From the Tennessee Comptroller of the Treasury –

Mayor Scott Conger
City of Jackson
121 East Main St., Suite 301
Jackson, TN 38301

Dear Mayor Conger:

It has come to our Office’s attention through inquiries from both citizens and media that the City of Jackson (“the City”) is exploring the possibility of paying its employees or contractors with cryptocurrency, particularly Bitcoin.

Municipalities may only exercise those powers delegated to them, our Office is currently unaware of a provision in the law that authorizes the City to directly pay its employees or contractors in cryptocurrency. Rather, such direct payments could run afoul of the Fair Labor Standards Act and other state wage laws.

While it may, on the other hand, be permissible for the City to provide its employees with an optional service to convert wages to cryptocurrency after the employees have been paid in U.S. dollars, we have seen a significant fluctuation in the cryptocurrency market in recent days. We would therefore urge you to remember your fiduciary responsibility to the citizens and to govern accordingly as you make such decisions in the future.

Sincerely,
Jason E. Mumpower
cc: Jackson City Council