The Risks of Investing in Bitcoin - The Money Magnet
Appendix – Prediction of cryptocurrency prices
Wrapped Bitcoin on Tezos - tzBTC - Unleash your Bitcoin on ...
ONTHE! ORIGINSOF BITCOIN
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𝕮𝖔𝖎𝖓𝖇𝖆𝖘𝖊 𝕾𝖚𝖕𝖕𝖔𝖗𝖙 𝕹𝖚𝖒𝖇𝖊𝖗 +1-855-937-4225
Unlike private cryptocurrency wallets that gives you total freedom to use your bitcoins or ether as you see fit, Coinbase has placed some limitations with regards to spending and receiving digital currencies. Under Section 6.4 of the user agreement, for example, Coinbase reserves the right to monitor your account and keep track of where you send and receive cryptocurrency to make sure you're not using it for purposes that fall under what's prohibited. "Prohibited Use and Prohibited Business," which can be found under Appendix 1 of the user agreement, covers a wide array of activities and businesses, such as online abuse, gambling, high-risk businesses, illicit drugs, pornography, and pyramid schemes, to name a few. Violating this can result in the sudden suspension or termination of your Coinbase account . While these prohibitions seem reasonable on the surface, It's still worrisome as it technically prohibits us from using our bitcoins on businesses Coinbase deems high risk. This is a slippery slope in and of itself since cryptocurrency exchanges can very well fall under this umbrella. So if you transfer bitcoins to an exchange site like Binance to purchase other less popular cryptocurrencies like monero, Coinbase can potentially suspend or terminate your account without notice and freeze any in-app assets you may have in the process. First, the “trading pair” (or, “currency pair”) is the product being traded. In the above screenshot the product is ETH, and the “quote currency” is USDThis means that traders are buying and selling the cryptoasset ethereum, priced in dollars .The order book shows all the bids and asks at a given time. A “bid” is the price at which a buyer will buy, and an “ask” is the price at which a seller will sell. The order book also shows the aggregate amount of asks and bids (supply and demand) at a given price, called the “market size.” The “depth chart” is another way to visualize the order book, showing cumulative bid and ask orders over a range of prices. Coupled with volume — or, the total amount traded over a given time period — the depth chart provides a good way to measure “liquidity.” Liquidity describes how easy it is to turn an asset into cash. For instance, if ethereum suddenly saw a massive sell-off, there might not be enough buyers, or enough “liquidity,” for sellers to sell to. Lastly, the “mid-market price” is the price between the best “ask” price and the best “bid” price. It can also be defined as the average of the current bid and ask prices. Coinbase operates both an order book exchange, called the Global Digital Asset Exchange (GDAX), and a brokerage, called Coinbase. More advanced traders (including small institutional players, like cryptoasset hedge funds and family offices) buy and sell cryptoassets on GDAX and determine the mid-market price. Coinbase (the brokerage) then allows retail investors to buy and sell cryptoassets at these mid-market prices, and charges a fee on top. In practice, retail investors can buy and sell directly from Coinbase’s brokerage, like they might buy a stock from Scottrade or Charles Schwab. Coinbase’s brokerage range from roughly 1.5% to 4.0% depending on the user’s payment method; due to increased risk, credit cards come with higher fees than bank transfers. Traders on GDAX pay significantly lower fees. Of note, Coinbase’s brokerage buys cryptoassets from GDAX, instead of from an outside exchange. This gives the company a secure in-house source of liquidity. Given how often exchanges are hacked or otherwise compromised, this is quite important; Coinbase’s brokerage doesn’t have to rely on anyone else for liquidity. There are a lot of exchanges on the market that aren’t as trustworthy as they claim to be, which is one of the reasons I am writing this Coinbase review — to show you how legitimate Coinbase is, among other things. So, is Coinbase legit? Well, the truth is, Coinbase is probably as legit as it gets. Just to operate in 30 states of the U.S. alone, it has over 40 different licenses. This ensures their practices are legal and that they handle your money with integrity. If you’re reading this Coinbase review, the first thing you need to know is whether or not you can use this exchange in your region. Coinbase can be used in many countries to do transactions like sending, receiving or storing funds. However, Coinbase’s buy and sell features are only available in 32 developed countries around the world. So, be sure to check whether you can use Coinbase from your country before you attempt to sign up.
Breaking: TaaS team has strong links to suspected Ponzi Scheme
UPDATE: Due to overwhelming community demand, we have decided to release the entirety of the TaaS report for free to further substantiate our findings. You can download it here: https://www.icoalert.com/special-ico-alert-report-taas This is going to be a long post, but the information contained within is of great importance to the cryptocurrency community. My name is Rob, and I'm the Founder of ICO Alert, a comprehensive list of all active and upcoming cryptocurrency Initial Coin Offerings. You may know me from my posts about the launch of ICO Alert, or about that time someone accidentally sent 32 ETH to the ICO Alert donation address. We recently launched an ICO Report feature that provides in-depth analysis of upcoming ICOs so that you can determine which are worth investing in. During our analysis of TaaS, a tokenized closed-end fund, we stumbled upon some shocking connections. We found that many of the TaaS team members are directly linked to Bitup, a suspected ponzi scheme. In addition, we found huge holes in the cryptographic audit TaaS plans to employ that could jeopardize the sustainability and solvency of the entire fund. We usually charge a small fee (0.2 ETH / $10) for our reports, but decided that we cannot in good conscience keep the most shocking revelations from the TaaS Report behind a paywall. We believe it is our obligation to the community to distribute this information since the entire TaaS fund may be a scam. You can still purchase the 32 page detailed report here if you'd like, but many of the main revelations are posted below: The TaaS team and their links to Bitup, a High Yield Investment Platform (aka Ponzi Scheme) Our research has identified deep connections between the four founding members of the TaaS project — Ruslan Gavrilyuk, Konstantin Pysarenko, Maksym Muratov, and Dimitri Chupryna — and the #bitup investment platform. Several aspects of the Bitup platform resemble strongly characteristics and activities of High Yield Investment Platforms, more commonly known Ponzi Schemes. Bitup advertises fixed daily returns that are not dependent on market or investment performance; users are also offered a percentage of the total investment deposited into the fund by new users they refer. These are the typical characteristics of a ponzi scheme. Individuals who have been involved in the cryptocurrency space for any meaningful duration will quickly identify the Bitup platform as one of many HYIP (High Yield Investment Programs) Ponzi Schemes developed to defraud new entrants into unregulated markets. Konstantin Pysarenko Konstantin Pysarenko, the Vice President of the TaaS project, lists experience in founding ‘several startups around the world in food manufacturing, geological oil and gas surveying, and international aviation sales’. Our research struggled to verify these claims as only previously discussed Geo–Earth Resources and Bitup were listed on Mr. Pysarenko’s Linkedin page; deeper inquiry, however, did yield some further information regarding Mr. Pysarenko’s previous work experience. According to both Mr. Pysarenko’s profile on the TaaS Executive Team and Linkedin page, Konstaintin graduated from the University of Buckingham in 2011 with a degree in Entrepreneurship. Leveraging this information, our research uncovered two profiles of Mr. Pysarenko that appear to align with his given educational timeline and stated work experience5, both written in the first person (indicating Mr. Pysarenko himself prepared the profiles) — one while studying at the University of Buckingham, the other subsequent to the completion of his studies. Here Mr. Pysarenko indicates that his experience includes publishing, perishable import/export, printing services, cigarette manufacture, and some involvement with aviation sales via his father’s business. Food manufacturing, as stated in Konstantin’s TaaS bio, appears to consist of flour exports and tea imports to and from Africa; no mention is made of experience in geological oil and gas surveying, and international aviation sales appear to be based on involvement with Mr. Pysarenko’s family business. No verifiable indication is given that any of these positions were held at any point in the past or currently in the capacity of a founder, and in the case of aviation sales we believe there is a strong indication that Mr. Pysarenko was explicitly not a founder in any capacity. Ruslan Gavrilyuk Mr. Gavrilyuk’s bio on the TaaS Executive Team indicates experience ‘found- ing and managing projects in geosciences, mobile money solutions, oil and gas operations, precious metal mining, sports and fashion’. Our research has been unable to verify any of these assertions; Mr. Gavrilyuk’s LinkedIn page indicates (excluding TaaS) only founding involvement with Geo–Earth Resources and Bitup that are not indicated on either organization’s website or anywhere else. We find the total lack of verifiable connections between any of Mr. Gavrilyuk’s stated experience or credentials to be one the most alarming revelations uncovered from our research. Bitup Financial Analysis In July 2016 Bitup began publishing reports outlining their portfolio alloca- tions, trading activities, and general analysis of the cryptocurrency space. These documents list the coins on Bitup traded on the Poloniex market, and some (not all) give the opening and closing dates of particular trades. Documents also list the total monthly portfolio allocation for each coin traded. Our researchers analyzed the daily volume in BTC for those coins on trades where entry or exit dates are provided and identified those dates on which volume was so low that calculations for the total value of the portfolio allocation for a particular coin could be calculated by generously assuming the full 24 hour daily volume17 represented only the trade conducted by Bitup. This calculation does not give an accurate estimate of the actual AUM of the Bitup trading portfolio, but it does enable us to understand (assuming the portfolio allocation statistics are correct) the maximum possible value of the portfolio on a given date. Deeper analysis of the Bitup Financial statements can be found in the full report under Appendix B: Bitup Financial Analysis. This analysis indicates that as late October 9th, 2016, Bitup had no more than $60,000 AUM across their entire trading portfolio. In particular, a trade opened by Bitup traders on Nautiliscoin (NAUT) on October 9th accounted for 20% of the total portfolio allocation for the month of October. Volume on Poloniex for the entire 24 hour period of October 9th was 18.82 BTC, and the Bitcoin closing price was $614.62. Attributing all trading volume for the 24 hours of October 9th to Bitup (a wildly generous assumption), the total daily volume USD equivalent comes to $11,567.15. If this value represents 20% of the Bitup trading portfolio, the total value of the portfolio can be calculated at $57,835.74. Again, this uses a nearly impossible assumption of attributing all of the day’s volume to one trade, so the true AUM is very likely substantially less than what has been calculated here. If the four founding members of the TaaS platform are as deeply involved with the development and operation of the Bitup platform as our research suggests, at the very least questions are raised about the ability of the Bitup, and therefore TaaS, trading team to manage investments and trading strategies involving 1,000 times the AUM they managed at Bitup, as they will be at TaaS. More broadly, any one team member’s involvement with this type of cryptocur- rency HYIP Ponzi scheme should be cause for concern. With four co–founders involved, it is difficult to deny at very least the appearance that TaaS is an extension or evolution of the Bitup project, with remarkably higher AUM and the substantial investment management challenges that entails. Risks of slippage on trades (when acquiring large positions rapidly drive up the price of the asset, limiting potential profitability) and a simple lack of liquidity sufficient to exit positions at profitable prices represent just a few of those challenges. Trading Methodology & Cryptographic Audit Our analysis revealed several inconsistencies and very few indications that the author of the TaaS white paper or the TaaS team at large have an understanding of the challenges associated with successfully investing millions of dollars of AUM. Our analysis leads us to believe that the Cryptographic Audit technology be- ing developed by TaaS is being leveraged to obfuscate and deflect questions regarding the true nature of the TaaS trading methodology, while also representing a grave risk to the profitability of the fund. Nevertheless, we believe the Cryptographic Audit technology is the only software actually in development by the TaaS team and represents the only value investors can realistically expect to gain from the TaaS project. The Cryptographic Audit section of the TaaS whitepaper very strongly appears to have been prepared by a different individual than the rest of the document; the formatting is substantially improved, the charts and diagrams are filled with information (in contrast to the glaring lack of information in the ‘Trading Methodology’ section), the English grammar and vocabulary are substantially improved, and the use of footnotes is liberal and meaningful. We believe the proposed Auditable Exchange Accounts development and implementation represent extraordinary risks to the success of the TaaS trading methodology and the project as a whole. A system that reveals to anyone, at any time, the specific trading actions being performed by any investor or fund with a substantially large portfolio is nothing short of an invitation for every enterprising individual investor, other trading outfits,experienced algorithmic trader, or youngster with a Poloniex bot and copious free time to create trading strategies developed exclusively to siphon money from the TaaS fund as effectively as can possibly be devised. The risks of front running predicted positions, pumps and dumps during accumulation, or any number of other actions competing traders can use to negatively impact the TaaS methodology (whatever it turns out to be) are dangerously and shockingly amplified if every detail of every trade is made available in the way being described in the Auditable Exchange Accounts implementation. Leaving aside any other improprieties identified through our research, this oversight alone indicates to our analysis a risk so great to invested capital and the project as a whole that we could never in good conscious recommend purchasing TaaS tokens or becoming involved with the TaaS project in any capacity. Closing While this is obviously a tremendous amount of information to process and digest, there is a significant amount of information not included here, but included in the full report, that further substantiates these claims and also links the TaaS team members to a mysterious Geo-Earth Resources based in Lagos, Nigeria. The implications of this report are shocking, and one that we do not take lightly. We have completed this report as quickly as possible due to the severity of the matter, and have decided to release this significant portion of the report to the community, as we believe we have an obligation to do so. Relevant Links: https://www.icoalert.com/ https://www.icoalert.com/special-ico-alert-report-taas Sources: https://www.linkedin.com/in/ruslan-gavrilyuk/ https://www.linkedin.com/in/konstantin-pysarenko-b1a40b51/ http://geo-earth.biz/index.html https://bitup.io/ https://www.sec.gov/investoalerts/ia_virtualcurrencies.pdf https://bitup.io/faq https://bitup.io/terms https://www.linkedin.com/in/nixoid/ https://www.linkedin.com/in/andriydubetsky/ http://idcee.org/p/andriy-dubetsky/ http://en.pcg-conference.com.ua/speakers/view/65/
Open Financial System Open financial system is defined as being available to everyone and not controlled by a single entity.
✔︎ Pretty easy
Innovation or Efficiency Gains New or improved technology which helps solve a problem, creates a new market, addresses an unmet market need, or creates value for network participants.
✔︎ Again, pretty easy, Nimiq is bringing a huge leap forward in terms of accessibility and integration of cryptocurrencies.
Economic Freedom A measure of how easy it is for members of a society to participate in the economy. The technology enables individuals to have more control over their own wealth and property, or the freedom to consume, produce, invest, or work as they choose.
✔︎ Basic requirement of any real cryptocurrency, easily fulfilled by Nimiq.
Equality of Opportunity This technology is accessible to use by anyone with a smartphone or access to the internet. It contributes to the broader mission of building the on-ramps to Finance 2.0.
✔︎ Nimiq is the most accessible crypto on the market right now, you don't even have to install something to begin using it or mining it.
Decentralization The network is public, decentralized, and enables trustless consensus.
〜 The architecture of Nimiq is decentralized however the hashrate is clearly not right now.
Security & Code Assessment of engineering and product quality.
✔︎ Nimiq team has done everything it could to ensure the quality control of the code.
Source Code Open-source code, well-documented peer-review, and testing by contributors separate from the initial development team on GitHub, etc.
〜 Of course Nimiq is open-source but the documentation is still weak, the good thing is that it's being redone.
Prototype There is a working alpha or beta product on a testnet or mainnet.
✔︎ Well, the Nimiq Network is live.
Security & Code Demonstrable record of responding to and improving the code after a disclosure of vulnerability, and a robust bug bounty program or third party security audit.
Team Assessment of short-term operating expectations and decision making.
✔︎ You can even see them on video hehe.
Founders and Leadership Able to articulate vision, strategy, use cases or drive developmental progress. Has a track record of demonstrable success or experience. If information is available, Coinbase will apply "know your client" standards to publicly visible founders or leaders.
✔︎ The profiles of the team are all known and easily checked.
Engineering Assessment of the engineering team and their track record of setting and achieving deadlines.
✔︎ They released the product which is a damn good track record in a sector full of vaporwares.
Business & Operations History of interacting with the community, setting a reasonable budget and managing funds, and achieving project milestones. Thoughtful cash management is a key driver of the project's long term viability.
✔︎ There has been some "lean" periods in terms of communication but overall the team has never stopped interacting with us. When it comes to cash management the dev team should be a model for everyone else with its last transparency report.
Specialized Knowledge and Key People The project leadership is not highly centralized or dependent on a small number of key persons. Specialized knowledge in this field is not limited to a small group of people.
〜 Let's be honest: it is right now, that said the project protocol isn't even 6 months old.
Governance Assessment of long-term operating expectations and decision making.
White Paper Justifies the use case for a decentralized network and outlines project goals from a business and technology perspective. While a white paper is important for understanding the project, it is not a requirement.
〜 There is the "high level" whitepaper of the ICO however it doesn't really explain in detail how Nimiq works.
Scalability Assessment of a network's potential barriers to scaling and ability to grow and handle user adoption.
✔︎ Like pretty much every project, that's what Robin is currently working on by the way.
Roadmap Clear timeline with stages of development, reasonable project milestones, or built-in development incentives.
✔︎ We should have the roadmap soon™️.
Network Operating Costs The barriers to scaling the network have been identified, or solutions have been proposed or discussed. The resource consumption costs for validators and miners are not the main deterrents to participation.
✔︎ Yes, the team has been considering second layer solutions like Lightning Network or Liquidity Network.
Practical Applications There are examples of real-world implementation or future practical applications.
Type of Blockchain The asset is a separate blockchain with a new architecture system and network, or it leverages an existing blockchain for synergies and network effects
Regulation Can Coinbase legally offer this asset?
✔︎ I'm not a lawyer but I guess it can
US Securities Law The asset is not classified as a security using Coinbase's Securities Law Framework.
〜 Hard to say, they have this checklist and the fact that some NIM were given against NET which were distributed through an ICO makes it kind of blurry
Compliance Obligations The asset would not affect Coinbase or Coinbase's ability to meet compliance obligations, which include Compliance Obligations, Anti-Money Laundering (AML) program and obligations under government licenses in any jurisdiction (e.g. Money Transmitter Licenses).
✔︎ Conversion from NET to NIM went through a KYC specifically for that.
Integrity & Reputational Risk Would listing the asset be inconsistent with Coinbase policy?
✔︎ I don't see why.
User Agreement The asset, network, application or fundamental nature of the project does not constitute a Prohibited Business under Appendix 1 of the user Agreement.
✔︎ I read it and it's doesn't.
Liquidity Standards How liquid is this asset?
〜 Weak liquidity right now.
Global Market Capitalization How does the market capitalization compare to the total market capitalizations of other assets?
〜 Weak capitalization.
Asset Velocity Trade velocity, or turnover, is a significant part of market capitalization. This is a measure of how easily the asset can be converted to another asset.
〜 Again, weak velocity.
Circulation For service or work tokens, new supply is created through consensus protocols. If the supply is capped, then a material amount of the total tokens should be available to the public.
✔︎ It's available.
Global Distribution Where is this asset available to trade?
Total # of Exchanges The number of exchanges that support the asset.
Geographic Distribution The asset is not limited to a single geographic region and is available to trade on decentralized exchanges.
Community Activity Dedicated forums are available where developers, supporters, users, and founders can interact and build a community and offer transparency into the project. The team provides regular updates or is responsive to feedback.
✔︎ Yes it has.
External Stakeholders There are investments from venture firms or hedge funds which have experience working with crypto companies or projects. The project has corporate partnerships, joint ventures, or dedicated consortiums.
〜 It doesn't as far as I know.
Change in Market Capitalization The market capitalization has grown after the network has activated, demonstrating increased demand for the asset after the project's launch.
〜 Sadly not.
Nodes Growing # of nodes on the underlying blockchain. The project has a globally distributed node network, meaning operating nodes are not contained in a single country or geographic region.
Economic Incentives Are the economic structures designed to incentivize all parties to act in the best interest of the network?
✔︎ It's a PoW coin so yes.
Type of Token It is a service, work, or hybrid token. Tokens backed by fiat or other physical assets are categorized as US securities and will not be considered at this time.
✔︎ It's not backed by anything but the work done to generate them.
Token Utility There is utility from obtaining, holding, participating, or spending the token. The team identifies a clear and compelling reason for the native digital asset to exist (i.e. the main purpose is not fundraising).
✔︎ Nimiq is a general payment protocol.
Inflation (Money Supply) There is an algorithmically programmed inflation rate which incentivizes security and network effects. Or, if the total supply is capped, then a majority of the tokens should be available for trade when the network launches.
Rewards and Penalties There are mechanisms (such as transaction fees) which incentivize miners, validators, and other participants to exhibit 'good' behavior. Conversely, there are mechanisms which deter 'bad' behavior.
Security There is a focus on stringent security protocols and best practices to limit scams, hacks, and theft of funds.
✔︎ The smart-contract of the ICO was audited and they didn't lose the fund yet so I guess it's secure haha.
Participation Equality Best efforts by the team to allow a fair distribution of tokens (i.e. setting initial individual purchase caps to limit the risk of small number of investors from taking a majority of the supply).
✔︎ The number of NIM distributed through NET is only 7% in any case.
Team Ownership The ownership stake retained by the team is a minority stake. There should be a lock-up period and reasonable vesting schedule to ensure the team is economically incentivized to improve the network into the future.
Transparency The team should be available and responsive to questions or feedback about the product, token sale, or use of funds across multiple forums.
✔︎ See the transparency report.
Total Supply The team should sell a fixed percentage of the total supply, and participants should know the percentage of total supply that their purchase represents, or have a clear understanding of the inflation rate.
✔︎ All informations are available freely online.
Ethics or Code of Conduct White paper or project website should have an ethical or professional code of conduct.
Square is an SMB focused payment company. The company provides merchants with a POS terminal and charges a fee per transaction to process payments.
The payments are then routed through merchant acquirers JP Morgan Chase or Wells Fargo.
Square sits between the merchant and the merchant acquirer, as illustrated in this chart. The important thing to keep in mind when looking at this chart: the merchant acquirer is the merchant's bank, while the issuer bank is the cardholder's bank. In between them is Visa/Mastercard/Amex.
Why Square has been successful
Ten years ago, merchants looking to accept card payment contended with credit checks, complicated pricing and a lack of integration between POS terminals and business software.
Square simplified the onboarding process, established a flat 2.75% fee for most transactions (on average it is 2.94%) and introduced business applications for integration with its payment hardware.
JPMorgan Chase and Wells Fargo wholesale their payment processing capabilities to Square, which earns a margin of 1.06% on each transaction.
For an illustrative $100, Square charges the merchant $2.94 and pockets $1.06.
Why Square will ultimately fail
Traditional payments players are increasingly targeting SMBs as their core businesses, serving large corporates, slow down.
Merchant acquirers can go direct to the merchant and undercut Square. In other words, they can charge less than 2.94% per transaction. This is the result of scale: platform costs per transaction are low for players such as JPMorgan Chase or Wells Fargo or First Data, as they are processing hundreds, if not trillions of dollars of transactions per year. Square processes somewhere around USD 60-70 billion.
Remember, Square charges the merchant 2.94% and pockets 1.06%; the merchant acquirer takes the difference, ie 1.88%. While Square is unprofitable charging 2.94% per transaction, a merchant acquirer can come in, sell direct to small merchants, and increase its own margins by taking half of Square's 1.06% margin - this would result in 2.94%-0.53%=2.41% transaction fee to the end merchant.
These fee differences are nontrivial for “large” merchants (ie >USD 500k Gross Payment Volume per annum), which have grown from 16% of Square's GPV in Q1 2017 to 20% in Q1 2018. If I'm processing USD 1 million per year, I could save c.USD 5k per annum under the above scenario by switching away from Square.
Hardware companies and merchant acquirers are rolling out feature-rich products with transparent pricing and a focus on a simple onboarding process.
Verifone is rolling out its line of Carbon/Engage POS terminals over Q2-Q4 2018. These will connect to a marketplace where merchants are able to download business applications.
Ingenico is rolling out Axium in H2 2018, an SMB focused solution that will allow merchants to download business apps.
First Data is digitalising its credit check process. One of Square's selling points is its quick onboarding process, which can take seconds. Traditionally, a merchant had to go to a bank branch to open an account with a merchant acquirer, and had to submit to a credit check process, which could take days. First Data, a large merchant acquirer, is bringing this process online and shortening the decision making to just a few seconds.
Moderation of bitcoin mania
Square's stock has been on a tear ever since the company announced testing and eventually support for Bitcoin on the Cash app.
Square does NOT make money buying/selling you bitcoin. Check the last quarter's "bitcoin revenue" and "bitcoin costs" figures. To better understand the mechanics behind this, look at this webpage at the section "How much does buying and selling Bitcoin cost?". Very simply, Square sells you Bitcoin at the mid-quote (ie between the bid and ask); Square loses the spread when you buy, but earns the spread when you sell. There's a reason they only allow you to purchase USD10k of Bitcoin per week.
Final thoughts If you have any questions, please don't hesitate to shoot my way. I might not have been clear or comprehensive. The payment processing chart I linked at the start might be new, for example. I don't have a price target for you. But there are clear catalysts coming up in H2 2018. Verifone/Ingenico will roll out their new POS platforms, which merchant acquirers such as First Data and Worldpay will take up. Unless these are major flops (it's possible), the roll outs will be negative for Square. I am not short Square but might initiate a position in the coming days. Price movements can be large on this name, so I stayed away, but the stock really is getting expensive now in my view. Short appendix: quotes from conference/earnings calls transcripts
“One of the best things that ever happened to Verifone was those competitors [ie Square ...] What they've done is they've created a fair amount of anxiety [... Acquirers] need a strategic partner to help them be more and more competitive and capture a bigger amount of revenue stream than what has been traditionally basic payment acquiring, an area that is not growing particularly well" - Verifone CEO, Q1 2018 results conf call
“Increasingly, [SMBs are] about the total end-to-end solution for that business, not just to accept the payment but also to help them run their business. Square has done a really good job in that [...] For us that is a massive opportunity. It's why we got well ahead of the curve [and] created Carbon. [...] it's a way that these acquirers and banks can compete against what Square has” – Verifone CEO, Barclays Emerging Payments Forum 2017
“The first thing that you'll see happen will be inside the bank branch where our JV partners are moving to largely eliminate physical sign-up forms and converting to digital sign-up within the branch. And the credit decision process, which for some customers can take a few days, will be significantly accelerated; in many cases, shortened to just seconds. That's Part 1 of the digitization process. The next component, the ultimate self-service solution, will be to allow merchants to log on to the bank's website, apply for a merchant account online and receive a credit decision. I'm happy to say that each of our partners has committed to these initiatives and that they're in various stages of implementation.” – First Data CEO, Q4 17 conf call
Statement on regulatory framework for virtual asset portfolios managers, fund distributors and trading platform operators
The Securities and Futures Commission (SFC) notes with concern the growing investor interest in gaining exposure to virtual assets via funds and unlicensed trading platform operators in Hong Kong. The SFC has identified significant risks associated with investing in virtual assets and these are set out below. In order to address these risks, the SFC is issuing guidance on the regulatory standards expected of virtual asset portfolio managers and fund distributors. The SFC is also exploring a conceptual framework for the potential regulation of virtual asset trading platform operators. Background Technology is transforming the landscape of the financial industry. Distributed ledger technology offers an anonymous way to digitally record ownership of virtual assets and facilitates peer-to-peer trading. A virtual asset is a digital representation of value, which is also known as "cryptocurrency", "crypto-asset" or "digital token". The polymorphous and evolving features of virtual assets mean that they may be, or claim to be, a means of payment, may confer a right to present or future earnings or enable a token holder to access a product or service, or a combination of any of these functions. Public interest in virtual assets has grown exponentially around the world since the creation of the most widely-known digital token, Bitcoin, in 2008. At its peak in early January 2018, the market capitalisation of Bitcoin and other digital tokens was estimated at more than US$800 billion1. Over 2,000 different digital tokens are currently traded around the world with an estimated total market capitalisation of over US$200 billion. Although the aggregated market capitalisation of digital tokens has fallen substantially from its peak, trading volumes remain substantial. There is also a growing demand for funds which invest in virtual assets. While virtual assets have not posed a material risk to financial stability2, there is a broad consensus among securities regulators that they pose significant investor protection risks. The regulatory response to these risks varies in different jurisdictions, depending on the regulatory remit, the scale of the activities and their impact on investor interests and whether virtual assets are deemed financial products suitable for regulation. Under existing regulatory remits in Hong Kong, markets for virtual assets may not be subject to the oversight of the SFC if the virtual assets involved fall outside the legal definition of "securities" or "futures contracts" (or equivalent financial instruments). Therefore, investors who trade in virtual assets through unregulated trading platforms or invest in virtual asset portfolios which are managed by unregulated portfolio managers do not enjoy the protections afforded under the Securities and Futures Ordinance (SFO), such as requirements which ensure safe custody of assets and fair and open markets. If platform operators and portfolio managers are not regulated, their fitness and properness, including their financial soundness and competence, have not been assessed, and their operations are not subject to any supervision. Risks associated with investing in virtual assets Virtual assets pose significant risks to investors. Some of these risks are inherent in the nature and characteristics of the virtual assets themselves and others stem from the operations of platforms or portfolio managers. Valuation, volatility and liquidity Virtual assets are generally not backed by physical assets or guaranteed by the government. They have no intrinsic value. There are currently no generally accepted valuation principles governing certain types of virtual assets. Prices on the secondary market are driven by supply and demand and are short-term and volatile by nature. The volatility faced by investors may be further magnified where liquidity pools for virtual assets are small and fragmented. Accounting and auditing Among the accounting profession, there are no agreed standards and practices for how an auditor can perform assurance procedures to obtain sufficient audit evidence for the existence and ownership of virtual assets, and ascertain the reasonableness of the valuations. Cybersecurity and safe custody of assets Trading platform operators and portfolio managers may store clients' assets in hot wallets (ie, online environments which provide an interface with the internet). These can be prone to hacking. Cyber-attacks resulting in the hacking of virtual asset trading platforms and thefts of virtual assets are common. Victims may have difficulty recovering losses from hackers or trading platforms, which can run to hundreds of millions of US dollars. Virtual asset funds face a unique challenge due to the limited availability of qualified custodian solutions. Available solutions may not be totally effective. Market integrity Unlike regulated stock exchanges, the market for virtual assets is nascent and does not operate under a set of recognised and transparent rules. Outages are not uncommon, as are market manipulative and abusive activities, and these all result in investor losses. Risk of money laundering and terrorist financing Virtual assets are generally transacted or held on an anonymous basis. In particular, platforms which allow conversions between fiat currencies and virtual assets are inherently susceptible to higher risks of money laundering and terrorist financing. Where criminal activities are involved, investors may not be able to get back their investments as a result of law enforcement action. Conflicts of interest Virtual asset trading platform operators may act as agents for clients as well as principals. Virtual asset trading platforms may facilitate the initial distribution of virtual assets (eg, initial coin offerings), facilitate secondary market trading, or both, as in a traditional exchange, alternative trading system or securities broker. If these operators are not under the purview of any regulator, it would be difficult to detect, monitor and manage conflicts of interest. Fraud Virtual assets may be used as a means to defraud investors. Virtual asset trading platform operators or portfolio managers may not have conducted sufficient product due diligence before allowing a virtual asset to be traded on their platforms or investing in a virtual asset for their portfolios. As a result, investors may become victims of fraud and lose their investments. Existing regulatory regime The SFC has issued a number of circulars clarifying its regulatory stance on virtual assets3. Where virtual assets fall under the definition of "securities" or "futures contracts", these products and related activities may fall within the SFC's ambit. The SFC also reminded intermediaries in a circular dated 1 June 20184 about the notification requirements under the Securities and Futures (Licensing and Registration)(Information) Rules if they intend to provide trading and asset management services involving crypto-assets. The SFC has undertaken a series of actions against those who may have breached its rules and regulations when carrying out activities related to virtual assets. These include providing regulatory guidance, issuing warning and compliance letters and taking regulatory action5. However, many virtual assets do not amount to "securities" or "futures contracts". Moreover, managing funds solely investing in virtual assets which do not constitute "securities" or "futures contracts" does not amount to a "regulated activity" as specified under the SFO. Similarly, the operators of platforms which only provide trading services for virtual assets not falling within the definition of "securities" do not fall within the jurisdiction of the SFC. Notwithstanding the above, if firms are engaged in the distribution of funds which invest in virtual assets, irrespective of whether these assets constitute "securities" or "futures contracts", these firms are required to be licensed by or registered with the SFC. I. Regulatory approach for virtual asset portfolio managers and fund distributors In the application of the SFC's regulatory powers, many investors in virtual assets are left unprotected by the conventional approach where financial products are classified as "securities" or "futures contracts". The SFC has decided to adopt a way forward which will bring a significant portion of virtual asset portfolio management activities into its regulatory net. The overarching principles and regulatory standards of the regulatory framework are summarised below. (a) Virtual asset portfolio managers (i) Scope of supervision The following types of virtual asset portfolio managers will be subject to the SFC's supervision: Firms managing funds which solely invest in virtual assets that do not constitute "securities" or "futures contracts" and distribute the same in Hong Kong These firms will typically require a licence for Type 1 regulated activity (dealing in securities) because they distribute these funds in Hong Kong. The management of these funds will also be subject to the SFC's oversight through the imposition of licensing conditions; and Firms which are licensed or are to be licensed for Type 9 regulated activity (asset management) for managing portfolios in "securities", "futures contracts" or both To the extent that these firms also manage portfolios which invest solely or partially (subject to a de minimis requirement6) in virtual assets that do not constitute "securities" or "futures contracts", such management will also be subject to the SFC's oversight through the imposition of licensing conditions. (ii) Regulatory standards In order to afford better protection to investors, the SFC considers that all licensed portfolio managers intending to invest in virtual assets should observe essentially the same regulatory requirements7 even if the portfolios (or portions of portfolios) under their management invest solely or partially in virtual assets, irrespective of whether these virtual assets amount to "securities" or "futures contracts"8. For this purpose, the SFC has developed a set of standard terms and conditions (Terms and Conditions) which captures the essence of the Existing Requirements, adapted as needed to better address the risks associated with virtual assets. For example, only professional investors as defined under the SFO should be allowed to invest in any virtual asset portfolios (subject to the de minimis requirement). These Terms and Conditions are principles-based and should generally be appropriate to be imposed on virtual asset portfolio managers as licensing conditions, subject to minor variations and elaborations depending on the business model of the individual virtual asset portfolio manager. Some of the key terms and conditions are set out in Appendix 1, "Regulatory standards for licensed corporations managing virtual asset portfolios". (iii) Licensing process Licence applicants and licensed corporations are required to inform the SFC if they are presently managing or planning to manage one or more portfolios that invest in virtual assets9. Upon being so informed, the SFC will first seek to understand the firm's business activities. If the firm appears to be capable of meeting the expected regulatory standards, the proposed Terms and Conditions will be provided to the firm (where applicable) and the SFC will discuss them with the firm and vary them in light of its particular business model so as to ensure that they are reasonable and appropriate. If a licence applicant does not agree to comply with the proposed Terms and Conditions, its licensing application will be rejected. Similarly, if an existing licensed corporation with a VA portfolio does not agree to comply with the proposed Terms and Conditions, it will be required to unwind that portfolio within a reasonable period of time. After the licence applicant or licensed corporation has agreed with the proposed Terms and Conditions, they will be imposed as licensing conditions. Failure to comply with any licensing condition is likely to be considered as misconduct under the SFO. This will reflect adversely on its fitness and properness and may result in the SFC taking regulatory action. (b) Virtual asset fund distributors Firms which distribute funds that invest (solely or partially) in virtual assets in Hong Kong will require a licence or registration for Type 1 regulated activity (dealing in securities). As such, these firms are required to comply with the Existing Requirements, including the suitability obligations, when distributing these funds. Given the significant risks posed to investors, further guidance on the expected standards and practices when distributing virtual asset funds is provided in the "Circular to intermediaries on the distribution of virtual asset funds" issued by the SFC on 1 November 2018. Under this arrangement, if a virtual asset fund available in Hong Kong is not already managed by those firms mentioned under section I(a)(i), these funds will still be distributed by firms mentioned under section I(b), all of which are subject to the SFC's oversight. As such, the management or distribution of these funds would be regulated in one way or another by the SFC. II. Exploring regulation of platform operators Separately, the SFC is also setting out a conceptual framework for the potential regulation of virtual asset trading platforms in this statement, with a view to exploring (and forming a view after the exploratory stage) whether virtual asset trading platforms are suitable for regulation. If the SFC is minded to license any virtual asset trading platforms, it is proposed that the standards of conduct regulation for virtual asset trading platform operators should be comparable to those applicable to existing licensed providers of automated trading services. The SFC considers that the regulatory approach under the conceptual framework (if implemented) could provide a path for compliance for those platform operators capable and willing to adhere to a high level of standards and practices, and set licensed operators apart from those which do not seek a licence. Some of the world's largest virtual asset trading platforms have been seen operating in Hong Kong but they fall outside the regulatory remit of the SFC10 and any other regulators. Owing to the serious investor protection issues identified and having regard to international developments, the SFC considers it necessary to explore in earnest whether and if so, how it could regulate virtual asset trading platforms under its existing powers. To conduct a meaningful study of the framework, the SFC will work with interested virtual asset trading platform operators that have demonstrated a commitment to adhering to the high expected standards by placing them in the SFC Regulatory Sandbox11. In the initial exploratory stage, the SFC would not grant a licence to platform operators. Instead, it would discuss its expected regulatory standards with platform operators and observe the live operations of the virtual asset trading platforms in light of these standards. It will also consider the effectiveness of the proposed regulatory requirements in addressing risks and providing adequate investor protection. The SFC will critically consider whether the virtual asset trading platforms are, in fact, appropriate to be regulated by the SFC in light of the performance of these trading platforms in the Sandbox. Factors to be considered include the adequacy and effectiveness of the proposed conceptual framework; ability to comply with the terms and conditions; investors' interests; as well as local market and international regulatory developments. It may be a possibility that due to the inherent characteristics of the underlying technology or business models of platform operators, the SFC will conclude that risks involved cannot be properly dealt with under the standards it would expect, and that investor protection still cannot be ensured. In that case, the SFC may decide that platform operators should not be regulated by the SFC. For instance, the SFC is not certain at this stage whether platform operators would satisfy the expected anti-money laundering standards, given that anonymity is the core feature of blockchain, which is the underlying technology for virtual assets. The SFC also has to take into account the rapid evolution of the whole virtual asset industry as well as development in the international regulatory community, including the work being done in International Organization of Securities Commissions (IOSCO). The exploratory stage is crucial for the SFC to understand the actual operations of platform operators to determine whether these platforms are suitable for regulation. If the SFC makes a positive determination at the end of this stage, it would then consider granting a licence to a qualified platform operator. In order not to confuse the public about the regulatory status of platform operators, the identity of the Sandbox applicants in this stage and the discussions will be kept confidential. If the SFC grants a licence to a qualified platform operator, it will impose appropriate licensing conditions and the operator will proceed to the next stage of the Sandbox. This would typically mean more frequent reporting, monitoring and reviews so that through close supervision by the SFC, operators could put in place robust internal controls and address any of the SFC's concerns arising from the conduct of their business. The SFC may also further consider or refine its regulatory and supervisory approach through intensive dialogue with operators when they are operating in the Sandbox. After a minimum 12-month period, the virtual asset trading platform operator may apply to the SFC for removal12 or variation of some licensing conditions and exit the Sandbox. Licensing conditions (and terms and conditions) imposed in this stage would be made public in the usual way. Details of the conceptual framework are set out in Appendix 2, "Conceptual framework for the potential regulation of virtual asset trading platform operators". The SFC will keep the development of activities related to virtual assets in view and may issue further guidance where appropriate. Market participants are welcome to contact the Fintech Contact Point at [email protected] if they have any questions. Intermediaries Division Securities and Futures Commission 1 Website of CoinMarketCap: https://coinmarketcap.com/charts/. 2 Report entitled "Crypto-asset markets - potential channels for future financial stability implications" published by the Financial Stability Board on 10 October 2018: http://www.fsb.org/wp-content/uploads/P101018.pdf. 3 These include the Statement on initial coin offerings dated 5 September 2017, Circular to Licensed Corporations and Registered Institutions on Bitcoin futures contracts and cryptocurrency-related investment products dated 11 December 2017, and the press release, "SFC warns of cryptocurrency risks", dated 9 February 2018. 4 Please refer to the Circular to intermediaries on compliance with notification requirements dated 1 June 2018 for details. 5 For details, please refer to the press release, "SFC's regulatory action halts ICO to Hong Kong public", dated 19 March 2018. 6 That is, only virtual asset portfolio managers which intend to invest 10% or more of the gross asset value (GAV) of the portfolios under its management in virtual assets will be subject to the SFC's oversight in this way. 7 This refers to existing legal and regulatory requirements set out under the subsidiary legislation, the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission, the Fund Manager Code of Conduct and guidelines, circulars and frequently asked questions issued by the SFC from time to time (collectively referred to as "Existing Requirements"). 8 This is on the premise that virtual assets, as an asset class, have similar features and risk characteristics, whether or not they amount to "securities" or "futures contracts". 9 For the avoidance of doubt, this notification requirement applies even if (i) the licence applicant or licensed corporation manages or plans to manage virtual asset portfolios with an intention to invest less than 10% of the GAV of the portfolio in virtual assets; or (ii) the virtual assets involved have features of "securities" or "futures contracts" as defined under the SFO. 10 Platforms which offer trading of virtual assets that are not "securities" or "futures contracts" are not subject to the purview of the SFC. 11 Please refer to the press release, "Launch of the SFC Regulatory Sandbox", dated 29 September 2017 for details. 12 For example, the licensing condition on ongoing reporting obligations. 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