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<p>[QUOTE=&quot;Peter Tompa, post: 3780045, member: 107785&quot;]Thanks to all who commented.&nbsp; There still is time to do so though the comment period ends today.&nbsp; Here is my personal comment:&nbsp; <a href="https://www.regulations.gov/document?D=DOS-2019-0031-0054" target="_blank" class="externalLink ProxyLink" data-proxy-href="https://www.regulations.gov/document?D=DOS-2019-0031-0054" rel="nofollow">https://www.regulations.gov/document?D=DOS-2019-0031-0054</a></p><p><br /></p><p><font size="5"><b>Comment</b></font></p><p>View document:</p><p><br /></p><p>Dear CPAC, Ive already written separately on behalf of IAPN and PNG. Please also consider these additional personal comments. </p><p><br /></p><p>1. The ANS kindly provided me a forum to detail my own views about import restrictions on coins and their detrimental impact on legitimate collecting, the appreciation, study and preservation of historical coinage and the people to people contacts coin collecting brings. See <a href="http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf" target="_blank" class="externalLink ProxyLink" data-proxy-href="http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf" rel="nofollow">http://numismatics.org/wikiuploads/DigitalPublications/WitschonkeTompaFinal.pdf</a></p><p><br /></p><p>2. Since that article has been published, collecting has even become more challenging given a rush of new import restrictions, most significantly ones of highly collected coins from Italy, Greece, Bulgaria, and Egypt.</p><p><br /></p><p>3. These restrictions are highly problematic because the way are applied. My reading of the CPIA is that import restrictions are meant to only apply prospectively to items illicitly exported from the country for which import restrictions were granted after the effective date of the governing regulations. The problem is that they are instead applied far more broadly as an embargo on all items on designated lists imported into the US after the effective date of applicable regulations. The one federal court that has been asked to look at the issue refused to get involved, claiming that it was a foreign policy issue. </p><p><br /></p><p>4. If restrictions were applied as contemplated by Congress, the impact on trade between the US and fellow collectors in Europe would be limited. However, embargoes make it impossible to legally import coins of types on designated lists because most coins simply lack sufficient information as far as Customs is concerned to import under the CPIAs safe harbor provisions.</p><p><br /></p><p>5. Let me provide an example. I purchased a Himyarite coin from Spink, a UK seller, back in 2009 for $70. It has wonderful old collection toning so was likely in a collection in the UK for many years before it was purchased. However, Spink did not provide me with any collection history for the coin, probably because they had none. It simply was not thought important to retain for coins at the time, and there still is no legal requirement that documentation is retained for such items. Moreover, even when it is retained, it is quite easy for it to be lost over time. For more, see <a href="https://culturalpropertynews.org/the-international-art-market-as-cultural-bogeyman-part-1/" target="_blank" class="externalLink ProxyLink" data-proxy-href="https://culturalpropertynews.org/the-international-art-market-as-cultural-bogeyman-part-1/" rel="nofollow">https://culturalpropertynews.org/the-international-art-market-as-cultural-bogeyman-part-1/</a>. I know I must have an invoice for my coin somewhere, but it is not easily at hand. Moreover, there was no reason for me to think I would need to keep an invoice when I purchased the coin. And, in any case, the invoice would not have an image on it so it is quite possible a customs official would not accept it as conclusive proof I purchased this coin in 2009 anyway.</p><p><br /></p><p>6. Such restrictions only harm honest collectors and dealers because as should be apparent from the attached pictures, such coins are so small that they may easily be smuggled. This makes CPIA import restrictions as applied by Customs the epitome of a poor regulatory scheme one that only punishes honest people importing coins from legitimate source in Europe, and which does nothing really to deter smugglers of such small items from todays war torn Yemen. </p><p><br /></p><p>7. Over time, the ever increasing number of embargoes placed on all sorts of coins has really harmed ancient coin collecting which provides most, if not all, support for the scholarly study of coins (Numismatics).</p><p><br /></p><p>8. A great example of how collecting supports academic study is the Caravan Kingdoms book written by a German collector of coins from the area along with an ANS academic, and published at the ANS. The ANS, and its publications are collector and dealer supported. The ANA, the other major center for the study of coins in the US, is also collector and dealer supported. In contrast, the Smithsonian, though it has a large collection, does little or no academic work and recently even discharged collectors helping to catalogue the collection as part of a Smithsonian wide move limiting the activity of volunteers. </p><p><br /></p><p>9. Without a strong collecting base, there will no longer be the necessary level of support for the ANS, the ANA and the study of numismatics in the US. So, although import restrictions have been pitched in the past as necessary to promote academic study of archaeological objects, that simply is not the case with respect to coins. In fact, if anything, over time import restrictions will have the opposite effect on Numismatic study in the US.</p><p><br /></p><p>Sincerely,</p><p><br /></p><p>Peter Tompa[/QUOTE]</p><p><br /></p>

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