come, confident that it will be a lifelong source of learning and growth.

Paul Bartlett: Gaining Confidence and Expertise
Paul Bartlett was thrilled to participate in the Summer Seminar, which he described as a transformative experience. “A class I took was Grading U.S. Coins Part 1, taught by Kyle Knapp and Owen Seymour—both expert graders. They taught me more than I thought possible.”

Beyond the technical aspects of grading, Paul was also immersed in the larger world of numismatics. “ANA does a great job hosting. When class was over, there was always something to do, from visiting the money museum to attending the coin auction or exploring Colorado Springs.”

Paul's interactions with fellow attendees in the dining hall were just as enriching as the formal lessons, giving him access to a wealth of knowledge from hobbyists and professionals alike. These conversations, combined with the expert instruction he received, have given Paul the confidence to take the next step in his numismatic journey—becoming a coin dealer.

“If you’re interested in advancing your coin knowledge, I highly recommend this experience,” Paul advises. Grateful for the opportunity, Paul extends his heartfelt thanks to NCBA for making his dream a reality.
 

Securing NCBA’s Future: Planned Giving Opportunities

In 2017, board member Mike Fuljenz of Universal Coin & Bullion made a lasting impact on the National Coin & Bullion Association by naming the organization as a $100,000 beneficiary of his life insurance policy. This generous act introduced planned giving as a new source of non-dues revenue for NCBA, offering supporters various ways to contribute to the organization’s long-term financial health.

Planned giving extends beyond life insurance and can include options like bequests in wills, charitable trusts, and retirement assets. Supporters can provide lasting financial support by naming NCBA as a beneficiary or allocating specific assets, allowing them to leave a legacy aligned with their values and the future of the numismatic community.

For more information on planned giving, consult your financial advisor or estate planner.
 

Upcoming Events

Navigating the New Anti-Money Laundering Act of 2020 Regulations, Part 3
The National Coin & Bullion Association invites all coin-business owners attending the 2025 FUN Convention to a seminar on the newly implemented Anti-Money Laundering (AML) Act of 2020. The session, led by AML expert Gary Knaus, will focus on the new regulations’ impacts on the numismatic and precious-metals bullion community.

Recent updates from the Department of Treasury highlight the importance of understanding these changes in order to maintain safe and compliant business practices. This seminar will provide a thorough overview of the regulations and their potential implications for your business.

Gary Knaus, a member of NCBA since 2012, has extensive experience in providing AML compliance services to bullion, coin, and jewelry dealers. His expertise will help attendees navigate the complexities of the new regulations and prepare for future developments in the industry.

We strongly encourage all dealers at the convention to attend this seminar. Staying informed is essential in today’s regulatory environment. The seminar is scheduled for Wednesday, January 8, 2025, at the Orange County Convention Center in Orlando, Florida (time and room to be determined).

For those who attended the previous seminars at the ANA World’s Fair of Money and the 2024 FUN Convention or members who want to catch up on previously released information, video recordings and slide decks from those events are available to NCBA dealer-members on our website. We also recommend reading the articles “The Anti-Money Laundering Act of 2020” in Member News, 2021 Q1, and “What Does Anti-Money Laundering Have to Do with My Company?” on our website for additional insights.

We look forward to your participation in this important seminar.
 
NCBA Board of Directors Meeting
A board of directors meeting will commence at 8:00 a.m. on Wednesday, January 8, 2025, at the Florida United Numismatists Convention in the Orange County Convention Center North/South Building in Orlando (room to be determined).

Participation and engagement from NCBA members are invaluable to the growth and success of our association. Members are welcome and encouraged to attend.

Member Attendance Guidelines
  • Membership Status: Please ensure your membership is current and dues are up to date to attend.
  • RSVP: Kindly confirm your attendance by December 31 for logistical purposes.
  • Participation: Opportunities for member input will be provided during designated segments of the meeting.
  • Meeting Conduct: Respectful adherence to meeting protocols is appreciated.
Your involvement is crucial to shaping our association’s future. We eagerly anticipate your active participation and valuable contributions during the meeting.

For inquiries or to RSVP, please contact executive director David Crenshaw at ncba@ncbassoc.org. 

Membership Dinner and Update
Save the Date!

Get ready for a fantastic evening! We are thrilled to invite you to our annual Membership Dinner and Update.

Date: Wednesday, August 20, 2025 
Time: Hors d’oeuvres and cocktails at 6:30 p.m.; dinner at 7:00 p.m. 
Location: Mickey Mantle’s Steakhouse, 7 South Mickey Mantle Dr, Oklahoma City, OK

Join us for a wonderful opportunity to mingle with fellow members and guests, enjoy a delicious meal, celebrate award presentations, and get the latest updates on NCBA’s activities.

Early Bird Special: Register by July 20, 2025, and save $25 per dinner ($100 now; $125 after July 20). 

Complimentary admission is included for Gold and Platinum members and one guest. Please RSVP. 

Sponsorship Opportunities: Consider becoming an event sponsor with a donation of any amount. Your support makes a significant difference!

Seating is limited, so be sure to register now and secure your spot! Click the button below to sign in and register. You’ll need your membership credentials—if you’ve forgotten them, there’s a link on the sign-in page to help you retrieve them.

CLICK HERE TO REGISTER NOW

We can’t wait to see you there!


Update Your Member Profile

Stay connected with NCBA through our website at ncbassoc.org. We ask that you take a moment to update your member profile via the Home page sign-in. If you do not know your username or password, select “Forgot Your Password” from the Home page to retrieve them.

Concerned Collectors Coalition members should add or update your state and federal legislators on your profile. CLICK HERE to find your legislators—remember, they may change following the election. 

By keeping your member profile up to date, you are guaranteed access to all the exclusive benefits and resources that an NCBA membership offers:
  • Member-only resources specifically for dealers, available online at ncbassoc.org
  • Federal and state legislative alerts and other important communications
  • Discounts on valuable cash- and broker-reporting information kits
  • Professional development educational seminars
  • Access to the online Member News quarterly newsletters
Should you need any assistance or have any questions or comments about your membership and/or benefits, please feel free to contact us at (678) 430-3252 or by email at ncba@ncbassoc.org.
 

Information Kits and White Papers: Essential Resources for Your Business

NCBA provides essential information to help you with cash and broker reporting. Copper and above members get a 50% discount off the listed price.

Cash-Reporting Kit ($200): The information provided by NCBA is intended to assist dealers in understanding the regulations on cash reporting and money laundering. This information is designed to be used in conjunction with the advice of your professional tax advisor.

Consumer Information Kit ($50): This information has been produced in response to many questions from consumers regarding what products and circumstances require transactions be reported to the U.S. Department of the Treasury / Internal Revenue Service.

CLICK HERE to order information kits.

Broker Reporting (Form 1099-B): In response to the IRS clarification regarding reporting obligations for precious-metals dealers, NCBA has released two new white papers. The first, titled “Understanding Reportable Items and Approved Brands for Precious Metals Contracts,” delves into the implications of the IRS clarification on reporting precious-metals sales. It offers insights into how specific items correlate with CFTC-approved contracts and provides information on approved brands that are acceptable for fulfilling precious-metals contracts.

The second white paper, “Navigating IRS Form 1099-B Reporting: Guidelines for Precious Metal Dealers,” is a comprehensive guide designed to show dealer-members how to navigate the reporting requirements outlined in IRS Form 1099-B. This document offers clear instructions on how to determine when reporting is necessary, particularly in light of potential regulatory changes. While these guidelines may stand alone, they are intended to complement the information provided in the “Understanding Reportable Items and Approved Brands for Precious Metals Contracts” white paper. 

Dealer-members may download these white papers from our website, ncbassoc.org, after signing in via the main menu: Resources > Knowledgebase > Anti-Money Laundering > Files. 

Sales-Tax Status & Economic Nexus Requirements by State

This quick-reference guide, for dealer-members only, shows the sales-tax exemption status (complete, partial, or nonexistent exemption) of each state on in-state retail sales of coins, currency, and precious-metals bullion. This guide also shows each state’s post-Wayfair economic nexus requirements.

Dealer-members may download this resource from our website, ncbassoc.org, via the main menu (sign-in required): Resources > Knowledgebase > Sales and Use Taxes > Files.
 

Draw More Exposure for Your Company

Would you like members and visitors to our website to see your company’s message? Would you like to capture the attention of NCBA members in our newsletter, Member News?

Help your company stand out with an advertisement in the advertising carousel and/or Member News. The “Our Sponsors” carousel on our website displays each ad in rotation for approximately five seconds. A carousel advertisement is a free benefit for Bronze-level members and above. Advertising in
Member News, which is sent to all NCBA members every quarter, is also a great way to get your message out.

CLICK HERE for more information.
 

States’ News

Presently, 46 states have complete or partial sales-tax exemptions on in-state retail sales of collector coins and precious-metals coins and bullion. Of those states, five (Alaska, Delaware, Montana, New Hampshire, and Oregon) have no state sales tax at all, while the other 40 have enacted legislation and adopted regulations to exempt such purchases. That leaves five states (Hawaii, Maine, New Jersey, New Mexico, and Vermont) and the District of Columbia who do not exempt retail sales of coins, currency, and precious-metals bullion from sales tax. Any member who would like to start a sales-tax exemption initiative in one of these remaining states or the District of Columbia should email ncba@ncbassoc.org.

Kentucky
Kentucky became the 45th state to enact a full or partial sales-tax exemption on the sale of coins, paper money, and precious-metal bullion, effective August 1, 2024. However, we have received a critical update that could impact the implementation of this exemption.

Initially, when House Bill 8—which included the sales-tax exemption—was submitted to Governor Andy Beshear in March, he attempted a line-item veto of the relevant section. The veto was later deemed unconstitutional by Attorney General Russell Coleman, allowing the General Assembly to direct the secretary of state to enroll the exemption into law. Despite this, the governor’s office is now disputing the enrollment, creating significant legal complications.

The General Assembly plans to challenge the governor’s veto in court. However, until the matter is resolved, businesses in Kentucky may need to collect sales tax on transactions involving bullion and currency to avoid conflicts with the Department of Revenue. This situation presents a dilemma for retailers: collecting sales tax could lead to consumer backlash and potential class action lawsuits, while not collecting it might result in penalties or interest from the Department of Revenue.

Given these developments, we strongly urge all dealers to carefully evaluate their approach to sales-tax collection after August 1, 2024. NCBA will keep dealers informed of any further updates.

In recognition of their efforts in the passage of the Kentucky legislation, several NCBA members were honored at the membership dinner and update event on August 7, 2024. Byrd Saylor III received the Diane Piret Memorial Outstanding Service Award, while Jeff Garrett, Jonathan Kern, Eddie Bruner, and Patrick Heller received the Legislative Champion Award. Their advocacy was instrumental in advancing this legislation, despite the ongoing challenges.

Nebraska
Nebraska’s sales-tax exemption for currency and bullion remains secure, despite legislative efforts that threatened its status. On July 25, 2024, Governor Jim Pillen requested the introduction of Legislative Bill 1, which included multiple tax-related changes and posed a risk to the long-standing exemption.

Thanks to early alert from NCBA member Pat Moran and the swift action of NCBA advisors and members, including written and in-person testimonies, the exemption was preserved. The special session concluded on August 20, 2024, with the exemption intact, demonstrating the effectiveness of vigilant advocacy. 

For more details, read the full story here.

Nevada
In 2022, NCBA member Scott Schwartz of Fidelitrade, Delaware Depository in Boulder City, played a crucial role in securing financial support for our lobbying efforts. This led to collaboration with Allen Rowe of Northern Nevada Coin in Carson City, who is spearheading our campaign for a currency and bullion sales- and use-tax exemption in Nevada.

Our objective is to replace the Nevada Administrative Code § 372.170, which currently provides a limited sales- and use-tax exemption for bullion coins sold at less than 150% of face value. Introducing legislation, we aim to replace this regulation to include a full exemption of currency and precious-metals bullion.

To advance this initiative, we are currently vetting lobbyists and working to secure a bill sponsor from either the senate or assembly, and then we plan to draft the bill language with the sponsor and a legislative staff attorney.

Following these steps, we will engage with the state’s fiscal agency to discuss the bill’s fiscal impact. The Nevada State Assembly session begins on February 3, 2025, which will mark the official start of our campaign.

We believe this exemption will foster job creation, stimulate economic development, and promote tax fairness. We encourage all members to support this important initiative and stay informed about our progress. For more details or to get involved, please contact Allen Rowe at (775) 884-1660 or email info@brokencc.com.

New Jersey
Senate Bill S721, initially introduced as Assembly Bill A5294, has successfully passed through the legislative process and been signed into law by New Jersey Governor Philip D. Murphy on September 12, 2024. This new law, which will take effect on January 1, 2025, exempts sales of investment metal bullion and certain investment coins from sales and use tax.

The $1,000 threshold does not apply to investment metal bullion. The $1,000 threshold is specifically for investment coins, as defined in the bill. Investment metal bullion refers to refined precious metals such as gold, silver, platinum, and palladium, where the value is based purely on the metal content, without regard to any specific monetary threshold like that of investment coins. So, only investment coins must meet the $1,000 market value requirement to qualify for the sales tax exemption, while investment metal bullion is exempt without such a value threshold.

Originally, the bill was amended on March 11, 2024, to remove the $1,000 threshold, and it subsequently passed unanimously by the Senate Budget and Appropriations Committee. The bill continued its progress, receiving unanimous approval from the senate on March 18, 2024, and was referred to the assembly. There, it cleared the Commerce, Economic Development, and Agriculture Committee on June 3, 2024. Following further negotiation, the $1,000 threshold was reinstated. The bill passed the Assembly Appropriations Committee before being substituted for the identical Assembly Bill A2812. The assembly passed A2812 unanimously (71–0), and it returned to the senate, which concurred with the changes on June 28, 2024.

The governor’s signature on S721 marks the successful culmination of a dedicated campaign led by the National Coin & Bullion Association (NCBA) and its coalition partners. The law includes a provision that exempts investment coins with a fair market value of not less than $1,000 from sales tax, addressing concerns from the Assembly Appropriations Committee about potential impacts on sales-tax revenue.

David Crenshaw, NCBA executive director, praised the legislation, highlighting the positive impact of sustained advocacy and collaboration. The strategic efforts of NCBA industry issues advisor Patrick Heller, lobbyists Patrick Torpey and Dan Smith of 1868 Public Affairs, and key decision-makers were instrumental in the smooth passage of the bill.

New Jersey joins a growing list as the 46th state offering similar tax exemptions, fostering a more favorable environment for investment in precious metals.

New Mexico
NCBA members Andrew and Shane Hoffman of Santa Fe Coins & Jewelry will lead our campaign for a currency and bullion sales- and use-tax exemption in New Mexico.

To advance this initiative, we are currently vetting lobbyists, securing a bill sponsor from either the senate or house, and preparing the bill language in collaboration with the sponsor and a legislative staff attorney.

Following these steps, we will engage with the state’s fiscal agency to discuss the bill’s fiscal impact. New Mexico’s legislative session begins on January 21, 2025, which will mark the official start of our campaign.

We believe this exemption will foster job creation, stimulate economic development, and promote tax fairness. We encourage all members to support this important initiative and stay informed about our progress. For more details or to get involved, please contact Andrew and Shane Hoffman at (505) 989-7680 or email ppmcoins@gmail.com.

Washington
The Joint Legislative Audit & Review Committee (JLARC) of Washington State is currently undertaking a thorough review of state tax preferences, including those related to precious metals and monetized bullion. This review is part of JLARC’s mandate to reassess state tax preferences every ten years, evaluating their impact, effectiveness, and overall relevance to current policy and economic conditions.

In December 2023, JLARC reached out to industry experts, including the National Coin & Bullion Association (NCBA), requesting input on the current sales-tax exemption for precious metals and bullion. JLARC staff sought to understand how these tax preferences affect businesses and consumers, as well as whether any states have repealed and re-enacted similar exemptions. They emphasized the need to gather insights from industry stakeholders, setting a timeline for outreach and initial discussions through mid-January 2024.

NCBA quickly responded, providing detailed input on the benefits of exempting precious metals and bullion from sales and use taxes, and a pivotal discussion took place in January 2024 between JLARC and NCBA representatives, including Pat Heller, NCBA’s industry issues advisor. We highlighted key advantages, such as supporting local businesses, preventing cross-border shopping due to neighboring states’ tax exemptions, and reducing tax burdens on smaller investors. NCBA’s feedback also underscored the broader economic benefits, including increased business activity and the growth of the precious metals sector, as evidenced by successful exemptions in states like Tennessee. 

The JLARC released its initial 2024 Tax Preference Reviews in July, where they estimated that Washington’s exemption on precious metals resulted in an annual loss of $28 million in sales taxes. This estimate was based on confidential taxpayer data, which raised questions from NCBA regarding its accuracy. NCBA expressed concerns that the actual sales figures might be significantly lower than projected, suggesting the estimate might be overstated by as much as 5–8 times the actual amounts.

In written follow-up testimony submitted in September 2024, NCBA emphasized several key points to defend the existing exemptions. We questioned the accuracy of the sales data used to estimate potential tax revenue losses and cited examples from other states where tax exemptions had been revoked, resulting in significant harm to local businesses. We pointed out that Washington residents would likely seek alternatives to avoid sales tax, such as purchasing from out-of-state vendors or using tax-exempt investment options like ETFs and vault storage. Furthermore, NCBA highlighted interstate competition, noting that nearly all other states provide similar exemptions, thus placing Washington businesses at a disadvantage if the exemption were revoked.

The review process will continue throughout 2024, with JLARC set to present its final report in December.
 

National News

Alert: Rising Threat of Courier Fraud Targeting Gold Buyers

The National Coin & Bullion Association (NCBA) and the Numismatic Crime Information Center (NCIC) are warning dealers and consumers about a sophisticated scam known as “courier fraud” that is increasingly targeting the gold and bullion markets. In this scheme, criminals impersonate law enforcement or bank officials to trick victims into buying gold under false pretenses, only for it to be stolen once purchased.

How It Works: Scammers pose as officials and create a sense of urgency, convincing victims to buy gold, which is then collected by the perpetrators under the guise of “safekeeping.” The victims are left without their gold and often at significant financial loss.

Recent Cases: This scam, previously common in the UK, is now impacting the U.S., with notable incidents including a $400,000 loss from one victim and another $3 million defrauded from Maryland residents.

Impact: These scams are not only causing financial damage but also undermining trust in legitimate bullion dealers. 

Protect Yourself: Be cautious of unsolicited calls asking for personal information or gold purchases, and verify any requests independently by contacting your bank or local authorities directly.

Stay vigilant and report suspicious activity to NCIC or the FBI’s Internet Crime Complaint Center. For more details and prevention tips, read the full story here.
 

Should You Dread an IRS Title 31 AML Audit? The answer is a bit more nuanced than you might think.

IRS audits come in two flavors. The first is an audit that is easily completed through the mail. You receive a letter from the IRS requesting specific information, such as a copy of your AML program or Independent Audit review. A date by which you must comply is provided, and if your program and/or review appear compliant, there is likely little to worry about.

The second type is in person. Business owners receive a letter from a revenue agent, who informs you of when they will be visiting your business, along with an Information Document Request (Form 4564) and a list of the material they want to see. This is the more anxiety-producing of the two audits, especially if you haven’t yet implemented an AML program that is fully compliant with AML regulations.  Between the amount of material requested and the generally short timeline, these can seem both overwhelming and frightening. I know, because I have a client undergoing one now. (The good news is they appear to have already effectively implemented their AML program, had regular reviews, and can put together—albeit with lot of extra effort—the documentation required by the IRS to prove it.) 

So, what types of documentation and materials are typically required for an in-person IRS AML audit? The list below, which is not necessarily inclusive, provides insights in the size of the task to be undertaken:
  • A copy of your anti-money laundering program
  • A copy of your business risk assessment
  • A copy of any written policy statements, procedures, etc., of the business that may relate to Bank Secrecy Act (BSA) provisions. (This includes your anti-money laundering program.)
  • A copy of BSA training materials, training schedules, employee attendance records, tests, and other documents showing employees completed BSA training
  • A copy of independent testing reports and recommendations
  • Books and records required to be maintained pursuant to BSA regulations 31 CFR 1027-100 and any other records as required for the period covered by the review (typically a year), including
    • Statements of accounts from banks, including paid checks, charges or debit entries, deposit slips, and any other credit memoranda (including checking, savings, money market accounts, etc.)
    • Daily, weekly, and monthly sales registers, work records, summaries and reconciliations needed to identify and reconstruct currency transactions with customers and counterparties
    • Signature or customer registers, customer/supplier lists, or other documents containing the names of the customer/supplier/counterparty, street address, and identification numbers
  • Journals/logs, including sales journals, accounts receivable, notes receivable, and cash receipts
  • Books and records that indicate payment types and amounts received from customers, including
    • Customer payments for merchandise
    • Sales log/listing
    • Sales invoices
    • Installment sales agreements
    • Copies of Form 8300—Report of Cash Payment Over $10,000 received in a Trade of Business and the corresponding invoices which have been prepared and/or filed, as well as copies of notification statements furnished to the customers
    • Company policies regarding any payment agreements
  • Purchase records for period of the audit
    • Supplier(s) background/identification information—if supplier is from another country, documentation that they are also following AML procedures and regulations
    • Invoices for merchandise received
    • Payment documentation
  • A list of nearby competitors who are dealers in precious metals, precious stones, or jewels
  • Copies of the following BSA reports filed during the period of the audit
    • FinCEN Form 114—Reporting of Foreign Bank and Financial Accounts (FBAR)
    • FinCEN Form 105—Report of International Transportation of Currency or Monetary Instruments (CMIR)
If that doesn’t take your breath away, you should probably read it again. However, if you have already been maintaining AML required documents, bank documents, and following the regulations, you can feel a bit more optimistic. 

IRS AML audits happen. Be prepared.

Are you going to the FUN Convention? If so, we hope you can attend our seminar, “Navigating the New Anti-Money Laundering Act of 2020 Regulations, Part 3,” on Wednesday, January 8, 2025, at the Orange County Convention Center in Orlando (time and room to be determined). This seminar will provide a thorough overview of the regulations and their potential implications for your business.
 
Gary Knaus, NCBA Anti-Money Laundering Advisor and owner of Knaus & Associates, Inc., has provided AML compliance services to bullion, coin, and jewelry dealers since 2012. Contact him at 630-963-6350 or gknaus@aml4u.com.


Support HR 7865: Advocate for Easier Import of Historical Coins and Enhanced Trade Relations

The International Association of Professional Numismatists urges NCBA members to express their support for HR 7865, a bill introduced by Representative Beth Van Duyne that seeks to amend the Convention on Cultural Property Implementation Act. This bill aims to ease import restrictions on ancient, medieval, and early modern coins by ensuring that lawful acquisitions can proceed without the broad and restrictive barriers currently in place. 

This legislation would facilitate the lawful trade of numismatic materials with European partners while upholding the original objectives of preventing the entry of recently looted items into the market. To support this effort, please contact your federal representatives and ask them to co-sponsor HR 7865. Find your representative here, and share your experience with IAPN executive director Peter Tompa at pkt@becounsel.com. For more details, please see the article on HR 7865 in CoinWeek.