Impact of COINS Act on Biotech: this is the summary image, and its spot-on:
Having waded through 163 pages of the draft COINS rule published by Treasury, my team and I can now respond with a simple graphic.View quoted post on X
It will blind US companies and undermine our biopharma capabilities and national security, exactly opposite to what the policy is aiming to achieve. It does nothing to actually block a Chinese biotech from commercializing a drug in the US, with a European partner, European investors, or on its own. We value medicines highly and will now be paying others for them. Why would we do this to ourselves? We shouldn’t.
But you can’t submit a comic to Treasury so we wrote out a detailed comment that both lays out how the draft rule would backfire on American biotech and what revisions would allow Treasury to better achieve their stated national security objectives.
Have a look. Biotech investors and executives are welcome to sign onto our comment but the main purpose of publishing it now is to drive discussion that helps everyone sharpen their thinking and informs their own comment to Treasury, due Dec 7th. Anyone is welcome to crib from this. No need to ask.
We wrote it after considerable input from legal experts and peers. Since coins draft rule is itself unclear on many points, reasonable people can disagree as to its intent and meaning, so some of our comments address broader points meant to encompass a range of possibilities.
If you read what Treasury wrote, you might get the sense that they know this will backfire on America and are looking for support to revise their language to avert harm. So give this thought and submit your own analysis. We provide links in the article to the submission page.
And thanks to all who have already signed on.
@NPLB_org
racap.com/rapport/commen…