CPAC Comments on Italy MOU

Smugglers

It is now past midnight Washington time, and a little window on the Regulations.gov website docket on the Italy MOU renewal tells us there were "274 Comments Received", and of these 297 have been posted up (uh?) so I guess before the coineys accuse them of "vote-rigging", we'll have to wait for the DOS to sort themselves out before we know the real tally. Several people who I know commented do not yet figure in the list - I guess the update will be on Monday.

The coineys were urged by Mr Lehman to say how they feel, and one or two did... SueMcGovern feels so strongly about it all, she posted twice (here and here). The dealer Paul-Francis Jacquier is another double-poster, he's honest enough to admit it's all about the money. Another double-poster was William Tse, who sent the same capitalised message twice: "American Freedoms should not be Stifled just to appease foreign governments. We are the UNITED STATES OF AMERICA and NOT THE UNITED STATES OF ITALY!!! Enough is..." repeated here.  Charlton Patterson is another double-poster ("Enough is enough. This MOU should be allowed to lapse. Its negative impacts on collecting and the appreciation of Italian culture and people").  Thomas R. Miller has one comment here and a much more entertaining one here

You should check out the British antiquities laws. They make so much sense that ours look pretty stupid in comparison.

I would say the fact that these "antiquity laws" to which he refers have nothing to do with what CCPIA regulates rather makes somebody else look stupid, actually. But then its rocket science to somebody who cannot count how many comments he's sent I guess (by the way, in the longer one, he gets the name of the Treasure Act wrong and obviously does not know how it operates).

There are two texts, one from a B.R.Bell, and another by Benjamin Bell. Are they the same author? Take a look and decide for yourselves, they are quite entertaining anyway and miss the point entirely. One quotes the Bible in support of abandoning America's obligations under the 1970 UNESCO Convention.

Then we have the deeply considered thoughts of Dick Stout, veteran metal detectorist and coin shooter
(see here: 'Metal Detectorists Support Artefact Smuggling' for his reasoning behind this comment): "Please let this regulation lapse. It serves no purpose other than to disenfranchise collectors. Time to turn the page...." (Eh?) That's it, he breaks off mid-sentence. His British metal detecting sidekick and staunch supporter of the IAPN and PNG John Howland cuts and pastes and then adds a trenchant comment of his own:

Restrictions will negatively impact on the cultural understanding and people to people contacts collecting provides. It's typically impossible to assume a particular coin (especially a Roman one) was first discovered within and subject to the export control of Italy. Italian historical coins are very common and widely and legally available for sale elsewhere, and it's the absurd to restrict coins freely available for sale in Italy itself. Utter lunacy.

Mr Howland's own collecting activities have a very strong effect on the degree and nature of his cultural empathy and people-to-people contacts.

His BFF Peter Tompa also writes twice, once as the lobbyist of the IAPN and PNG ("as a representative of the small businesses of the numismatic trade") and then on his own behalf as a collector. The IAPN and PNG want the CPAC to recommend that instead of following the CCPIA (how so?) for coins they should recommend that:

Any renewal should let import restrictions, particularly on coins, lapse. No new restrictions should countenanced on late Roman Republican or Roman Imperial coins. CBP should be directed to allow entry of coins of the sort lawfully available for sale in Italy that are accompanied by E.U. export permit or other documentation evidencing legal export from an E.U. member state.

So, scrutiny of coin imports should "lapse" but also EU export licences should be accepted - some contradiction there, no? Two things, first of all the EU did not exist when the CCPIA was drafted, to recognize this kind of export licence, the CCPIA needs to be rewritten or amended (I'm all for that, let us tighten it up and make it more suitable for the job in the markets of the 21st century). Secondly what it seems the IAPN and PNG are slyly trying to slip in here can be seen as nothing else than paving the way for a smugglers' carte blanche. As everybody knows (including Professor Gerstenblith I am sure), current EU Regulations on the export of cultural goods do not require export licences for most ancient coins, though the national regulations of countries within the EU (the UK and Italy for example) in different circumstances do. The IAPN and PNG apparently want the EU regulations to cancel out the laws and expectations of the individual countries. Just what kind of legal advice are the IAPN and PNG paying Peter Tompa for? Mr Tompa's "own" contribution is merely the text he posted up for other collectors to copy and paste in his mass mailing campaign.Odd though isn't it that the lawyer himself does not ask the CPAC for what the IAPN and PNG do. Also the size of his comment from the IAPN and PNG suggests he might be paid by the word, there is sop much totally superfluous padding that this looks a real possibility.

I note that  Ed Snible suggests instead of export licence checks, that "less drastic" would be: "Let us make markets more transparent, and provide no incentive for secrecy" I am sure there'll be many responsible collectors 100% behind him there - how many dealers are? (He adds pointedly: "I am a coin collector and independent scholar. I am not a dealer nor do I have a financial interest in this matter".) How many of the other commentators can claim the same?

Now I expect Peter Tompa will be sitting down soon to count up the "yays" and "nays" to announce that once again coiney mass mailing "won the competition". In the words of Mr Howland, utter lunacy.