Summary: Everyone knows that when you give your assets to someone else, they always keep them safe. If this is true for individuals, it is certainly true for businesses. Custodians always tell the truth and manage funds properly. They won't have any interest in taking the assets as an exchange operator would. Auditors tell the truth and can't be misled. That's because organizations that are regulated are incapable of lying and don't make mistakes. First, some background. Here is a summary of how custodians make us more secure: Previously, we might give Alice our crypto assets to hold. There were risks:
Alice might take the assets and disappear.
Alice might spend the assets and pretend that she still has them (fractional model).
Alice might store the assets insecurely and they'll get stolen.
Alice might give the assets to someone else by mistake or by force.
Alice might lose access to the assets.
But "no worries", Alice has a custodian named Bob. Bob is dressed in a nice suit. He knows some politicians. And he drives a Porsche. "So you have nothing to worry about!". And look at all the benefits we get:
Alice can't take the assets and disappear (unless she asks Bob or never gives them to Bob).
Alice can't spend the assets and pretend that she still has them. (Unless she didn't give them to Bob or asks him for them.)
Alice can't store the assets insecurely so they get stolen. (After all - she doesn't have any control over the withdrawal process from any of Bob's systems, right?)
Alice can't give the assets to someone else by mistake or by force. (Bob will stop her, right Bob?)
Alice can't lose access to the funds. (She'll always be present, sane, and remember all secrets, right?)
See - all problems are solved! All we have to worry about now is:
Bob might take the assets and disappear.
Bob might spend the assets and pretend that he still has them (fractional model).
Bob might store the assets insecurely and they'll get stolen.
Bob might give the assets to someone else by mistake or by force.
Bob might lose access to the assets.
It's pretty simple. Before we had to trust Alice. Now we only have to trust Alice, Bob, and all the ways in which they communicate. Just think of how much more secure we are! "On top of that", Bob assures us, "we're using a special wallet structure". Bob shows Alice a diagram. "We've broken the balance up and store it in lots of smaller wallets. That way", he assures her, "a thief can't take it all at once". And he points to a historic case where a large sum was taken "because it was stored in a single wallet... how stupid". "Very early on, we used to have all the crypto in one wallet", he said, "and then one Christmas a hacker came and took it all. We call him the Grinch. Now we individually wrap each crypto and stick it under a binary search tree. The Grinch has never been back since." "As well", Bob continues, "even if someone were to get in, we've got insurance. It covers all thefts and even coercion, collusion, and misplaced keys - only subject to the policy terms and conditions." And with that, he pulls out a phone-book sized contract and slams it on the desk with a thud. "Yep", he continues, "we're paying top dollar for one of the best policies in the country!" "Can I read it?' Alice asks. "Sure," Bob says, "just as soon as our legal team is done with it. They're almost through the first chapter." He pauses, then continues. "And can you believe that sales guy Mike? He has the same year Porsche as me. I mean, what are the odds?" "Do you use multi-sig?", Alice asks. "Absolutely!" Bob replies. "All our engineers are fully trained in multi-sig. Whenever we want to set up a new wallet, we generate 2 separate keys in an air-gapped process and store them in this proprietary system here. Look, it even requires the biometric signature from one of our team members to initiate any withdrawal." He demonstrates by pressing his thumb into the display. "We use a third-party cloud validation API to match the thumbprint and authorize each withdrawal. The keys are also backed up daily to an off-site third-party." "Wow that's really impressive," Alice says, "but what if we need access for a withdrawal outside of office hours?" "Well that's no issue", Bob says, "just send us an email, call, or text message and we always have someone on staff to help out. Just another part of our strong commitment to all our customers!" "What about Proof of Reserve?", Alice asks. "Of course", Bob replies, "though rather than publish any blockchain addresses or signed transaction, for privacy we just do a SHA256 refactoring of the inverse hash modulus for each UTXO nonce and combine the smart contract coefficient consensus in our hyperledger lightning node. But it's really simple to use." He pushes a button and a large green checkmark appears on a screen. "See - the algorithm ran through and reserves are proven." "Wow", Alice says, "you really know your stuff! And that is easy to use! What about fiat balances?" "Yeah, we have an auditor too", Bob replies, "Been using him for a long time so we have quite a strong relationship going! We have special books we give him every year and he's very efficient! Checks the fiat, crypto, and everything all at once!" "We used to have a nice offline multi-sig setup we've been using without issue for the past 5 years, but I think we'll move all our funds over to your facility," Alice says. "Awesome", Bob replies, "Thanks so much! This is perfect timing too - my Porsche got a dent on it this morning. We have the paperwork right over here." "Great!", Alice replies. And with that, Alice gets out her pen and Bob gets the contract. "Don't worry", he says, "you can take your crypto-assets back anytime you like - just subject to our cancellation policy. Our annual management fees are also super low and we don't adjust them often". How many holes have to exist for your funds to get stolen? Just one. Why are we taking a powerful offline multi-sig setup, widely used globally in hundreds of different/lacking regulatory environments with 0 breaches to date, and circumventing it by a demonstrably weak third party layer? And paying a great expense to do so? If you go through the list of breaches in the past 2 years to highly credible organizations, you go through the list of major corporate frauds (only the ones we know about), you go through the list of all the times platforms have lost funds, you go through the list of times and ways that people have lost their crypto from identity theft, hot wallet exploits, extortion, etc... and then you go through this custodian with a fine-tooth comb and truly believe they have value to add far beyond what you could, sticking your funds in a wallet (or set of wallets) they control exclusively is the absolute worst possible way to take advantage of that security. The best way to add security for crypto-assets is to make a stronger multi-sig. With one custodian, what you are doing is giving them your cryptocurrency and hoping they're honest, competent, and flawlessly secure. It's no different than storing it on a really secure exchange. Maybe the insurance will cover you. Didn't work for Bitpay in 2015. Didn't work for Yapizon in 2017. Insurance has never paid a claim in the entire history of cryptocurrency. But maybe you'll get lucky. Maybe your exact scenario will buck the trend and be what they're willing to cover. After the large deductible and hopefully without a long and expensive court battle. And you want to advertise this increase in risk, the lapse of judgement, an accident waiting to happen, as though it's some kind of benefit to customers ("Free institutional-grade storage for your digital assets.")? And then some people are writing to the OSC that custodians should be mandatory for all funds on every exchange platform? That this somehow will make Canadians as a whole more secure or better protected compared with standard air-gapped multi-sig? On what planet? Most of the problems in Canada stemmed from one thing - a lack of transparency. If Canadians had known what a joke Quadriga was - it wouldn't have grown to lose $400m from hard-working Canadians from coast to coast to coast. And Gerald Cotten would be in jail, not wherever he is now (at best, rotting peacefully). EZ-BTC and mister Dave Smilie would have been a tiny little scam to his friends, not a multi-million dollar fraud. Einstein would have got their act together or been shut down BEFORE losing millions and millions more in people's funds generously donated to criminals. MapleChange wouldn't have even been a thing. And maybe we'd know a little more about CoinTradeNewNote - like how much was lost in there. Almost all of the major losses with cryptocurrency exchanges involve deception with unbacked funds. So it's great to see transparency reports from BitBuy and ShakePay where someone independently verified the backing. The only thing we don't have is:
ANY CERTAINTY BALANCES WEREN'T EXCLUDED. Quadriga's largest account was $70m. 80% of funds are in 20% of accounts (Pareto principle). All it takes is excluding a few really large accounts - and nobody's the wiser. A fractional platform can easily pass any audit this way.
ANY VISIBILITY WHATSOEVER INTO THE CUSTODIANS. BitBuy put out their report before moving all the funds to their custodian and ShakePay apparently can't even tell us who the custodian is. That's pretty important considering that basically all of the funds are now stored there.
ANY IDEA ABOUT THE OTHER EXCHANGES. In order for this to be effective, it has to be the norm. It needs to be "unusual" not to know. If obscurity is the norm, then it's super easy for people like Gerald Cotten and Dave Smilie to blend right in.
It's not complicated to validate cryptocurrency assets. They need to exist, they need to be spendable, and they need to cover the total balances. There are plenty of credible people and firms across the country that have the capacity to reasonably perform this validation. Having more frequent checks by different, independent, parties who publish transparent reports is far more valuable than an annual check by a single "more credible/official" party who does the exact same basic checks and may or may not publish anything. Here's an example set of requirements that could be mandated:
First report within 1 month of launching, another within 3 months, and further reports at minimum every 6 months thereafter.
No auditor can be repeated within a 12 month period.
All reports must be public, identifying the auditor and the full methodology used.
All auditors must be independent of the firm being audited with no conflict of interest.
Reports must include the percentage of each asset backed, and how it's backed.
The auditor publishes a hash list, which lists a hash of each customer's information and balances that were included. Hash is one-way encryption so privacy is fully preserved. Every customer can use this to have 100% confidence they were included.
If we want more extensive requirements on audits, these should scale upward based on the total assets at risk on the platform, and whether the platform has loaned their assets out.
There are ways to structure audits such that neither crypto assets nor customer information are ever put at risk, and both can still be properly validated and publicly verifiable. There are also ways to structure audits such that they are completely reasonable for small platforms and don't inhibit innovation in any way. By making the process as reasonable as possible, we can completely eliminate any reason/excuse that an honest platform would have for not being audited. That is arguable far more important than any incremental improvement we might get from mandating "the best of the best" accountants. Right now we have nothing mandated and tons of Canadians using offshore exchanges with no oversight whatsoever. Transparency does not prove crypto assets are safe. CoinTradeNewNote, Flexcoin ($600k), and Canadian Bitcoins ($100k) are examples where crypto-assets were breached from platforms in Canada. All of them were online wallets and used no multi-sig as far as any records show. This is consistent with what we see globally - air-gapped multi-sig wallets have an impeccable record, while other schemes tend to suffer breach after breach. We don't actually know how much CoinTrader lost because there was no visibility. Rather than publishing details of what happened, the co-founder of CoinTrader silently moved on to found another platform - the "most trusted way to buy and sell crypto" - a site that has no information whatsoever (that I could find) on the storage practices and a FAQ advising that “[t]rading cryptocurrency is completely safe” and that having your own wallet is “entirely up to you! You can certainly keep cryptocurrency, or fiat, or both, on the app.” Doesn't sound like much was learned here, which is really sad to see. It's not that complicated or unreasonable to set up a proper hardware wallet. Multi-sig can be learned in a single course. Something the equivalent complexity of a driver's license test could prevent all the cold storage exploits we've seen to date - even globally. Platform operators have a key advantage in detecting and preventing fraud - they know their customers far better than any custodian ever would. The best job that custodians can do is to find high integrity individuals and train them to form even better wallet signatories. Rather than mandating that all platforms expose themselves to arbitrary third party risks, regulations should center around ensuring that all signatories are background-checked, properly trained, and using proper procedures. We also need to make sure that signatories are empowered with rights and responsibilities to reject and report fraud. They need to know that they can safely challenge and delay a transaction - even if it turns out they made a mistake. We need to have an environment where mistakes are brought to the surface and dealt with. Not one where firms and people feel the need to hide what happened. In addition to a knowledge-based test, an auditor can privately interview each signatory to make sure they're not in coercive situations, and we should make sure they can freely and anonymously report any issues without threat of retaliation. A proper multi-sig has each signature held by a separate person and is governed by policies and mutual decisions instead of a hierarchy. It includes at least one redundant signature. For best results, 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. History has demonstrated over and over again the risk of hot wallets even to highly credible organizations. Nonetheless, many platforms have hot wallets for convenience. While such losses are generally compensated by platforms without issue (for example Poloniex, Bitstamp, Bitfinex, Gatecoin, Coincheck, Bithumb, Zaif, CoinBene, Binance, Bitrue, Bitpoint, Upbit, VinDAX, and now KuCoin), the public tends to focus more on cases that didn't end well. Regardless of what systems are employed, there is always some level of risk. For that reason, most members of the public would prefer to see third party insurance. Rather than trying to convince third party profit-seekers to provide comprehensive insurance and then relying on an expensive and slow legal system to enforce against whatever legal loopholes they manage to find each and every time something goes wrong, insurance could be run through multiple exchange operators and regulators, with the shared interest of having a reputable industry, keeping costs down, and taking care of Canadians. For example, a 4 of 7 multi-sig insurance fund held between 5 independent exchange operators and 2 regulatory bodies. All Canadian exchanges could pay premiums at a set rate based on their needed coverage, with a higher price paid for hot wallet coverage (anything not an air-gapped multi-sig cold wallet). Such a model would be much cheaper to manage, offer better coverage, and be much more reliable to payout when needed. The kind of coverage you could have under this model is unheard of. You could even create something like the CDIC to protect Canadians who get their trading accounts hacked if they can sufficiently prove the loss is legitimate. In cases of fraud, gross negligence, or insolvency, the fund can be used to pay affected users directly (utilizing the last transparent balance report in the worst case), something which private insurance would never touch. While it's recommended to have official policies for coverage, a model where members vote would fully cover edge cases. (Could be similar to the Supreme Court where justices vote based on case law.) Such a model could fully protect all Canadians across all platforms. You can have a fiat coverage governed by legal agreements, and crypto-asset coverage governed by both multi-sig and legal agreements. It could be practical, affordable, and inclusive. Now, we are at a crossroads. We can happily give up our freedom, our innovation, and our money. We can pay hefty expenses to auditors, lawyers, and regulators year after year (and make no mistake - this cost will grow to many millions or even billions as the industry grows - and it will be borne by all Canadians on every platform because platforms are not going to eat up these costs at a loss). We can make it nearly impossible for any new platform to enter the marketplace, forcing Canadians to use the same stagnant platforms year after year. We can centralize and consolidate the entire industry into 2 or 3 big players and have everyone else fail (possibly to heavy losses of users of those platforms). And when a flawed security model doesn't work and gets breached, we can make it even more complicated with even more people in suits making big money doing the job that blockchain was supposed to do in the first place. We can build a system which is so intertwined and dependent on big government, traditional finance, and central bankers that it's future depends entirely on that of the fiat system, of fractional banking, and of government bail-outs. If we choose this path, as history has shown us over and over again, we can not go back, save for revolution. Our children and grandchildren will still be paying the consequences of what we decided today. Or, we can find solutions that work. We can maintain an open and innovative environment while making the adjustments we need to make to fully protect Canadian investors and cryptocurrency users, giving easy and affordable access to cryptocurrency for all Canadians on the platform of their choice, and creating an environment in which entrepreneurs and problem solvers can bring those solutions forward easily. None of the above precludes innovation in any way, or adds any unreasonable cost - and these three policies would demonstrably eliminate or resolve all 109 historic cases as studied here - that's every single case researched so far going back to 2011. It includes every loss that was studied so far not just in Canada but globally as well. Unfortunately, finding answers is the least challenging part. Far more challenging is to get platform operators and regulators to agree on anything. My last post got no response whatsoever, and while the OSC has told me they're happy for industry feedback, I believe my opinion alone is fairly meaningless. This takes the whole community working together to solve. So please let me know your thoughts. Please take the time to upvote and share this with people. Please - let's get this solved and not leave it up to other people to do. Facts/background/sources (skip if you like):
The inspiration for the paragraph about splitting wallets was an actual quote from a Canadian company providing custodial services in response to the OSC consultation paper: "We believe that it will be in the in best interests of investors to prohibit pooled crypto assets or ‘floats’. Most Platforms pool assets, citing reasons of practicality and expense. The recent hack of the world’s largest Platform – Binance – demonstrates the vulnerability of participants’ assets when such concessions are made. In this instance, the Platform’s entire hot wallet of Bitcoins, worth over $40 million, was stolen, facilitated in part by the pooling of client crypto assets." "the maintenance of participants (and Platform) crypto assets across multiple wallets distributes the related risk and responsibility of security - reducing the amount of insurance coverage required and making insurance coverage more readily obtainable". For the record, their reply also said nothing whatsoever about multi-sig or offline storage.
In addition to the fact that the $40m hack represented only one "hot wallet" of Binance, and they actually had the vast majority of assets in other wallets (including mostly cold wallets), multiple real cases have clearly demonstrated that risk is still present with multiple wallets. Bitfinex, VinDAX, Bithumb, Altsbit, BitPoint, Cryptopia, and just recently KuCoin all had multiple wallets breached all at the same time, and may represent a significantly larger impact on customers than the Binance breach which was fully covered by Binance. To represent that simply having multiple separate wallets under the same security scheme is a comprehensive way to reduce risk is just not true.
Private insurance has historically never covered a single loss in the cryptocurrency space (at least, not one that I was able to find), and there are notable cases where massive losses were not covered by insurance. Bitpay in 2015 and Yapizon in 2017 both had insurance policies that didn't pay out during the breach, even after a lengthly court process. The same insurance that ShakePay is presently using (and announced to much fanfare) was describe by their CEO himself as covering “physical theft of the media where the private keys are held,” which is something that has never historically happened. As was said with regard to the same policy in 2018 - “I don’t find it surprising that Lloyd’s is in this space,” said Johnson, adding that to his mind the challenge for everybody is figuring out how to structure these policies so that they are actually protective. “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
The most profitable policy for a private insurance company is one with the most expensive premiums that they never have to pay a claim on. They have no inherent incentive to take care of people who lost funds. It's "cheaper" to take the reputational hit and fight the claim in court. The more money at stake, the more the insurance provider is incentivized to avoid payout. They're not going to insure the assets unless they have reasonable certainty to make a profit by doing so, and they're not going to pay out a massive sum unless it's legally forced. Private insurance is always structured to be maximally profitable to the insurance provider.
The circumvention of multi-sig was a key factor in the massive Bitfinex hack of over $60m of bitcoin, which today still sits being slowly used and is worth over $3b. While Bitfinex used a qualified custodian Bitgo, which was and still is active and one of the industry leaders of custodians, and they set up 2 of 3 multi-sig wallets, the entire system was routed through Bitfinex, such that Bitfinex customers could initiate the withdrawals in a "hot" fashion. This feature was also a hit with the hacker. The multi-sig was fully circumvented.
Bitpay in 2015 was another example of a breach that stole 5,000 bitcoins. This happened not through the exploit of any system in Bitpay, but because the CEO of a company they worked with got their computer hacked and the hackers were able to request multiple bitcoin purchases, which Bitpay honoured because they came from the customer's computer legitimately. Impersonation is a very common tactic used by fraudsters, and methods get more extreme all the time.
A notable case in Canada was the Canadian Bitcoins exploit. Funds were stored on a server in a Rogers Data Center, and the attendee was successfully convinced to reboot the server "in safe mode" with a simple phone call, thus bypassing the extensive security and enabling the theft.
The very nature of custodians circumvents multi-sig. This is because custodians are not just having to secure the assets against some sort of physical breach but against any form of social engineering, modification of orders, fraudulent withdrawal attempts, etc... If the security practices of signatories in a multi-sig arrangement are such that the breach risk of one signatory is 1 in 100, the requirement of 3 independent signatures makes the risk of theft 1 in 1,000,000. Since hackers tend to exploit the weakest link, a comparable custodian has to make the entry and exit points of their platform 10,000 times more secure than one of those signatories to provide equivalent protection. And if the signatories beef up their security by only 10x, the risk is now 1 in 1,000,000,000. The custodian has to be 1,000,000 times more secure. The larger and more complex a system is, the more potential vulnerabilities exist in it, and the fewer people can understand how the system works when performing upgrades. Even if a system is completely secure today, one has to also consider how that system might evolve over time or work with different members.
By contrast, offline multi-signature solutions have an extremely solid record, and in the entire history of cryptocurrency exchange incidents which I've studied (listed here), there has only been one incident (796 exchange in 2015) involving an offline multi-signature wallet. It happened because the customer's bitcoin address was modified by hackers, and the amount that was stolen ($230k) was immediately covered by the exchange operators. Basically, the platform operators were tricked into sending a legitimate withdrawal request to the wrong address because hackers exploited their platform to change that address. Such an issue would not be prevented in any way by the use of a custodian, as that custodian has no oversight whatsoever to the exchange platform. It's practical for all exchange operators to test large withdrawal transactions as a general policy, regardless of what model is used, and general best practice is to diagnose and fix such an exploit as soon as it occurs.
False promises on the backing of funds played a huge role in the downfall of Quadriga, and it's been exposed over and over again (MyCoin, PlusToken, Bitsane, Bitmarket, EZBTC, IDAX). Even today, customers have extremely limited certainty on whether their funds in exchanges are actually being backed or how they're being backed. While this issue is not unique to cryptocurrency exchanges, the complexity of the technology and the lack of any regulation or standards makes problems more widespread, and there is no "central bank" to come to the rescue as in the 2008 financial crisis or during the great depression when "9,000 banks failed".
In addition to fraudulent operations, the industry is full of cases where operators have suffered breaches and not reported them. Most recently, Einstein was the largest case in Canada, where ongoing breaches and fraud were perpetrated against the platform for multiple years and nobody found out until the platform collapsed completely. While fraud and breaches suck to deal with, they suck even more when not dealt with. Lack of visibility played a role in the largest downfalls of Mt. Gox, Cryptsy, and Bitgrail. In some cases, platforms are alleged to have suffered a hack and keep operating without admitting it at all, such as CoinBene.
It surprises some to learn that a cryptographic solution has already existed since 2013, and gained widespread support in 2014 after Mt. Gox. Proof of Reserves is a full cryptographic proof that allows any customer using an exchange to have complete certainty that their crypto-assets are fully backed by the platform in real-time. This is accomplished by proving that assets exist on the blockchain, are spendable, and fully cover customer deposits. It does not prove safety of assets or backing of fiat assets.
If we didn't care about privacy at all, a platform could publish their wallet addresses, sign a partial transaction, and put the full list of customer information and balances out publicly. Customers can each check that they are on the list, that the balances are accurate, that the total adds up, and that it's backed and spendable on the blockchain. Platforms who exclude any customer take a risk because that customer can easily check and see they were excluded. So together with all customers checking, this forms a full proof of backing of all crypto assets.
However, obviously customers care about their private information being published. Therefore, a hash of the information can be provided instead. Hash is one-way encryption. The hash allows the customer to validate inclusion (by hashing their own known information), while anyone looking at the list of hashes cannot determine the private information of any other user. All other parts of the scheme remain fully intact. A model like this is in use on the exchange CoinFloor in the UK.
A Merkle tree can provide even greater privacy. Instead of a list of balances, the balances are arranged into a binary tree. A customer starts from their node, and works their way to the top of the tree. For example, they know they have 5 BTC, they plus 1 other customer hold 7 BTC, they plus 2-3 other customers hold 17 BTC, etc... until they reach the root where all the BTC are represented. Thus, there is no way to find the balances of other individual customers aside from one unidentified customer in this case.
Proposals such as this had the backing of leaders in the community including Nic Carter, Greg Maxwell, and Zak Wilcox. Substantial and significant effort started back in 2013, with massive popularity in 2014. But what became of that effort? Very little. Exchange operators continue to refuse to give visibility. Despite the fact this information can often be obtained through trivial blockchain analysis, no Canadian platform has ever provided any wallet addresses publicly. As described by the CEO of Newton "For us to implement some kind of realtime Proof of Reserves solution, which I'm not opposed to, it would have to ... Preserve our users' privacy, as well as our own. Some kind of zero-knowledge proof". Kraken describes here in more detail why they haven't implemented such a scheme. According to professor Eli Ben-Sasson, when he spoke with exchanges, none were interested in implementing Proof of Reserves.
And yet, Kraken's places their reasoning on a page called "Proof of Reserves". More recently, both BitBuy and ShakePay have released reports titled "Proof of Reserves and Security Audit". Both reports contain disclaimers against being audits. Both reports trust the customer list provided by the platform, leaving the open possibility that multiple large accounts could have been excluded from the process. Proof of Reserves is a blockchain validation where customers see the wallets on the blockchain. The report from Kraken is 5 years old, but they leave it described as though it was just done a few weeks ago. And look at what they expect customers to do for validation. When firms represent something being "Proof of Reserve" when it's not, this is like a farmer growing fruit with pesticides and selling it in a farmers market as organic produce - except that these are people's hard-earned life savings at risk here. Platforms are misrepresenting the level of visibility in place and deceiving the public by their misuse of this term. They haven't proven anything.
Fraud isn't a problem that is unique to cryptocurrency. Fraud happens all the time. Enron, WorldCom, Nortel, Bear Stearns, Wells Fargo, Moser Baer, Wirecard, Bre-X, and Nicola are just some of the cases where frauds became large enough to become a big deal (and there are so many countless others). These all happened on 100% reversible assets despite regulations being in place. In many of these cases, the problems happened due to the over-complexity of the financial instruments. For example, Enron had "complex financial statements [which] were confusing to shareholders and analysts", creating "off-balance-sheet vehicles, complex financing structures, and deals so bewildering that few people could understand them". In cryptocurrency, we are often combining complex financial products with complex technologies and verification processes. We are naïve if we think problems like this won't happen. It is awkward and uncomfortable for many people to admit that they don't know how something works. If we want "money of the people" to work, the solutions have to be simple enough that "the people" can understand them, not so confusing that financial professionals and technology experts struggle to use or understand them.
For those who question the extent to which an organization can fool their way into a security consultancy role, HB Gary should be a great example to look at. Prior to trying to out anonymous, HB Gary was being actively hired by multiple US government agencies and others in the private sector (with glowing testimonials). The published articles and hosted professional security conferences. One should also look at this list of data breaches from the past 2 years. Many of them are large corporations, government entities, and technology companies. These are the ones we know about. Undoubtedly, there are many more that we do not know about. If HB Gary hadn't been "outted" by anonymous, would we have known they were insecure? If the same breach had happened outside of the public spotlight, would it even have been reported? Or would HB Gary have just deleted the Twitter posts, brought their site back up, done a couple patches, and kept on operating as though nothing had happened?
In the case of Quadriga, the facts are clear. Despite past experience with platforms such as MapleChange in Canada and others around the world, no guidance or even the most basic of a framework was put in place by regulators. By not clarifying any sort of legal framework, regulators enabled a situation where a platform could be run by former criminal Mike Dhanini/Omar Patryn, and where funds could be held fully unchecked by one person. At the same time, the lack of regulation deterred legitimate entities from running competing platforms and Quadriga was granted a money services business license for multiple years of operation, which gave the firm the appearance of legitimacy. Regulators did little to protect Canadians despite Quadriga failing to file taxes from 2016 onward. The entire administrative team had resigned and this was public knowledge. Many people had suspicions of what was going on, including Ryan Mueller, who forwarded complaints to the authorities. These were ignored, giving Gerald Cotten the opportunity to escape without justice.
There are multiple issues with the SOC II model including the prohibitive cost (you have to find a third party accounting firm and the prices are not even listed publicly on any sites), the requirement of operating for a year (impossible for new platforms), and lack of any public visibility (SOC II are private reports that aren't shared outside the people in suits).
Securities frameworks are expensive. Sarbanes-Oxley is estimated to cost $5.1 million USD/yr for the average Fortune 500 company in the United States. Since "Fortune 500" represents the top 500 companies, that means well over $2.55 billion USD (~$3.4 billion CAD) is going to people in suits. Isn't the problem of trust and verification the exact problem that the blockchain is supposed to solve?
To use Quadriga as justification for why custodians or SOC II or other advanced schemes are needed for platforms is rather silly, when any framework or visibility at all, or even the most basic of storage policies, would have prevented the whole thing. It's just an embarrassment.
We are now seeing regulators take strong action. CoinSquare in Canada with multi-million dollar fines. BitMex from the US, criminal charges and arrests. OkEx, with full disregard of withdrawals and no communication. Who's next?
We have a unique window today where we can solve these problems, and not permanently destroy innovation with unreasonable expectations, but we need to act quickly. This is a unique historic time that will never come again.
How To End The Cryptocurrency Exchange "Wild West" Without Crippling Innovation
In case you haven't noticed the consultation paper, staff notice, and report on Quadriga, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.
Many of you have limited time to read the full proposal, so here are the highlights:
Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.
Regular Transparent Audits
Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.
Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
Background and Justifications
Cold Storage Custody/Management After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems: • Funds stored online or in a smart contract, • Access controlled by one person or one system, • 51% attacks (rare), • Funds sent to the wrong address (also rare), or • Some combination of the above. For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program. The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms. • 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective. • The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated. The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II. On The Subject of Third Party Custodians Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems. However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies. There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both. On The Subject Of Insurance ShakePay has taken the first steps into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC. However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example, the insurance agent refused because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange in South Korea, their insurance claim was denied, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.” ShakePay's insurance was only reported to cover their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance. In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework. A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians. On The Subject of Fractional Reserve There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds. There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past. Proof of Reserves/Transparency/Accountability Canadians need to have visibility into the backing on an ongoing basis. The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users. Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit. The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided. Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense. Hot Wallet Management The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets. However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process. A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage. Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
Current Draft Proposal
(1) Proper multi-signature cold wallet storage. (a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet. (b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time). (c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. (d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds. (e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers. (2) Regular and transparent solvency audits. (a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row. (b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored. (c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process. (d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify. (e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible. (3) Protections for hot wallets and transactions. (a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets. (b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy. (c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage. (d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange. (e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.
Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized. The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges. The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.
Disclaimer: I am not and have never been affiliated with any of the mentioned parties in a private or professional matter. Presumably in an attempt to smear a local competitor, Hayden Otto inadvertently publishes irrefutable on-chain proof that he excluded non-BCH retail revenue to shape the "BCH #1 in Australia" narrative.
Scroll down to "Proof of exclusion" if you are tired of the drama recap.
Scroll down to "TLDR" if you want a summary.
In September 2019, BitcoinBCH.com started publishing so called monthly "reports" about crypto retail payments in Australia. They claimed that ~90% of Australia's crypto retail revenue is processed via their own HULA system and that ~92% of all crypto retail revenue happens in BCH. They are aggregating two data sources to come up with this claim. One is TravelByBit (TBB) who publishes their PoS transactions (BTC, LN, ETH, BNB, DASH, BCH) live on a ticker. The other source is HULA, a newly introduced POS system (BCH only) and direct competitor to TBB run by BitcoinBCH.com - the same company who created the report. Despite being on-chain their transactions are private, not published and not verifiable by third parties outside BitcoinBCH.com Two things stood out in the "reports", noted by multiple users (including vocal BCH proponents):
The non-BCH parts must have tx excluded and the report neglects to mention it (the total in their TBB analysis does not match what is reported on the TBB website.)
The BCH part has outliers included (e.g. BCH city conference in September with 35x the daily average)
Hayden Otto's reaction
In direct response to me publishing these findings on btc, Hayden Otto - an employee at BitcoinBCH.com and the author of the report who also happens to be a moderator of /BitcoinCash - banned me immediately from said sub (source). In subsequent discussion (which repeated for every monthly "report" which was flawed in the same ways as described above), Hayden responded using the same tactics: "No data was removed"
"The guy is straight out lying. There is guaranteed no missing tx as the data was collected directly from the source." (source)
"Only data I considered non-retail was removed"
"I also had these data points and went through them to remove non-retail transactions, on both TravelbyBit and HULA." (source)
He admits to have removed non-BCH tx by "Game Ranger" because he considers them non-retail (source). He also implies they might be involved in money laundering and that TBB might fail their AML obligations in processing Game Ranger's transactions (source). The report does not mention any data being excluded at all and he still fails to explain why several businesses that are clearly retail (e.g. restaurants, cafes, markets) had tx excluded (source). "You are too late to prove I altered the data"
"[...] I recorded [the data] manually from https://travelbybit.com/stats/ over the month of September. The website only shows transactions from the last 7 days and then they disappear. No way for anyone to access stats beyond that." (source)
Proof of exclusion
I published raw data as extracted from the TBB site after each report for comparison. Hayden responded that I made those numbers up and that I was pulling numbers out of my ass. Since he was under the impression that
"The website only shows transactions from the last 7 days and then they disappear. No way for anyone to access stats beyond that." (source)
he felt confident to claim that I would be
unable to provide a source for the [missing] data and/or prove that that data was not already included in the report. (source)
Luckily for us Hayden Otto seems to dislike his competitor TravelByBit so much that he attempted to reframe Bitcoin's RBF feature as a vulnerability specific to TBB PoS system (source). While doublespending a merchant using the TBB PoS he wanted to prove that the merchant successfully registered the purchase as complete and thus exposed that the PoS sales history of TBB's merchants are available to the public (source), in his own words:
"You can literally access it from a public URL in the Web browser. There is no login or anything required, just type in the name of the merchant." (source)
As of yet it is unclear if this is intentional by TBB or if Hayden Ottos followed the rules of responsible disclosure before publishing this kind of data leak. As it happens, those sale histories do not only include the merchant and time of purchases, they even include the address the funds were sent to (in case of on-chain payments). This gives us an easy method to prove that the purchases from the TBB website missing in the reports belong to a specific retail business and actually happened - something that is impossible to prove for the alleged HULA txs. In order to make it easier for you to verify it yourself, we'll focus on a single day in the dataset, September 17th, 2019 as an example:
Hayden Otto's report claims 20 tx and $713.00 in total for that day (source)
The TBB website listed 40 tx and a total of $1032.90 (daily summary)
Paste the associated crypto on-chain address 17MrHiRcKzCyuKPtvtn7iZhAZxydX8raU9 in a blockchain explorer of your choice, e.g like this. This proves that a transfer of funds has actually happened.
I let software aggregate the TBB statistics with the public sale histories and you'll find at the bottom of this post a table with the on-chain addresses conveniently linked to blockchain explorers for our example date. The total of all 40 tx is $1032.90 instead of the $713.00 reported by Hayden. 17 tx of those have a corresponding on-chain address and thus have undeniable proof of $758.10. Of the remaining 23, 22 are on Lightning and one had no merchant history available. This is just for a single day, here is a comparison for the whole month.
TBB wo. Game Ranger
TBB according to Hayden
The usual shills will respond in a predictive manner: The data must be fake even though its proof is on-chain, I would need to provide more data but HULA can be trusted without any proof, if you include outliers BCH comes out ahead, yada, yada. But this is not important. I am not here to convince them and this post doesn't aim to. The tx numbers we are talking about are less than 0.005% of Bitcoin's global volume. If you can increase adoption in your area by 100% by just buying 2 coffees more per day you get a rough idea about how irrelevant the numbers are in comparison. What is relevant though and what this post aims to highlight is that BitcoinBCH.com and the media outlets around news.bitcoin.com flooding you with the BCH #1 narrative are playing dirty. They feel justified because they feel that Bitcoin/Core/Blockstream is playing dirty as well. I am not here to judge that but you as a reader of this sub should be aware that this is happening and that you are the target. When BitcoinBCH.com excludes $1,000 Bitcoin tx because of high value but includes $15,000 BCH tx because they are made by "professionals", you should be sceptical. When BitcoinBCH.com excludes game developers, travel businesses or craftsmen accepting Bitcoin because they don't have a physical store but include a lawyer practice accepting BCH, you should be sceptical. When BitcoinBCH.com excludes restaurants, bars and supermarkets accepting Bitcoin and when pressed reiterate that they excluded non-retail businesses without ever explaning why a restaurant shouldn't be considered reatil, you should be sceptical. When BitcoinBCH.com claims the reports have been audited but omit that the data acquisition was not part of the audit, you should be sceptical. I expect that BitcoinBCH.com will stop removing transactions from TBB for their reports now that it has been shown that their exclusion can be provably uncovered. I also expect that HULA's BCH numbers will rise accordingly to maintain a similar difference. Hayden Otto assumed that nobody could cross-check the TBB data. He was wrong. Nobody will be able to disprove his claims when HULA's BCH numbers rise as he continues to refuse their release. You should treat his claims accordingly. As usual, do your own research and draw your own conclusion. Sorry for the long read.
BitcoinBCH.com claimed no transactions were removed from the TBB dataset in their BCH #1 reports and that is impossible to prove the opposite.
Hayden Otto's reveals in a double spend attempt that a TBB merchant's sale history can be accessed publicly including the merchant's on-chain addresses.
(For example,) this table shows 40 tx listed on the TBB site on Sep 17th, including their on-chain addresses where applicable. The BitcoinBCH.com report lists only 20 tx for the same day.
(Most days and every months so far has had BTC transactions excluded.)
(For September, TBB lists $10,502 yet the report only claims $3,737.
Just spent about 12 hours figuring out my tax liabilities with bitcoin.tax. Here is how it went...
I have been reading more lately about all the US tax liabilities that can come into play in the crypto world and have started worrying about how much I would owe for 2017. I was starting to lose some sleep on the matter and finally decided to organize all of my activity once and for all. I figured I'd write this post for other people who might want to find out what I have learned in this process. I am filing in the US, but some of this might apply to people in other countries as well. If you have just bought and HODL'd then it will probably be much simpler for you. But if you have done ICOs and any trading and are worried about this stuff, don't worry too much. Its totally possible to get yourself organized with a little bit of work. Background Bought my first ETH in Feb '17 from Coinbase and since then:
Have traded probably 50 different tokens on 10 different exchanges
Have participated in 21 ICOs
Have received Airdropped tokens
Have sold some and withdrawn profits to my bank account
The Tools The best place to get started is bitcoin.tax Referral Link Normal Link I signed up for the 1 year plan for $19.95 (they also accept crypto) and believe me its worth every penny. You can use it for free, but are limited to 100 items (I ended up having > 1500). It really does almost everything for you, so you don't have to worry about figuring out the cost basis yourself. The only time USD was involved was buying via coinbase, everything else was handled as a token to token trade. Microsoft Excel or Google Sheets is a must if you are doing any trading on the non-supported exchanges because you might have to massage the data into the correct format. Etherscan Unfortunately, for some trades and the ICOs, I had to go directly to Etherscan to track down the data. DeltaBalances This is a lifesaver for tracking trades made on ED. I wasn't able to get the export feature working, but copy/pasting the table into Excel was fine. Html Table to CSV If you are having trouble copy/pasting table data this comes in handy. You can just copy the raw table HTML from Chrome Dev Tools and get a nice CSV. Exchanges I am only going to list the exchanges I use and how I was able to get the data into bitcoin.tax. But regardless of the method, make sure you verify all the data that was imported. The system did a bad import on my Bitfinex data and I had to wipe it and reimport because it was missing a bunch of rows. All the importing is done on the trading tab of bitcoin.tax. Some exchanges require you to download a .csv file from the exchange website, and some have direct API access. Just follow the tutorials on bitcoin.tax for each exchange. The Easy Ones Bitcoin.tax supports API data pulls for these exchanges: Bitfinex, Coinbase, GDAX, Kraken. For these, I still recommend going to the exchanges and downloading a copy of your history for your personal records. You need to login to the exchange and download trade history and then use bitcoin.tax's import tool for these: Binance, Bittrex, Poloniex The Tough Ones Trades made on Etherdelta present a bit of a challenge. There is no direct import into bitcoin.tax so you will have to manually compile a CSV and import it to their system. They give you a template to follow with the required data and it will require a bit of "massaging" to get the ED data to the correct format. For this is it extremely helpful to use DeltaBalances. For each wallet you use you will need to check the trade history and go back a sufficient number of days to cover your trading history. Warning, it might take a long time for this process to finish and it isn't 100% reliable. When I ran it, it needed to download > 200MB worth of data for the 260 days I went back. My suggestion is to run it a few times to validate the results. You will need to run it for each wallet you use to trade on ED. Once you get the results, you can try copy/paste the table into Excel and then format the columns to match. Liqui was the biggest pain in the ass of them all. If you traded a lot on Liqui, be prepared for some pain because they have no export and only show you the history of 1 pair at a time (and only the last 30 trades!). Liqui has over 250 trading pairs so if you forgot what you traded, you will tediously have to go through each pair to check. I couldn't bear this, so I ended up coding a custom script to query all 250 trading pairs and dump out the data for me, then I had to import that into Excel and format it to match the bitcoin.tax template. Kucoin wasn't too bad. They don't have an export function, but you can copy paste the tables into Excel and massage the data there. I did a few trades with OasisDEX but when I went there it didn't have any of my history, so I had to manually cobble that together from looking at Etherscan. Luckily it was only a few trades or else this would have been very tedious. ICOs Like I mentioned, I participated in something like 20 ICOs this last year. Unfortunately I have no records of any of them. In bitcoin.tax I handled these as just another trade. In order to track down the ICOs I participated in, I was forced to use Etherscan and go through my whole transaction history looking for them. In order to add the trades manually in bitcoin.tax you need the Date, the # of ETH you spent and the # of tokens you received. It's not super difficult, but just very tedious. One that threw me for a curve ball was RedPulse. This was a NEO ICO, but adding a trade manually doesn't yet support NEO as a currency. The workaround for this is putting it into a CSV and importing it that way. In fact, if I was to do this again, I would have built a CSV for all the ICOs and just imported it that way rather than inputting them one-by-one. Airdrops I treated airdrops as "Gifts/Tips" under the income tab. I had to find these through Etherscan. Verifying the data In order to verify that all seemed right and there are no problems, there are two things that I was working toward:
No unmatched trades -- On the reports tab, you can filter by "unmatched trades". Ideally you won't have any of these. If there are some, you may need to do some more digging to see why
Closing position report -- On the reports tab, your closing position report should match as closely as possible to your current holdings in Blockfolio.
Conclusion Overall, although there was some tedious parts, this was a really good exercise. Going through my entire history gave me some great insight on how my strategies played out (ICOs were great / I suck at trading). As far as the taxes themselves, it turned out to be a lot more than I was expecting, but considering the gains I am not too sad. Going into this next year I am going to make some changes. First of all, I will probably stop trading as much. It just wasn't that successful for me and created a lot of work and taxes on top of that. Secondly, I really want to try and stay away from exchanges that don't (or don't plan to) offer history exports. Third, I will probably hold most of my unsold ICOs for at least a year so as not to be liable for short term gains. Lastly, I will keep better records as I go along so I don't have to do so much digging for next tax season. I hope this can help some of you guys figure this out and I would love to hear any additional tips from those of you who have gone through this. Edit: A couple other hiccups that I just remembered. Some tokens change their symbol, this can cause some havoc, I had done some trades in MyriadCoin as MYR then it changed to something else and it got all wacky. Updating the old token symbol to the new one seemed to do the trick. Also, to add to the Liqui woes, I had bought some BCAP way back in the day, but it got delisted so there is no way I found through the UI to get that information. The only way I found out I had actually done that trade was that the script I coded iterated through every possible trading pair and only then it was uncovered. Edit #2: I got a request for the liqui ruby script
Cardano (ADA) was created by a team led by Charles Haskinson, who previously worked on Ethereum, but left the number of cryptocurrency developers before the ICO. In 2014, he and Jeremy wood formed IOHK. In the same year, a group of Japanese investors signed a 6-year contract with this firm to create a blockchain project based on the use of algorithms for independent execution of exchange operations with different types of assets. https://preview.redd.it/2i65etfaxmt31.png?width=308&format=png&auto=webp&s=29c9fbda1552a59c33452e60afb1bd1b8d6c3d48 The platform was named after Gerolamo Cardano, an Italian mathematician, engineer, philosopher and astrologer. The Ada token was composed of 3 letters of the scientist's surname so that the name of the world's first female programmer-Ada Lovelace - turned out. The currency ICO was held in several stages in 2015-2017. as a result, $62 million was collected during operations only within the ADA Coin system. Until 2019, the developers plan to launch a number of decentralized applications and services for the implementation of smart contracts. In the beginning, the team warned that the low speed of operations (only 5-10 transactions per second) can affect the rate of cryptocurrency. Experts plan to increase the speed of transactions by introducing the system of bandwidth nodes, the Protocol of which will be written in the programming language Haskell. Also prevent the success of the project could reputation of the author of the idea of Charles Hoskinson, who left his previous job without explanation. But the cost of the coin was not affected by these factors, the prospects for the project are good. Cardano Presentation The success of the project is also facilitated by the fact that it is engaged in 3 institutions performing different functions:
IOHK is responsible for the construction of the siege system. This institution is engaged in the technical side of the platform, its improvement.
The Cardano Foundation is located in Switzerland. Responsible for the control of the organization and its development, standardization and protection of technologies.
Emurgo is based on the Isle of man. The organization was created to promote the company's products in the market.
The goal of the creators of the project is a sustainable system that is able to attract investment and thereby support itself.
MAIN FEATURES OF CARDANO COIN
Cardano (ADA) is a cryptocurrency whose task is to secure smart contracts between users on terms beneficial to both parties. Such principles of asset exchange will be the basis for further development of digital currencies. The Ada token has many pluses, but there are also minuses.
Democracy in the control of transactions and mining.
Scientific approach in the development of the mathematical block of the platform, allowing to have a good traffic generation.
High degree of protection against hacker attacks.
Protection of users from unscrupulous partners.
Using test software.
Incomplete platform management.
No protocols for long-term planning.
Insufficient control over the data provided by users.
HOW TO MINE CARDANO
The Cardano platform is based on the Proof of Stake algorithm. This means that the chances of a miner to create a block are directly proportional to the assets available to him, the results of work on solving a mathematical problem do not matter.
Advantages of Cardano mining:
No expensive equipment is required.
Don't need a lot of electricity.
WHERE AND HOW TO BUY CARDANO ADA CRYPTOCURRENCY
Cardano coins are traded in pairs with other cryptocurrencies on most exchanges (Finance, Bitrix, Http, Upbit, Bithumb, Cryptopia, etc.). There are exchangers (Prostocash, Xchange, 60 cek) and Exmo exchange, where you can buy Cardano cryptocurrency for rubles and other Fiat currency, after exchanging it for bitcoins or ethers. You can pay in exchangers via PayPal or Bank card. Purchase instructions ADA:
To buy in exchange for Bitcoin or Etherium.
Register on the exchange and install a wallet with Cardano support.
Exchange purchased bitcoins or ethers for Cardano.
Withdraw ADA to wallet.
Purchase on Binance Crypto exchanges provide the ability to store funds, but it is better to withdraw tokens to the wallet immediately after purchase. If this is not possible, you should take care of the security of your account. Asset storage is better not to trust little-known exchanges.
Until March 2018, the only e-wallet in which ADA could be stored was Daedalus. There are versions for Windows, Mac and Linux. The wallet is suitable for anonymous transactions. The Cardano team plans to issue a debit card that can be replenished through this e-wallet. Daedalus installation instructions:
Find the Get started tab and go to Deadalus wallet.
Click on Download, download the app.
Open the file, configure the installation settings.
https://preview.redd.it/tyomywqj2nt31.png?width=400&format=png&auto=webp&s=d0cf94f05c85c2205abde505831e5aeaca03dd8e In March, it became possible to store ADA tokens in the Centra wallet. This means that the currency can be withdrawn using the Centra card in 36 million terminals around the world. Web wallets are popular because of convenience. Many sites offer to download them to store ADA, but this should not be done, so as not to fall for the tricks of scammers. On the official website of the company there is no data on cooperation with owners of online wallets.
WHAT ARE THE PROSPECTS FOR THE ADA CRYPTOCURRENCY
Given the big plans of Cardano developers, the forecast for 2020 regarding this cryptocurrency is good. If the team implements its ideas to expand the use of coins, ADA may become popular in the market after a while, despite the fall in user confidence in cryptocurrencies. Road map of Cardano The author of the platform Hoskinson said that the work on scaling the data will not yield results until 2019. Developers want to introduce innovative technologies into their project, their creation and research takes a lot of time. By the end of the year, it is planned to standardize the protocols and improve the reliability of the system, but the achievement of these goals may be delayed due to the complexity of the ideas. At this stage of operation of the platform, information about the use of high technologies in support of Cardano's work is not proven. Cryptocurrency faces competition among firms providing such services. It interferes with its development. Specialists working on improving Litecoin and Dash use similar principles when conducting transactions. Ripple plans to become an element combining currencies recognized as official and digital assets, making it more attractive to investors. The exclusivity of the project is that its development is scientifically justified. But this is not a significant advantage, as most traders do not want to spend time figuring out the details of the technical side of the project, and are interested in its functionality. If the Cardano project team fulfills its plans by the end of the year, the prospect of this currency is quite good. The success of ADA depends on how convenient the token will be to use.
Cryptocurrency Terms And Definitions - Common Crypto Words To Know
The blockchain community is not left out when it comes to the use of jargon and phrases. The use of words that look strange to those who are not involved in crypto is totally inevitable. It’s definitely going to be difficult for anyone not in this space to understand words like “ERC20, ICO or gas. So in order to help such people out, we have made a list of the most common cryptocurrency terms and definitions. Please sit back and enjoy your ride. Cryptocurrency Terms And Definitions One can categorize these terms into various parts. First of all, we will deal with general cryptocurrency terms and definitions. Blockchain Blockchains are distributed ledgers which are secured by cryptography. Everyone has access to read the information on every blockchain which means they are essentially public databases but the data update can only be done by the data owners. In the case of blockchains, data doesn’t remain on a single centralized server, they are copied across hundreds of thousands of computers worldwide. Projects such as Ethereum, Vechain, EOS etc. fall under this class of technology. Mining: The means of trying to ‘solve’ the next available block. One needs huge amounts of computer processing power to carry this out effectively. There is always a reward for doing this. Mining rig: A specially designed computer that processes proof-of-work blockchains such as Ethereum. They consist of multiple high-end graphic processors (GPUs) so as to maximize their processing power. Node: This is a computer that has a copy of the blockchain and is working to keep it in a good shape. PoW: The full meaning of this is Proof-of-work. The Ethereum network currently makes use of this algorithm. PoS: Its full meaning is Proof-of-stake. It is the proposed future algorithm for Ethereum. Those that own ETH will be able to lock up all or a portion of their ether for a given amount of time in order to ‘vote’ and generate network consensus instead of mining in its current form. Stakeholders will get rewards in form of ETH by doing so. Fork: This takes places when a certain blockchain splits into two different chains. This usually happens in the crypto space when new ‘governance rules’ are infused into the blockchain’s code. Software wallet: A crypto-currency storage that exists purely on a computer as software files. You can generate these kinds of wallets for free from diverse sources. MyEtherWallet (MEW) is one of the most popular sources around. Hardware wallet: A device that one can securely keep cryptocurrency. People often say that these wallets are the most secure way to store cryptocurrency. Examples of the most common hardware wallet models around are Ledger Nano S and Trezor. Cold storage: This is a way of moving your cryptocurrency from an online wallet to an offline one, as a means of safekeeping them from hack. There are a lot of ways to carry this out. Some methods that are commonly used include: · Using a hardware wallet to store your cryptocurrency. · By printing out the QR code of a software wallet and keeping it somewhere which is safe. · You can also move the files of a software wallet onto an external storage device such as USB drive and keeping it somewhere safe. Trading Related Cryptocurrency Terms And Definitions Exchange: These are websites where people trade (buy and sell) their cryptocurrencies. Some of the popular crypto exchanges we have around include Binance, Poloniex, Bittrex etc. Market order / market buy / market sell: A sale or purchase which is made on an exchange at the current price. A market buy acquires the cheapest Bitcoin available on the order book while a market sell fills up the most high-priced buy order on the books. Limit order / limit buy / limit sell: These are orders which are placed by traders to buy or sell a cryptocurrency when the price reaches a certain amount. They are pretty much like ‘for-sale’ signs you see on goods. Sell wall / buy wall: Cryptocurrency traders are able to see the current limit buy and sell points using a depth chart. The chart’s graphical representation is very much like a wall. FIAT: Refer to a government-issued currency. An example is the US dollar. Whale: A person who owns huge amounts of cryptocurrency. Margin trading: This is an act of increasing the intensity of a trade by using your existing coins. It is very risky for an inexperienced trader to partake in this. Stay safe!! Going long: This is a margin trade that gives profit if the price goes up. Going short: It is a margin trade that gives profit if the price goes down. Bullish: Being optimistic that the price of cryptocurrency is going to increase. Bearish: This is an expectation that the price of cryptocurrency is going to decrease. ATH: This simply means All-Time-High. This is the highest point that has been reached by a particular coin or token. Take for instance, Bitcoin’s ATH is about $20,000 and this was achieved around December 2017 and January 2018. Altcoin: A word used to qualify other cryptocurrencies which is not Bitcoin. Examples of altcoins are Ripple, NEO, EOS, Vechain, Electroneum etc. Tokens: These are ‘currency’ of projects which are hosted on the ethereum network. They raise money by issuing their own tokens to the general public. Tokens have a significant use in the project's ecosystem. Examples of tokens are Enjin Coin (ENJ), Zilliqa (ZIL), OmiseGO (OMG), Augur (REP) etc. ICO: The full meaning is Initial Coin Offering. This is synonymous to an IPO in the non-crypto world. Startups give out their own token in exchange for Bitcoin or ether. Shilling / pumping: An act of advertising another cryptocurrency. It is mostly done in a way that tricks as many people as possible into believing that a coin or token will get to a higher price in the future. Market Cap: This is the total value of a cryptocurrency. To calculate this, one has to multiply the total supply of coins by the current market price. You can get a run-down of several cryptocurrency projects on Coinmarketcap. Stable coin: This is a cryptocurrency which has an extremely low volatility. You can use a stable coin to trade against the overall crypto market. Arbitrage: A situation where a trader takes advantage of a difference in the price of the same coin / token on two different exchanges. FOMO: Simply means Fear Of Missing Out. That overwhelming feeling that one needs to get on board when there is a massive rise in the price of a commodity. This is also applicable in the crypto space. FUD: Fear, Uncertainty, and Doubt. It is a baseless negativity which is spread intentionally by someone or a group of people who want the price of cryptocurrency to decrease. FUDster: A person who spreads FUD. Pump And Dump: This happens when an altcoin gets a ton of attention, leading to a massive increase in price, and likewise followed by a big price crash of that altcoin. ROI: Return on Investment. The percentage profit a trader makes on an initial investment (i.e. A 100% ROI simply indicates that a trader doubled his money). TA: Trend Analysis or Technical Analysis. A way of examining current coin charts so as to make predictions for the next market movement. Next, we will be moving on to crytocurrency terms and definitions that are ethereum related. Dapp: Decentralized Application. It is an application that uses a decentralized peer-to-peer network like Ethereum smart contract as its back-end code. Bagholder: A person who still holds on to a particular altcoin despite having a pump and dump crash. Smart contract: This is a code that is deployed onto the Ethereum blockchain, it often helps with the direct interaction of how money flows from one point to another. The Flippening: A future event showing the capacity of Ethereum’s market cap (or some other cryptocurrency) surpassing Bitcoin’s market cap, making Ethereum the most ‘valuable’ crypto-currency. Gas: It is a measurement of the amount of processing needed by the ethereum network to execute a transaction. More complex transactions like deploying a smart contract onto the network requires more gas than sending ether from one wallet to another which is obviously a simpler operation. Gas price: This is the amount of ether an initiator of a transaction is willing to spend for each gas unit on a transaction. The higher the gas price, then the faster the processing of the transaction. Wei: It is the smallest denomination of ether. Gwei: This is a denomination of ether (ETH). Gwei is the unit for measuring gas prices. 1 Ether = 1,000,000,000 Gwei (109). MEW: MyEtherWallet is a site where users can generate ethereum wallets for free. We also have a handful of cryptocurrency terms and definitions that are memes. See some of them below; Hodl: People use this word when signifying that a person is keeping his coins / tokens for a long period of time. A couple of years back, someone on a Bitcoin forum made a post with a typo HODL in place of HOLD. Ever since then, this term has become one of the most popularly used term in crypto. Mooning: In crypto, this term comes to play when the price of cryptocurrencies move up astronomically. Lambo: This is highly synonymous with crypto. You can't leave out this word when discussing about cryptocurrency terms and definitions. This is the car we’re all goona buy when crypto makes us rich. This is gentlemen: People use this phrase when pointing out positive things that are currently taking place in the cryptosphere. Now that you are conversant with some of the commonly used cryptocurrency terms and definitions, you can now go out there and showcase your new crypto vocabulary to the world.
Is China Cooking Up the Biggest Cryptocurrency Exchange Bubble or Rewriting the Industry?
https://preview.redd.it/04m8ii3z4cd11.png?width=736&format=png&auto=webp&s=3e0f91a9fe9a8e1a18544b5fc0082eb838826b72 When I asked our production assistant "are you following FCoin," she gave me a perplexed look and replied, "what? Filecoin?" Apparently, FCoin was not on her radar. I don't fault her. Nowadays, with over hundreds of crypto exchanges around, an exchange that is barely a month old doesn't sound like something that warrants paying attention to. When I typed "FCoin" into the Google search bar, the search engine autocorrected to "pcoin." However, this exchange in its infancy has already become the focus of the Chinese crypto circle and is either writing its own legend or will eventually reveal itself as one of the biggest scams in crypto history. I heard about FCoin for the first time on Jun 12th. Members of the Chinese crypto circle had started talking about this new entrant to the game. The new kid on the block was not only already billing itself as the biggest exchange by volume, having accumulated over 28 billion yuan within a 24 hour period on the 15th day after launch, but had even gone as far as to publicly announce that its trading volume surpassed the sum of the trading volumes of the second to the seventh biggest exchanges, including major players Binance and Huobi. The first reaction among the crypto crowd was to question the authenticity of their data. Even as I pen this article, their trading data can still not be found on popular crypto data sources such as coinmarketcap.com or Block Hero. Fake trades, that is, the trading of cryptocurrencies between two accounts owned by the same exchange, is an open secret across the exchange industry, especially in China. Everyone is doing it but no one owns up to it. Some industry insiders have told me that, in their opinion, at least 85% of the trading volume at the top exchanges is “fake,” a shocking number if there is any validity to the “allegation” in an industry that is trying to build a trustworthy reputation for itself. I was unable to find a way to independently verify the number, however when I asked Bobby Lee, the founder of BTC China, about FCoin’s trading volume, his first reaction was, "I wouldn't trust any volume numbers from cypto-exchanges.” FCoin’s story has since evolved beyond the issue of trading volume manipulation. Soon afterwards, Huobi announced that they plan to ally with 100 exchanges and adopt the same model as FCoin. Then CZ from Binance (the world’s second largest crypto-exchange if FCoin’s numbers are to be believed) said sarcastically on Weibo, the closest thing in China to Twitter, that they are ready to work with even 1000 exchanges in order to emulate the model. Apparently, it isn’t just a story of someone cooking the trading number as the sector’s biggest players already found it a new threat. https://preview.redd.it/sbqfny0b5cd11.png?width=740&format=png&auto=webp&s=ee6fa8ae5be681f917f144cf1f83bf337e2d2932 The cryptocurrency exchange industry is evolving at a super-fast pace. Mt. Gox, remember them? They were the first-generation exchange and used to be the sole player dominating the bitcoin trading business. Their reign ended when their entire network sank after a major hack. In China, BTC China was the first to initiate the cryptocurrency exchange business, however, were surpassed by OKCoin and Huobi within a couple of years. Last year, Binance moved to the head of the class in months. On December 16, 2017, they sent out a tweet saying: “5 months to reach Number One in the WORLD.” Then Binance saw their 1st quarter earnings in 2018 surpass those of 148-year-old Deutsche Bank. https://preview.redd.it/tj8qf9vc5cd11.png?width=740&format=png&auto=webp&s=7d2051c7c1c033876d6b9a9f3d4100daf97a984b However things have since been changing even faster, with the time between events, no longer counted in months but rather in days. It took FCoin roughly one tenth of the time that it took Binance to move into the number one position, assuming their data is correct. Zhang Jian, FCoin’s founder and former CTO of Huobi, said in a WeChat group that even members of their own team were surprised that things were happening that quickly. The team had to work day and night to constantly upgrade the system, as the trading volumes the system had to handle kept growing exponentially. Now let’s talk about FCoin’s model. What kind of magic is attracting that volume of trades? FCoin’s model is called “trans-fee mining.” They didn’t really invent it. Besides FCoin, several other cryptocurrency exchanges had made their appearance around the same time trying out that model, for example Dragonex, yet the model deployed in each case varies in the details. In FCoin’s case, users can trade cryptocurrencies and facilitate the trades by paying transaction fee like any other exchanges. However the users will receive the full rebate of the transaction fee in the form of FT, FCoin’s token. Every day, FCoin will reward dividends to all the FT token holder. The dividend is based on the transaction fee income accumulated in the last 24 hours. At the beginning FCoin took 80% of all the transaction fees as dividends to the user. Now under certain condition, the entire 100% is returned to the user. https://preview.redd.it/mk5iqqda7cd11.png?width=740&format=png&auto=webp&s=24dc5a43b9f4eb5c112c50df266f7311aeb5491a The user not only earns FT tokens, but also gains dividends simply by holding onto the FT without the heavy investment in machines and electricity that is needed to mine bitcoin. If FT’s price can be held at a certain level and the transaction fee revenue stream is stable, the user can make money if they hold onto their FT long enough. It sounds lucrative to many people. Users rushed in and kept on selling and buying, not for the purpose of changing positions, but purely to create the trade that allows them to receive or mine FT coins. Zhang said now their biggest challenge is to calculate all the dividends on a daily basis as it has now become so massive. According to their official website, about 170 BTC is distributed to users as a dividend today and the number was over 1500 BTC the day before. I guess the trading volume is pretty volatile. https://preview.redd.it/3rfdy93c7cd11.png?width=740&format=png&auto=webp&s=1584dd4d259474465dd681c2e12be20b48cfaa90 During the interview with the press, Zhang Jian explained that his idea behind this new model follows Satoshi Nakanomo’s original design for bitcoin. He said his fundamental theory is to build a community to support the trading eco-system rather than simply seeking to maximize profits like other centralized exchanges. Besides receiving a dividend, the FT holder can also participate in the system’s management. Zhang gained a lot of support in the crypto circle especially from the people who made money on Fcoin. However, many questions remain. https://preview.redd.it/t3kpjfbe7cd11.png?width=740&format=png&auto=webp&s=b5aa7ce6e598954b80c6ae4bd429b4aa9cfa477a Firstly, the question of the fake trades: Zhang Jian says that the FCoin system can prevent fake trades as they simply wouldn’t have the money to reward FT coin holders with the dividends. Although not everyone buys that answer, since some people think FCoin can still fiddle with the volume number by trading between its own accounts and give their own accounts FC coins, generating a lot of dividends, most of which is just returned to FCoin after the fact. Given that FT is not on blockchain now makes it hard to track how they are distributed. Zhang said FT will be put on the chain eventually. Still it is possible that FT is a “fake it until you make it” case. However, FCoin may not have a strong motivation to overstate the data for sustainability reasons, something which I will explain later. https://preview.redd.it/30h37k2g7cd11.png?width=627&format=png&auto=webp&s=cde3c8162e9306c15485cd27bdaebbaf38781ff5 Secondly, CZ from Binance said in a statement that he believes FCoin is simply another kind of ICO. The users pay FCoin the transaction fee using BTC or ETH and receive FT coins in return. At the end of the day, it is not really any different than using BTC or ETH to purchase FT. And, when I hear of valuations of FCoin at 50 billion dollar, it does seem off the wall, especially considering the firm’s short history. Upon hearing that Binance doubted the evaluation, Zhang laughed it off and retorted in return that Binance was an ICO project as well at an interview. https://preview.redd.it/j8qi26uh7cd11.png?width=740&format=png&auto=webp&s=f2cd1a6179877ed56b3a2885d4497df9b6ce1aec The third issue is sustainability. One has to question whether the transaction fee income is enough to support the run rate, and as to whether FCoin’s model, as it is currently structured, can support itself for much longer. There is a limited supply of FT coins, 10 billion in total. According to FCoin’s announcement, 51% of them will be rewarded to users through the “trans-fee mining.” At the time of this writing, FCoin’s official site indicated that more than 28 million FT had been mined the previous day. Let’s assume on average that 25 million FT are mined per day. That means, it will take only 204 days to mine all the FT needed to award users through the “trans-fee mining” program. What will happen after that? The FT holder can still receive the dividends but will no longer receive any FT coin for the transaction fee they paid. The return, in that case, will be significantly lower. This could become a cycle, with another exchange suddenly showing up with a more lucrative mining program, instigating a massive migration to the new player. And when that player runs out of tricks, the next one could come along. That is already happening: on Jun 25th, Bit-z launched its platform token BZ and started a similar “trans-fee mining” program. They claimed that within the first 12 hours, the transaction volume had hit 27 billion yuan, if the data is to believed.
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