LEGALCOIN DETECTIVE
PUBLIC DOCUMENT
2026
OPEN LETTER TO
TEXAS DEPARTMENT OF BANKING
March 28, 2026
Recipients: Commissioner Charles G. Cooper
Language: EN
Subject: Virtual Currency
Money Transmission
PROCESS TIMELINE
Letter drafted and published publicly
March 28, 2026
Sent to [email protected] + DOB web form
March 28, 2026
Awaiting DOB response from Commissioner Cooper
Expected: 10–30 business days
Confirmation: LegalCoin outside money transmission scope
Pending
Response received
Pending
RECIPIENTS & CONTACTS
TO – PRIMARY
Texas Banking Commissioner
DEPARTMENT
Texas Department of Banking (DOB)
Non-Depository Supervision · Virtual Currency
TEXAS MSMA 2023 – WHY THIS MATTERS FOR LEGALCOIN
The Texas Money Services Modernization Act (2023) explicitly clarified that non-stablecoin virtual currencies — those without a fixed peg to fiat currency — do not constitute "money or monetary value" under Texas Finance Code Chapter 152 (MSMA 2023). This means LegalCoin, as a utility governance token with no fiat peg, most likely falls outside the scope of money transmission licensing requirements enforced by DOB. We are seeking formal written confirmation of this position.
OFFICIAL DOCUMENT
HOUSTON, TEXAS / FRANKFURT AM MAIN — MARCH 28, 2026
Dear Commissioner Cooper,
I am writing publicly on behalf of YOUR I Inc., a Texas nonprofit corporation headquartered in Houston, TX, because the regulatory question we raise affects not only our organization but the broader innovation ecosystem in Texas.
We have developed LegalCoin Detective — an experimental nonprofit model that serves as a transparent, community-governed alternative to traditional legal insurance (e.g., ARAG SE-type coverage). Our model allows community members, volunteers, and participants in the User-Economy-Driven Color Code project to submit legal cases via AI tools and a decentralized "Detective" network, bypassing opaque and often ineffective legacy coverage providers.
The project operates through YOUR I Inc. (Texas nonprofit), TAVO AS VŠĮ (Lithuania), and project management partners in Germany, involving over 200 volunteers across multiple countries, with particular focus on linguistic minority rights and access to justice.
Regulatory basis for this inquiry: Under the Texas Money Services Modernization Act (2023), non-stablecoin virtual currencies are explicitly excluded from the definition of "money or monetary value" under Texas Finance Code Chapter 152 (MSMA 2023). We believe LegalCoin — a non-pegged utility governance token — falls outside DOB's money transmission licensing scope. We respectfully request formal written confirmation
We respectfully request clarity on the following:
1. Does LegalCoin — as a non-stablecoin utility governance token providing access to AI tools, voting rights, and community services — fall outside the definition of "money or monetary value" under Texas Finance Code Chapter 152 (MSMA 2023) and the MSMA 2023?
2. Does operating LegalCoin Detective as a nonprofit mutual aid mechanism require an MSB license under Chapter 152, or does it qualify as a Digital Asset Service Provider under Chapter 160 of the Texas Finance Code?
3. Would the Texas DOB consider providing a No-Action Letter or informal guidance for our nonprofit pilot model?
As documented in the attached Economic Impact Assessment, systemic legal bottlenecks in the EU have already caused a documented opportunity loss exceeding $108M and stalled the creation of 1,000+ high-tech jobs that could have been anchored in Texas. Regulatory clarity from the DOB would directly enable us to reactivate this development pipeline under Texas jurisdiction.
We are fully prepared to provide all necessary documentation, participate in a meeting with your office, and engage in open dialogue. This letter is published publicly at home.youri.org/dob as part of our transparency commitment.
Thank you for your time.
Best regards,
R. Kadziene
Founder & Director, YOUR I Inc. (Texas nonprofit corporation)
Director, TAVO AS VŠĮ (Lithuania)
ECONOMIC IMPACT – REGULATORY JUSTIFICATION
€12,9M
Lost EU Funding
Digital Europe, Horizon Europe, Invest EU
€42,8M
Lost Private Capital
1:3 leverage – blocked investments
1,000+
Texas Jobs Stalled
Texas Enterprise Fund impact
€108M+
Total Opportunity Loss
2025–2030 projection
This letter has been published publicly at home.youri.org as part of YOUR I Inc.'s commitment to transparency.
YOUR I Inc. is a registered Texas nonprofit corporation. All regulatory responses will be published here upon receipt and with permission.
Collaboration:
YI™NGO, YI™ INC., PM Germany
Preserving Languages, Empowering Communities
Contact
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