More about today's CPAC hearing later, but for now this is what I said more, or less, during my allotted 5 minutes:
Thank you for allowing IAPN and PNG- which represent the small businesses of the numismatic trade – the opportunity to speak to you again.
Let me add my voice to the 70% or so of the public comments posted on the regulations.gov website that either opposed the MOU in full or opposed any extension of import restrictions to coins. This is a remarkable number, particularly when one also considers that the AIA and Greek Embassy actively lobbied archaeologists who excavate in Greece and others for support.
Numismatics, or the study of coins, used to be known as the “hobby of kings.” The large numbers of coin collectors opposed to restrictions confirms that this generally no longer the case, but in Greece it remains so. There, only a chosen few can hold ancient coins legally. But they can and do then import largely what they want. For example, the Alpha Bank and the Greek National Coin Collection accessioned rare, unprovenanced Athenian Decadrachms (worth $250,000 - $1 million) to their collections. Such coins are typically found outside of Greece. Thus, this is no “repatriation by purchase,” except in a nationalistic sense.
Let me be clear. I am glad Greek museums and at least some Greek citizens can legally build large collections of unprovenanced ancient coins. But, then doesn’t that also make any Greek request for import restrictions hypocritical?
Such import restrictions will only impact Americans. As a letter in the record from the Bavarian Minister of Economic Affairs demonstrates, many EU citizens trade unprovenanced Greek coins quite freely and without the need for export permits. This brings us to the CPIA’s “concerted international response” requirement. That provision, which seeks to ensure the comity and effectiveness of any import restrictions, cannot possibly be met here.
Then, there is the “first discovery” requirement. Restrictions may only be lawfully imposed on artifacts “first discovered within” Greece. But, as set forth in our Greek Coin Finds study, coins struck in Greece and found elsewhere must account for some 18% of the estimated 350,000,000, or more ancient coins of the entire Greek world extant, making the “first discovery” requirement impossible to meet as well.
CPAC should consider the potential impact of import restrictions on the ability of ordinary American citizens to collect Greek coins and to engage in cultural exchange with European collectors. Please, let’s not make coin collecting the “hobby of kings” once more.