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FORVM`s Classical Numismatics Discussion Board  |  Numismatic and History Discussions  |  Ancient Coin Forum (Moderator: Danny S. Jones)  |  Topic: Private collecting soon to be banned ? 0 Members and 1 Guest are viewing this topic. « previous next »
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helvetica
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« on: June 29, 2020, 05:04:35 pm »

I just received this email from CNG:

Once again, our hobby is being threatened by potential new restrictions on
the import of ancient coins. This time, two of most popular of all ancient
types, Roman Republican and Roman Imperial coins, are in the cross-hairs.
It is reportedly being proposed that import restrictions on all Roman coins
be added to the current Memorandum of Understanding (MOU) between the
United States and Italy as it comes up for renewal this year.

To protect the pursuit we all love, Classical Numismatic Group is asking
our collector friends and colleagues to send comments to the US State
Department opposing any restrictions on the importation of Greek and Roman
coins that were produced in Italy. The deadline for comments is July 8.

In the past few years, collectors have gained some important exemptions for
certain coin types via lobbying the State Departments Cultural Property
Advisory Committee (CPAC). While the record is mixed and some restrictions
have been imposed, until now both later Roman Republican issues (after 211
BC) and Roman Imperial coins have not been subject to restrictions.

This government regulation or MOU is up for renewal every five years. Since
2011 when this restriction first applied to ancient coins, it has covered
Greek coins produced in Italy as well as the earliest Roman coins, pre-211
BC. This time, certain segments of American archaeological associations and
a powerful lobbying organization that seeks to ban all private collecting
of ancient artifacts will likely push for the extension of restrictions to all Roman coins.


This would greatly reduce the number of coins that could enter and make
importation from overseas venues either illegal or vastly more difficult
and time consuming. This, along with the additional costs of importation to
include required documentation, would likely lead to increased prices.

While many of the most expensive coins do have pedigrees, there are many
coins entering the market that do not have an extensive paper trail.  While
we have learned to live with restrictions on certain types of ancient coins
by researching pedigrees, this has curtailed the trade among these types
and resulted in increased prices that have limited the collector base and
the general enjoyment of an age-old hobby.

Comments should be polite, succinct and to-the-point. They should request
that the current restriction on coins produced in Italy be removed, as
coins by their nature are intended to circulate widely, in many cases far
beyond the borders of Italy or even the Roman Empire. The current
nation-state of Italy did not exist until 1861, therefor Italy should have
no claim on coins produced thousands of years in the past. It is important
to stress that, even if the current restrictions remain, under no
conditions should they be extended to all Roman coins.


For further information including suggested comments, see [2] Please Help
Save Roman Imperial Coin Collecting by Peter Tompa, a cultural property
attorney who has made it is lifes work to stand against arbitrary import
restrictions.

Comments may be submitted to the [3]Cultural Property Advisory Committee.
Please click the blue button at the top right to be directed to the comment
page. Please note that your comments are not private and may be included on
the government public comment page. The deadline to submit a comment is
July 8.


Thank you for your attention to this important matter! Please feel free to
contact CNG with any questions.

References

[Commercial Links Removed by Admin]
2. http://culturalpropertyobserver.blogspot.com/2020/06/please-help-save-roman-imperial-coin.html
3. https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233
4. https://www.regulations.gov/comment?D=DOS-2020-0022-0002
[Commercial Links Removed by Admin]

CNG, LLC
Classical Numismatic Group
P.O. Box 479
Lancaster, PA 17608
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frgreg
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« Reply #1 on: June 29, 2020, 07:43:46 pm »

I also received this e-mail.  I submitted my comments on the government website.  I hope and encourage others to as well.

https://www.regulations.gov/document?D=DOS_FRDOC_0001-5233

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PMah
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« Reply #2 on: June 29, 2020, 09:04:50 pm »

Although I am a collector in the area most at risk, the hobby's general response of mere opposition isn't going to be very successful, as shown by the current regulations.   Once a regulation gets to the comment phase, it essentially means the agency has determined the preferred course and the views of likely major impacted groups have been made known.  There is a bit of a dance but there usually has to be a major shift in the baseline to change the outcome, and the field has not created that shift.  I have never been impressed by the approach taken by the industry groups.  I have read the material over the years and it is simply not compellingly presented.
   Some of the arguments,  such as Italy didn't exist until 1861, are frankly not worth making.
 That's true of almost every sovereign nation except perhaps Japan, and nation-states do not cede sovereignty except by economic or physical coercion. And they generally do not encroach unless massive economic issues are in play.    If the US chose to protect pre-Columbian material,  shouting "the US didn't exist until 1776" would not win the argument, and having "Sweden" make that claim would be even less compelling.  There's simply no leverage.
   The better argument is that the US could delay extension and condition such restrictions on Italy and Greece adopting a form of the UK's Portable Antiquities Scheme, both for discoveries and for export registration and licensing.   There's solid statistics there and the archeo-groups are ok with it.    That's the sort of ask-and-get dealing that seems to get some traction in DC today.   Are the groups and governments likely to agree today? No, and that's why a different approach probably should have been taken a long time ago.
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Molinari
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« Reply #3 on: June 30, 2020, 06:46:30 am »

Although I am a collector in the area most at risk, the hobby's general response of mere opposition isn't going to be very successful, as shown by the current regulations.   Once a regulation gets to the comment phase, it essentially means the agency has determined the preferred course and the views of likely major impacted groups have been made known.  There is a bit of a dance but there usually has to be a major shift in the baseline to change the outcome, and the field has not created that shift.  I have never been impressed by the approach taken by the industry groups.  I have read the material over the years and it is simply not compellingly presented.
   Some of the arguments,  such as Italy didn't exist until 1861, are frankly not worth making.
 That's true of almost every sovereign nation except perhaps Japan, and nation-states do not cede sovereignty except by economic or physical coercion. And they generally do not encroach unless massive economic issues are in play.    If the US chose to protect pre-Columbian material,  shouting "the US didn't exist until 1776" would not win the argument, and having "Sweden" make that claim would be even less compelling.  There's simply no leverage.
   The better argument is that the US could delay extension and condition such restrictions on Italy and Greece adopting a form of the UK's Portable Antiquities Scheme, both for discoveries and for export registration and licensing.   There's solid statistics there and the archeo-groups are ok with it.    That's the sort of ask-and-get dealing that seems to get some traction in DC today.   Are the groups and governments likely to agree today? No, and that's why a different approach probably should have been taken a long time ago.

Good point.
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« Reply #4 on: July 03, 2020, 11:14:10 pm »

Hi folks,

I submitted my comment today.

Meepzorp
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Anaximander
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« Reply #5 on: July 05, 2020, 02:34:21 pm »

I have also submitted my comments. 
Thanks to PMah for the thoughtful input and Helvetica for sharing the MOU links. 
The submitted comments from Peter Tompa (and see his attachment) are useful as arguments, with the goal of promoting lawful trade.

Anaximander
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« Reply #6 on: July 05, 2020, 02:46:21 pm »

I think I should clear up one thing. Private collecting is not going to be banned. MOU's strictly relate to imports. Still a big issue, but not a ban on collecting.
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