List Of Cryptocurrency Accounting Firms UseTheBitcoin
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Bob The Magic Custodian
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.
It is no doubt Grayscale’s booming popularity as a mainstream investment has caused a lot of community hullabaloo lately. As such, I felt it was worth making a FAQ regarding the topic. I’m looking to update this as needed and of course am open to suggestions / adding any questions. The goal is simply to have a thread we can link to anyone with questions on Grayscaleand its products. Instead of explaining the same thing 3 times a day, shoot those posters over to this thread.My hope is that these questions are answered in a fairly simple and easy to understand manner. I think as the sub grows it will be a nice reference point for newcomers. Disclaimer: I do NOT work for Grayscale and as such am basing all these answers on information that can be found on their website / reports. (Grayscale’s official FAQ can be found here). I also do NOT have a finance degree, I do NOT have a Series 6 / 7 / 140-whatever, and I do NOT work with investment products for my day job. I have an accounting background and work within the finance world so I have the general ‘business’ knowledge to put it all together, but this is all info determined in my best faith effort as a layman. The point being is this --- it is possible I may explain something wrong or missed the technical terms, and if that occurs I am more than happy to update anything that can be proven incorrect Everything below will be in reference to ETHE but will apply to GBTC as well.If those two segregate in any way, I will note that accordingly.
ETHE is essentially a stock that intends to loosely track the price of ETH. It does so by having each ETHE be backed by a specific amount of ETH that is held on chain. Initially, the newly minted ETHE can only be purchased by institutions and accredited investors directly from Grayscale. Once a year has passed (6 months for GBTC) it can then be listed on the OTCQX Best Market exchange for secondary trading. Once listed on OTCQX, anyone investor can purchase at this point. Additional information on ETHE can be found here.
So ETHE is an ETF?
No. For technical reasons beyond my personal understandings it is not labeled an ETF. I know it all flows back to the “Securities Act Rule 144”, but due to my limited knowledge on SEC regulations I don’t want to misspeak past that. If anyone is more knowledgeable on the subject I am happy to input their answer here.
How long has ETHE existed?
ETHE was formed 12/14/2017. GBTC was formed 9/25/2013.
How is ETHE created?
The trust will issue shares to “Authorized Participants” in groups of 100 shares (called baskets). Authorized Participants are the only persons that may place orders to create these baskets and they do it on behalf of the investor. Source: Creation and Redemption of Shares section on page 39 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here Note – The way their reports word this makes it sound like there is an army of authorizers doing the dirty work, but in reality there is only one Authorized Participant. At this moment the “Genesis” company is the sole Authorized Participant. Genesis is owned by the “Digital Currency Group, Inc.” which is the parent company of Grayscale as well. (And to really go down the rabbit hole it looks like DCG is the parent company of CoinDesk and is “backing 150+ companies across 30 countries, including Coinbase, Ripple, and Chainalysis.”) Source: Digital Currency Group, Inc. informational section on page 77 of the “Grayscale Bitcoin Trust (BTC) Form 10-K (2019)” – Located Here Source: Barry E. Silbert informational section on page 75 of the “Grayscale Bitcoin Trust (BTC) Form 10-K (2019)” – Located Here
How does Grayscale acquire the ETH to collateralize the ETHE product?
An Investor may acquire ETHE by paying in cash or exchanging ETH already owned.
Cash: The investor pays the subscription amount in cash and the Authorized Participant will use that cash to purchase ETH.
ETH: The investor transfers the ETH to the Authorized Participant, which will contribute the ETH in-kind to the Trust.
Source: Creation and Redemption of Shares section on page 40 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Where does Grayscale store their ETH? Does it have a specific wallet address we can follow?
ETH is stored with Coinbase Custody Trust Company, LLC. I am unaware of any specific address or set of addresses that can be used to verify the ETH is actually there. As an aside - I would actually love to see if anyone knows more about this as it’s something that’s sort of peaked my interest after being asked about it… I find it doubtful we can find that however. Source: Part C. Business Information, Item 8, subsection A. on page 16 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Can ETHE be redeemed for ETH?
No, currently there is no way to give your shares of ETHE back to Grayscale to receive ETH back. The only method of getting back into ETH would be to sell your ETHE to someone else and then use those proceeds to buy ETH yourself. Source: Redemption Procedures on page 41 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Why are they not redeeming shares?
I think the report summarizes it best:
Redemptions of Shares are currently not permitted and the Trust is unable to redeem Shares. Subject to receipt of regulatory approval from the SEC and approval by the Sponsor in its sole discretion, the Trust may in the future operate a redemption program. Because the Trust does not believe that the SEC would, at this time, entertain an application for the waiver of rules needed in order to operate an ongoing redemption program, the Trust currently has no intention of seeking regulatory approval from the SEC to operate an ongoing redemption program.
Source: Redemption Procedures on page 41 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
What is the fee structure?
ETHE has an annual fee of 2.5%. GBTC has an annual fee of 2.0%. Fees are paid by selling the underlying ETH / BTC collateralizing the asset. Source: ETHE’s informational page on Grayscale’s website - Located Here Source: Description of Trust on page 31 & 32 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
What is the ratio of ETH to ETHE?
At the time of posting (6/19/2020) each ETHE share is backed by .09391605 ETH. Each share of GBTC is backed by .00096038 BTC. ETHE & GBTC’s specific information page on Grayscale’s website updates the ratio daily – Located Here For a full historical look at this ratio, it can be found on the Grayscale home page on the upper right side if you go to Tax Documents > 2019 Tax Documents > Grayscale Ethereum Trust 2019 Tax Letter.
Why is the ratio not 1:1? Why is it always decreasing?
While I cannot say for certain why the initial distribution was not a 1:1 backing, it is more than likely to keep the price down and allow more investors a chance to purchase ETHE / GBTC. As noted above, fees are paid by selling off the ETH collateralizing ETHE. So this number will always be trending downward as time goes on. Source: Description of Trust on page 32 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
I keep hearing about how this is locked supply… explain?
As noted above, there is currently no redemption program for converting your ETHE back into ETH. This means that once an ETHE is issued, it will remain in circulation until a redemption program is formed --- something that doesn’t seem to be too urgent for the SEC or Grayscale at the moment. Tiny amounts will naturally be removed due to fees, but the bulk of the asset is in there for good. Knowing that ETHE cannot be taken back and destroyed at this time, the ETH collateralizing it will not be removed from the wallet for the foreseeable future. While it is not fully locked in the sense of say a totally lost key, it is not coming out any time soon. Per their annual statement:
The Trust’s ETH will be transferred out of the ETH Account only in the following circumstances: (i) transferred to pay the Sponsor’s Fee or any Additional Trust Expenses, (ii) distributed in connection with the redemption of Baskets (subject to the Trust’s obtaining regulatory approval from the SEC to operate an ongoing redemption program and the consent of the Sponsor), (iii) sold on an as-needed basis to pay Additional Trust Expenses or (iv) sold on behalf of the Trust in the event the Trust terminates and liquidates its assets or as otherwise required by law or regulation.
Source: Description of Trust on page 31 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Grayscale now owns a huge chunk of both ETH and BTC’s supply… should we be worried about manipulation, a sell off to crash the market crash, a staking cartel?
First, it’s important to remember Grayscale is a lot more akin to an exchange then say an investment firm. Grayscale is working on behalf of its investors to create this product for investor control. Grayscale doesn’t ‘control’ the ETH it holds any more then Coinbase ‘controls’ the ETH in its hot wallet. (Note: There are likely some varying levels of control, but specific to this topic Grayscale cannot simply sell [legally, at least] the ETH by their own decision in the same manner Coinbase wouldn't be able to either.) That said, there shouldn’t be any worry in the short to medium time-frame. As noted above, Grayscale can’t really remove ETH other than for fees or termination of the product. At 2.5% a year, fees are noise in terms of volume. Grayscale seems to be the fastest growing product in the crypto space at the moment and termination of the product seems unlikely. IF redemptions were to happen tomorrow, it’s extremely unlikely we would see a mass exodus out of the product to redeem for ETH. And even if there was incentive to get back to ETH, the premium makes it so that it would be much more cost effective to just sell your ETHE on the secondary market and buy ETH yourself. Remember, any redemption is up to the investors and NOT something Grayscale has direct control over.
Yes, but what about [insert criminal act here]…
Alright, yes. Technically nothing is stopping Grayscale from selling all the ETH / BTC and running off to the Bahamas (Hawaii?). BUT there is no real reason for them to do so. Barry is an extremely public figure and it won’t be easy for him to get away with that. Grayscale’s Bitcoin Trust creates SEC reports weekly / bi-weekly and I’m sure given the sentiment towards crypto is being watched carefully. Plus, Grayscale is making tons of consistent revenue and thus has little to no incentive to give that up for a quick buck.
That’s a lot of ‘happy little feels’ Bob, is there even an independent audit or is this Tether 2.0?
Actually yes, an independent auditor report can be found in their annual reports. It is clearly aimed more towards the financial side and I doubt the auditors are crypto savants, but it is at least one extra set of eyes. Auditors are Friedman LLP – Auditor since 2015. Source: Independent Auditor Report starting on page 116 (of the PDF itself) of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here As mentioned by user TheCrpytosAndBloods (In Comments Below), a fun fact:
The company’s auditors Friedman LLP were also coincidentally TetheBitfinex’s auditors until They controversially parted ways in 2018 when the Tether controversy was at its height. I am not suggesting for one moment that there is anything shady about DCG - I just find it interesting it’s the same auditor.
“Grayscale sounds kind of lame” / “Not your keys not your crypto!” / “Why is anyone buying this, it sounds like a scam?”
Welp, for starters this honestly is not really a product aimed at the people likely to be reading this post. To each their own, but do remember just because something provides no value to you doesn’t mean it can’t provide value to someone else. That said some of the advertised benefits are as follows:
Access to trading within a tax advantaged retirement account
Institutions can easily and safely get exposure to crypto in a more legal-friendly manner
Ease of use for those who are not very technologically savvy
Ease of access for someone who doesn’t want to set up a Coinbase account
Perceived trust in institutional platforms over something like Coinbase or Kraken
Degen traders who just want access to the volatility ETHE provides that have no interest in crypto beyond that
So for example, I can set up an IRA at a brokerage account that has $0 trading fees. Then I can trade GBTC and ETHE all day without having to worry about tracking my taxes. All with the relative safety something like E-Trade provides over Binance. As for how it benefits the everyday ETH holder? I think the supply lock is a positive. I also think this product exposes the Ethereum ecosystem to people who otherwise wouldn’t know about it.
Why is there a premium? Why is ETHE’s premium so insanely high compared to GBTC’s premium?
There are a handful of theories of why a premium exists at all, some even mentioned in the annual report. The short list is as follows:
ETHE is NOT redeeming shares and as such doesn’t have an effective arbitrage mechanism
ETHE has a 1 year wait to be sold on the secondary market, again negating the ability to effectively arbitrage the premium
People may simply be willing to pay a premium for the benefits stated above.
Why is ETHE’s so much higher the GBTC’s? Again, a few thoughts:
ETHE hasn’t been around as long, so there is less secondary market supply to go around
ETHE was listed at an insanely high premium to begin with
ETHE might simply be more popular at the moment
Could just be sheer stupidity (investors think ETHE is a 1:1 ratio not 1:11)
Are there any other differences between ETHE and GBTC?
I touched on a few of the smaller differences, but one of the more interesting changes is GBTC is now a “SEC reporting company” as of January 2020. Which again goes beyond my scope of knowledge so I won’t comment on it too much… but the net result is GBTC is now putting out weekly / bi-weekly 8-K’s and annual 10-K’s. This means you can track GBTC that much easier at the moment as well as there is an extra layer of validity to the product IMO.
I’m looking for some statistics on ETHE… such as who is buying, how much is bought, etc?
There is a great Q1 2020 report I recommend you give a read that has a lot of cool graphs and data on the product. It’s a little GBTC centric, but there is some ETHE data as well. It can be found here hidden within the 8-K filings.Q1 2020 is the 4/16/2020 8-K filing. For those more into a GAAP style report see the 2019 annual 10-K of the same location.
Is Grayscale only just for BTC and ETH?
No, there are other products as well. In terms of a secondary market product, ETCG is the Ethereum Classic version of ETHE. Fun Fact – ETCG was actually put out to the secondary market first. It also has a 3% fee tied to it where 1% of it goes to some type of ETC development fund. In terms of institutional and accredited investors, there are a few ‘fan favorites’ such as Bitcoin Cash, Litcoin, Stellar, XRP, and Zcash. Something called Horizion (Backed by ZEN I guess? Idk to be honest what that is…). And a diversified Mutual Fund type fund that has a little bit of all of those. None of these products are available on the secondary market.
Are there alternatives to Grayscale?
I know they exist, but I don’t follow them. I’ll leave this as a “to be edited” section and will add as others comment on what they know. Per user Over-analyser (in comments below):
As asked by pegcity - Okay so I was under the impression you can just give them your own ETH and get ETHE, but do you get 11 ETHE per ETH or do you get the market value of ETH in USD worth of ETHE?
I have always understood that the ETHE issued directly through Grayscale is issued without the premium. As in, if I were to trade 1 ETH for ETHE I would get 11, not say only 2 or 3 because the secondary market premium is so high. And if I were paying cash only I would be paying the price to buy 1 ETH to get my 11 ETHE. Per page 39 of their annual statement, it reads as follows:
The Trust will issue Shares to Authorized Participants from time to time, but only in one or more Baskets (with a Basket being a block of 100 Shares). The Trust will not issue fractions of a Basket. The creation (and, should the Trust commence a redemption program, redemption) of Baskets will be made only in exchange for the delivery to the Trust, or the distribution by the Trust, of the number of whole and fractional ETH represented by each Basket being created (or, should the Trust commence a redemption program, redeemed), which is determined by dividing (x) the number of ETH owned by the Trust at 4:00 p.m., New York time, on the trade date of a creation or redemption order, after deducting the number of ETH representing the U.S. dollar value of accrued but unpaid fees and expenses of the Trust (converted using the ETH Index Price at such time, and carried to the eighth decimal place), by (y) the number of Shares outstanding at such time (with the quotient so obtained calculated to one one-hundred-millionth of one ETH (i.e., carried to the eighth decimal place)), and multiplying such quotient by 100 (the “Basket ETH Amount”). All questions as to the calculation of the Basket ETH Amount will be conclusively determined by the Sponsor and will be final and binding on all persons interested in the Trust. The Basket ETH Amount multiplied by the number of Baskets being created or redeemed is the “Total Basket ETH Amount.” The number of ETH represented by a Share will gradually decrease over time as the Trust’s ETH are used to pay the Trust’s expenses. Each Share represented approximately 0.0950 ETH and 0.0974 ETH as of December 31, 2019 and 2018, respectively.
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.
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.
Answer - As for Kava, Kava was originally founded in January 2018. It was formed by cofounders Scott Stuart, Ruaridh O’Donnell and myself with the mission to tackle the problem of interoperability. We started the company working with larger projects like Ripple, MakerDao, and Cosmos on their layer 2 and interoperability problems and developed a lot of expertise in this area. It wasn’t until 2019 that we eventually decided to put our expertise to public use and create the first interoperable DeFi blockchain, Kava.
Could you please tell me what KAVA cryptocurrency is? What problem does it solve?
Answer - KAVA is the staking, governance, and reserve asset of the Kava DeFi platform. KAVA is required by node operators to secure transactions on the blockchain. Additionally, when lending fees are paid, they are converted to Kava and burned reducing the overall supply of KAVA tokens. As more users use the Kava lending platform, KAVA should become more scarce overtime.
What is the advantage of keeping the KAVA token for a long and short term?
Answer - In the short term, if you stake KAVA you can earn additional block rewards every day, block by block. This provides a nice steady return on the Kava usually in the range of 3-20% depending on the number of people staking.
We will be opening the gates of DeFi to many top tier assets such as BNB, XRP, ATOM, and BTC which have never been able to use lending, stablecoins, or other DeFi Services. If you are a KAVA hodler you can benefit from owning and having a stake in the network as we grow because as the network grows, Kava is burned and it becomes more scarce as a resource.
Chainlink is KAVA’s partner, can you explain more about this partnership?
Answer - Yes, this is not the usual chainlink partnership where a blockchain consumes data from Chainlink’s oracle solution.
No oracle solution adequate for DeFi applications on Cosmos was available. For this reason, Kava has teamed up with Chainlink to bring its data and reliable oracle solution to the Cosmos ecosystem. Chainlink nodes now will be able to securely publish data directly on the Kava blockchain where it can be used or easily transported to other Cosmos-based blockchains and applications. Chainlink oracles on Kava utilize all the industry-leading technologies of Chainlink, while enabling more frequent price updates and improving the reach and distribution of where that data can be used.
Since Kava’s blockchain is built using Tendermint, Tendermint-based blockchains within the Cosmos ecosystem (Binance, Terra, OKChain, Cosmos Hub, Agoric, Aragon, and others) will now be able to retrieve market data such as cryptocurrency, FX, and commodity prices. For DEX’s like Binance this will enable them to create futures, options, and other derivative products they were not able to do so before.
TLDR: Kava + Chainlink Data creates the ideal hub for all blockchains and applications to get their DeFi services and Data, and as result makes Kava a natural hub for the growing Cosmos ecosystem.
What is the KAVA CDP product? Do you have any exciting things down the pipeline that you can share?
Answer - First, let me clarify that CDP simply means “collateralized-debt-position” similar to CDOs that exist in the traditional finance world. What it means is a loan using collateral to back the loan.
Kava’s lending platform offers collateralized loans to users who have crypto. Getting a loan with Kava’s platform is great if you don’t want to sell your crypto position, but need short term cash for payments or if you want to use the loan to get a levered / margin position without going through KYC.
As for news! Kava’s lending platform is scheduled to officially launch on the mainnet June 10th.
At this time, DeFi will be made available to BNB for the first time ever. Also at this time, the Kava DeFi platform will be awarding the first users that have BNB extremely high rewards for being early adopters.
Each week, 74,000 KAVA will be given out to all the users who have taken out loans on Kava. Yes, you get free KAVA, for taking out a loan using BNB!
Why should BNB users use KAVA’s lending platform and take out USDX? And how to mint USDX with BNB on KAVA CDP?
Answer - Free- maybe let's call it rewards for being good users 😉
The rewards are platform growth incentives so that we can grow the platform quickly.
Well at launch, definitely the KAVA rewards are a huge reason for BNB users to use it.
As for the product long-term, the major use case for our lending platform is to get a levered position without needing an exchange or to go through KYC.
How it works is that a BNB holder can deposit their BNB and take out USDX loans - this capital they will take and buy more BNB with it. Most people will use the loan this way to get 2-3x the original BNB amount. If the price goes up on BNB, they win 2-3x the gains!
Of course if the price goes down and they cannot repay their loan, the BNB collateral might get liquidated, so be careful, it works just like a margin trading account.
Brian do you have any more information or links for our community about this?
KAVA was initially planned to launch on Ripple network but later switched to Cosmos Tendermint Core. [email protected] is that something you see in Tendermint Core that is not available anywhere?
Answer - For clarification, Kava was never planned to be on Ripple. However, Ripple is a Kava investor, shareholder, and partner.
We selected the Cosmos-SDK featuring the Tendermint BFT consensus because during our past work with Ripple, MakerDao, ETH, and other layer 2 work we learned the value of “finality” of blockchains. For example, on ETH, the finality of blocks do not happen right away. You need to reach 15+ blocks to be confirmed on Ethereum to really know a transaction has passed. This results in really slow user experiences that aren’t acceptable in finance or any application really.
Tendermint solves this because it makes every transaction final and occur in seconds.
Additionally, we chose the Cosmos-SDK as the framework to build our stand alone blockchain, Kava because it allowed us to create our own security model and design which enables Kava as a DeFi platform responsible for millions of dollars of collateral to be very secure in a way we could net get if we built it on any other network.
KAVA does cross-chain support. Compared to other DeFi platforms, KAVA offer collateralized loans and stable coins to users too. How will volatility be managed there with so many different collateral systems in CDP?
Answer - Volatility is an important consideration and accurate and timely price reference data is needed to make sure the system works.
All the collateral positions rely on price feeds from oracles to determine if they are safe or need to be liquidated. Kava has created a novel partnership with Chainlink, where Chainlink oracles that normally run on Ethereum, operate nodes directly on Kava where they can post prices. This Kava to avoid network congestion, high gas fees, and other less desirable issues found on Ethereum, while enabling the oracles with Kava’s fast blocktimes and finality so they can actually deliver price updates 10-20x more frequently than is possible elsewhere. This makes Kava’s price feed data very reliable.
In times of volatility, if liquidations occur, the Kava platform automatically auctions collateral off for USDX on the market and burns the USDX. This mechanism keeps the system balanced and USDX algorithmically stable and always fully collateralized by real assets.
And it does this transparently, unlike the real world CDOs which caused the world issues in 2008 due to the lack of transparency in their assets and risk.
Recently, Binance has released a white paper on BSC, a Binance smart chain. So, what can I get by staking through Binance Coin BNB?
Answer - Yay for smart contracts!
What can we get by staking bnb?
Staking BNB on Kava, or depositing it in a CDP and creating USDX from it earns users KAVA in rewards everyweek. A lot of rewards. In addition, you get USDX to hold which also pays out a savings rate each block that is much better than say what USD in a checking account could do.
Various platforms are in Ethereum. So why is Kava not at Ethereum?
Answer - I could speak about this for ages, but there is a reason for Ethereum being the home to many hacks and bugs.
Kava is not on ethereum because we couldn’t build our system there. The main reasons. as I have mentioned are:
(1) Ethereum has congestion, oracle issues, high fees, and slow block times.
(2) Ethereum’s open smart contracting system can do anything. This is great for building crypto kitties, but horrible for financial software as it makes all code have infinite attack vectors that hackers can use which are impossible to test for. We built our own chain so we could scope the code and limit what attack vectors are possible.
(3) Building in solidity, the language of Ethereum, is horrible. The development environment is bad, testnets don’t work, and many other things are painful. Kava is primarily built in GO which is far superior for financial applications in most respects.
(4) The future is Cosmos. Binance, Okchain, terra, Cosmos Hub(ATOM), and Kava all are created using the Cosmos-SDK framework. I believe this is the future and the blockchain developers are moving to this in mass. Over 110 projects now are building with the Cosmos-SDK.
What are ways by which Kava project generates profit/revenue to maintain project. What is your revenue model?
Answer - Kava is a for-profit financial DAO with over 80 different businesses staking Kava and voting on its evolution. They want to see Kava succeed so they vote to fund operations and developments that drive user growth in Kava. Due to fees paid in Kava and the burning mechanism, as the system grows in users, the Kava supply decreases making those that hold Kava win due to scarcity.
Lending/Borrowing has been introduced by Binance. How can this affect the Kava since people can directly borrow BUSD from Binance with BNB used as collateral than going to Kava?
Answer - Kava will be featured on Binance as well. The main benefit of Kava is that there is no counterparty. The capital is minted on demand not sourced from somewhere. Binance and other centralized parties on the otherhand need to find capital to provide loans, creating a cost of capital. Kava is much more efficient at providing capital and avoids a lot of regulator issues.
I'll add I think BUSD in the future might be usable for collateral to Kava's loans as well. It would be cool 🙂
What's your opinions on Future of DeFi & DApps? Do you think that DeFi is the future of current Financial world? Also, How do you see the future of KAVA?
Answer - I believe Centralized Finance and the existing infrastructure has a place. It has a lot of issues that cause things like the 2008 crisis and the current insolvency issues that are happening across the world due to trust-based debt with no actual backers other than the people which end up bailing out banks and other financial institutions that have made poor decisions.
DeFi's future is bright because it solves this fundamental issue. It removes trust and adds transparency. Kava is right at the foundation for all of DeFi as things grow and mature.
Recently, we have seen some big hacks in DeFi platforms. How will KAVA deal with these bad actors of crypto and what security measures have been taken by KAVA for the safety of users' funds?"
Answer - Unlike a lot of DeFi startups, we take things seriously. We don't ""move fast and break things"" as Mark Zuckerberg would say.
We do a thorough analysis before suggesting to deploy code. Our internal team works very hard to run tests and simulations, once it passes internally, we give it to 3rd party auditors who try and game it and break the code. If it passes there, we give the code to the community to review and vote into the mainnet. In this way, I’d estimate about 100+ people review our code and test it before it goes live and consumers can touch it. I don't know many other project teams that due things with such diligence.
Binance for KAVA is a very valuable partner in terms of increasing the number of users, but what is KAVA ready to give equivalent to Binance users? What applications will be integrated into Binance to expand the ecosystem?
Answer - Kava gives the BNB users loans. It gives the DEX a stablecoin and the ability to offer margin products. Kava’s connection to binance chain and chainlink data also enables Binance DEX to offer trustless derivatives like options and futures products going forward.
Cosmos has limitations on working with PoW coins. How do you technically solve the problem of implementing DeFi products for bitcoin?
Answer - Cosmos is great for hard-to-work-with blockchains like BTC. It's flexible in how you can construct bridges. For example, the validator set can have a multisig private key split up into pieces in order to create a trustless escrow and control of assets on other blockchains. In this way, we can create peg zones with Cosmos for the best assets in the world. Once a zone is established, it can be used on Kava and other Cosmos chains.
USDX is currently a little-known stable coin. Do you plan to add it to the top exchanges with good liquidity, including Binance?
Answer - USDX will be growing quickly. We have a plan to have it listed and get liquidity across several known exchanges shortly after launch.
There are several options for using USDX on the KAVA platform, one of which is Margin Trading / Leverage. Is this a selection function or a compulsory function? Wondering since there are some investors who don`t like margin. What is the level of leverage and how does a CDP auction work?
Answer - Using Kava for Margin trading is 100% optional. You can choose how you want to use the margin loan. You don’t have to spend the USDX unless you want to. It could be used for everyday payments as well in the case you simply don’t want to sell your underlying collateral. If you don’t want the risk, do small loans with lots of collateral.
Will your team have a plan to implement the DAO module on your platform, as it provides autonomy, decentralization and transparency?
Answer - DAO - Kava is a for-profit DAO and it’s fully functional already. We have on-chain governance and have underwent several votes and evolutions you can look at. You actually can see some current voting processes taking place here: https://kava.mintscan.io/proposals
We recently implemented a cool feature called committees, which enables the DAO to elect a small group of experts to make decisions without needing a vote of the whole user base. This enables the experts to have control over a small portion of the protocol - such as monitoring the debt limit, fees, etc and enables Kava to operate faster and be more adaptable in volatile market conditions.
How can we address the possible overloads and security threats caused by increased users in the DeFi scene?
Answer - Yes, this is a huge issue for Ethereum, MakerDAO and everyone in the space. I don’t see a bright future for DeFi on Etheruem unfortunately. You can’t have a blockchain do everything well. Tether alone congests most of Ethereum and makes oracle price feeds lag the market. This can cause liquidations that should not happen and real people will lose real funds. It’s a huge issue.
The hope is for a dedicated system like Kava to provide a better backbone for DeFi applications going forward.
I should point out that Kava is not just a MakerDao for Cosmos or a CDP for Bitcoin. Kava is designed to be a foundational layer for DeFi services that every new blockchain and application will need.
Every blockchain will need DeFi services like lending, stablecoins, and data and they need it to be very secure. Kava does all this with its cross-chain lending plarform, USDX stablecoin, and Chainlink data in an incredibly secure, but accessible manner.
In this way, Kava aims to connect and serve all the major cryptocurrency communities and build it’s place at the center, where every developer can get what they need to build financial applications of the future."
What distinguishes Kava from your existing competitors like Syntetix?
Answer - Synthetix isn't really a competitor, but it is an interesting project in terms of mechanism design. We share a lot of common investors and have similar token economic ideas with them. The only blockchain project that could be is MakerDAO, but they can only work with ETH assets due to their design. We are focused on the major cap assets - BTC, BNB, XRP, ATOM and others have a much larger market than ETH to address. BTC is 10x the size alone. Currently no one serves them with DeFi. We’re going after this opportunity and believe it to be a huge one.
Why is the KAVA coin not used for Mint, why am I asking that because I see it can also make the value of KAVA coins grow naturally?
Answer - Why is Kava not used as a collateral? Well, it could be I suppose. The community might vote for this in the near future if they want us to be like synthetix. It makes the Kava token more valuable and it will incentivize much more locked-up Kava reducing overall circulating supply which is fairly favorable. The main reason we have not done this yet is that we(Kava and its community) are still weighing the risks of doing this given that Kava also functions as a reserve asset. I think it's likely Kava gets added as collateral at some point, but it will likely have a high debt-collateral ratio to address the issues similar to Synthetix which is 750%.
How do you prevent in a manipulated KAVA Mint just to take advantage of a token prize when minting?
Answer - Minting rewards and manipulation. We’ve thought of this. Each week, the blockchain counts all the blocks, counts how many people had a loan in that period, then takes the average loan amount over time to calculate the rewards. If you open and close a loan - you will get very little rewards. You only get a large reward if you keep the loan open the full period.
Who are your oracle providers? Are you also an oracle provider?
Answer - Kava may run 1 oracle in the future, but we will always have many and be the minority. Most chainlink oracle node operators are large players in the space that run staking infrastructure companies like cosmostation, chainlayer, chorus one, figment networks, etc. Binance will also be one of our oracles.
If we look at all the different types of DeFi products _(decentralized exchanges, stablecoins, atomic swaps, insurance products, loan platforms, trade financing platforms, custody platforms, and crowdfunding platforms) currently covering important areas of traditional finance...where does Kava fit in?
Answer - To make any interesting financial product work you need capital, a stable store of value, and price data. These are really hard to get on current blockchain environments. Kava provides all of these.
Many people describe Kava as similar to Maker (MKR). How is Kava different? Why do you think Kava has more potential?
Answer - MakerDAO is a smart contract with a singular purpose, to serve ETH. It sadly inherited the problems of ethereum. Kava is designed from the ground up for security and interoperability. We are targeting bigger and better assets and have more capabilities to serve them with what their developers and ecosystem need.
What is the uniqueness of KAVA project that cannot be found in other project that´s been released so far ?
Answer - Well in June 10th, we will be the first ever blockchain project to bring DeFi to another blockchain in a real way. BNB users will have loans, stablecoins, and much more.
The gas fee is an issue for blockchain besides scalability. Does your Kava provide a solution for gas?
Answer - gas fees are very low on Kava, only high enough to prevent spam. We dont need high fees for TX because validators are paid in block rewards. Additionally, we dont have competing transactions from crypto-kitties or other non-financial applications. This leaves all of Kava's throughput 100% dedicated to scaling financial transactions.
Kava project works on DeFi (Decentralized Finance) But what’s the benefits of Decentralized Financial system? What are the possibilities of DeFi over Centralized Finance system?
Answer - Open access, no need for trust, and no censorship by singular governments or parties. Kava is accessible anywhere in the world, by anyone.
Data supplied by oracles are false at times, how do you prevent this? How reliable are data received by KAVA?
Answer - This is why using premium / credentialed APIs is important for oracles. These data sources tend to be more accurate and better managed. Wrong prices can happen - for liquidation systems like Kava, we factor this into our design by using an average of data overtime form all oracles as part of the calculation.
Can anyone become a KAVA validator, or is it just an invitation from the project itself? What are the requirements for becoming a KAVA verifier?
Answer - Anyone can become a validator, but you will need to stake or have enough stake delegated to you from others to be in the top 100 validators to earn block rewards.
DEFI PULSE said that a total of 902M is currently locked. According to you, how will this number change in the next few years, and how will KAVA position itself as the top player in this market segment?
Answer - DeFi will only grow through 2020. And likely grow massively.
All projects on DeFi pulse are ""ethereum"" based. Kava is going to shake the blockchain world in the next few weeks by being the first ""multi-chain"" project on DeFi pulse and by my estimations we should quickly surpass a lot of the projects on that list.
I am an testnet minter and the process seem Simplified, now I want to know if minting of USDX will continue when you launch Mainnet and do you have plans to build your own KAVA WALLET for easy minting on your mainnet
Answer - Simple blockchain experience?! high praise! Yes the process will be the same. Kava will not provide interfaces or wallets. Kava Labs builds software for the blockchain, our community members like Cosmostation, Frontier, Trust Wallet build support for people to interact with it.
What business plans does Kava have with Seoul (South Korea) after partnering with Cosmostation? Do you plan to expand your products beyond Asia? Have you thought about harnessing the potential of South America?
Answer - South Korea is a perfect market for Kava's DeFi. Regulations prohibit fiat-backed stablecoins and margin trading. Kava's platform uses crypto-backed stabvlecoins and can enable users to get loans to margin trade. I am looking forward to further developing the Korean market for Kava, working with close partners like Cosmostation and showing the world real use cases of DeFi.
Thank you for taking the time to conduct this AMA. Do you have any parting words, and where can the people go to keep up with all of the new happenings regarding Kava Labs?
Answer - Thanks for all the awesome questions! Amazingly thoughtful!
I've been promising the world cross-chain DeFi since June of last year. The IEO and mainnet went live Nov 2019. It's been a year of hard work - but an industry first is coming on June 10th. I'm excited. I hope you guys are.
Thanks for having me, I hope you become a USDX minter and get KAVA rewards. And last but not least, I love Binance - it's Kava's first home and I'm really happy to open up DeFi to BNB first.
So, let's say I am a bank. I issue a stable coin (supposedly backed by USD reserves) Here's the catch. I am willing to loan my stable dollar token in return for a LOAN of us dollars. Not actual dollars. An IOU. Now, this is perfectly shady, but it can get darker. Let's say I specify that I only lend to large institutions, or brokers working on their behalf. Not small time investors that can go broke. Then, I hire a broker on my own behalf. The broker loans me my own us dollars, and I then loan him my stable coins. But it gets worse. Now, I and my broker both know these new stable coins are imaginary. Fluff. The last thing we should be doing with them is buying an asset with real value, like bitcoin or ethereum. But we take our fluff tokens to the exchanges, and instead of actually buying btc with them, we now use that fluff money in something far more abusive. We use our real funds to buy btc, and then we use our fluff funds to set up massive buy walls. People fomo in, and we close the walls out, and dump our btc at elevated prices on the market. So far so good... But the exchanges get wind of what we are doing. So what do we do? We bribe them of course! In our fluffy tokens that are not tethered to real us dollars anymore. They are not backed 1 to 1. of course the auditors are coming. But we got warned by the corrupt ceos of the exchanges. And we move our tokens back in house, settle up our internal loans to ourselves, and walk away with the $$$ that we manipulated out of some centralized markets. The token I am talking about is called Tether. The corrupt exchange is binance. And the solution is DEFI and the Kyber network. It is built on top of ethereum, and its a decentralized exchange. Stop using centralized exchanges. You will get burned. You will have spoof walls made out of bogus tether hit you. You will lose money trading against these people. Don't. Do. It. Trade on the network that protects you. Trade on the network that plays fair. Thanks for listening to my TED talk, and I hope you all have a good night. Stay safe.
Re-Launching The Borderless, Unkillable Crypto-Fiat Gateway, DAIHard. Enter or Exit Crypto via Any Fiat and Any Payment Method, Anywhere in the World, Without KYC. All you need is a little Dai.
Some of you might recall recall our initial facepalm failed launch about 3 months ago (post-mortem here). Well, we're back--this time with an audit and some new features. This version of DAIHard should should die a little harder this time ;)
After shopping around a bit in the auditor space, we decided to go with Adam Dossa--the very same Adam Dossa that actually found our launch vulnerability and responsibly disclosed it to us! You can see his report here. By the way, Adam has been a gem: friendly, professional, timely, and flexible. Definitely keep him in mind if you need an audit!
Following is an updated version of our original launch post. If you've already read that, you might want to skip to the heading What's New in v0.9.2. Or you can go straight to the app or go to our info site for more info! Here is a legitimate concern most of us are familiar with:
To enter or exit the crypto economy, we rely on centralized exchanges such as Coinbase, which track their users, impose limits, and are tightly coupled to their jurisdiction and its banking system. And for all we know, any day now regulations could start tightening these controls further (*we've actually seen some of this play out in the two months since our first launch post). In light of this, can we say in any meaningful sense that crypto is anonymous, limtiless, borderless, immune to regulation, and (most importantly) unstoppable?
To really address this concern, we need a completely decentralized gateway between fiat and crypto: something that extends the benefits of crypto to the very act of moving between the old and new economies. But the design of such a platform is far from obvious. (Localethereum comes close, but as discussed under Unkillable, it doesn't quite cut it. And Bisq is decentralized, but has significant UX hurdles.) We believe we've found a solution. We are proud to present:
DAIHard v0.9.2 - Almost Definitely Not Broken This Time
If you want to jump right in, we recommend first watching our latest usage demo (7 min), then diving in and giving it a shot with a small amount of Dai. (Try it on Kovan first if mainnet is too scary!) DAIHard extends many of the promises of crypto (borderless, anonymous, limitless, unstoppable) into the exchange mechanism itself, allowing anyone, anywhere to bypass centralized exchanges and the control they impose. More concretely, DAIHard is a platform, run on smart contracts, for forming one-off crypto/fiat exchanges with other users, in which:
The method of fiat transfer is open-ended, but agreed upon up-front (for example: bank transfer, cash handoff, transfer of online credit, cash drop...).
You and the counterparty can communicate via end-to-end encrypted chat to coordinate the fiat transfer (i.e. communicate bank account number or reveal a cash drop location).
Crucially, in the last phase, the Seller can choose to burn the Dai instead of releasing it to the Buyer (but he can't get it back). This credible threat of burn is what makes the platform reliable in the absence of a centralized group of arbitrators or moderators. For more on this see the DAIHard Game Theory medium article (10 min read).
You Need either xDai, or both Dai and Ether, to Use The Tool (At Least For Now)
If you want to buy Dai on DAIHard, you must already have Dai--1/3 of the amount you want to purchase--to put up as a burnable deposit. For example, if you only have 10 Dai now, you can only commit to buying 30 Dai, and must complete that trade before using the newly bought Dai to open up a bigger offer (for up to 120 Dai that time). Most tragically of course, this means that if you don't already have some crypto, you can't use this tool to get crypto--this is why we avoid calling DAIHard an onramp specifically. This comes from the fact that both parties must have "skin in the game" for the game theory to work, and a smart contract can only threaten to burn crypto. We have some ideas on how to address this drawback in the not-too-distant future, which we'll write about soon. For now it's time to launch this thing and get some users!
Dangerous and Scary To Use
In rare cases, a user may have to burn Dai and face a loss on the entire trade amount. The necessity of this ever-present risk is explained in detail in DAIHard Game Theory. However, a cautious, rational user can gather information (possibly via our [subreddit](daihard)!) about how people have used the tool, successfully and unsuccessfully. They can then create a buy or sell offer with wisely chosen settings based on what has worked for others. Other cautious, rational users can find this offer and commit to the trade if they dare. We expect the vast majority of committed trades should involve rational, cautious users, and should therefore resolve happily. Still, inevitably there will be sloppy trades that result in burns. As the tool is used, we'll be keeping a close eye on the frequency of burns and keeping you guys updated (perhaps via a "System Status" utility similar to the one found on MakerDao's explorer). In the end, though, we expect the risk in using DAIHard to be comparable to the risk of using any exchange or DNM: ever-present but low enough for the platform to be useful as whole. So, while DAIHard will never shut down and can't perform an exit scam, the bad news is it's not risk-free. Users will have to approach DAIhard with the same level of caution they would with any new exchange (albeit for different reasons and with a different approach). So what's the good news?
The Good News
While these drawbacks are significant, they enable some remarkable features that no other crypto/fiat exchange mechanism can boast.
(Correction: Bisq seems to have a decentralized arbitration system) We are aware of no other crypto/fiat exchange platform that is truly unkillable. Bisq and localethereum comes close, but both localethereum relies on centralized processes of arbitration. This means their fraud-and-scam-prevention system can be sued, jailed, or otherwise harrassed--and if that part stops working, it doesn't matter how decentralized the rest of the system was. DAIHard, in contrast, gives the users the power to police and punish each other, via the aforementioned credible threat of burn. This is simple game theory, and the rules of this game are etched permanently into the DAIHard Factory and Trade contract code: impervious to litigation, regulation, and political pressure. This Factory contract has no owner and no suicide or pause code. It cannot be stopped by us or anyone else. Like Toastycoin, this thing was immortal the moment it was deployed (even more immortal than RadarRelay, for example, which does rely on an ownership role). Both DAIHard and Toastycoin (and probably whatever we build next) will last for as long as a single Ethereum node continues mining, and it will remain easy to use as long as someone can find the HTML/JS front-end and a web3 wallet. (The HTML/JS front-end (built in Elm, by the way, with the lovely elm-ethereum!) is currently hosted on Github pages, which is centralized--but even if Github takes down the page and deletes the code, it's a minor step to get the page hosted on IPFS, something that is on our near-term roadmap in any case)
No KYC, No Limits
It's smart contracts all the way down, so DAIHard never asks any nosy questions--if you have Metamask or some other web3 wallet installed and set up, with some ETH and Dai (or just xDai), you can immediately open or commit to a trade. You don't even need a username! (In fact, we're so inclusive, even machines are allowed--no CAPTCHA here!) You're limited only by the collateral you put up, so if you have 10,000 Dai you could open up a buy offer for 30,000 Dai (or a sell offer for 10,000 Dai) right now. We do reccommend trying the tool out first with a small amount of Dai... But we're not your mom! Do what you want!
It simply doesn't matter where you are, because DAIHard doesn't need to interface with any particular jurisdiction or payment system to work. DIAHard works by incentivizing people (or robots?) to navigate the particular real-world hurdles of bank transfers, cash drops, or other fiat transfer methods. These incentives work whether you're in America, Zimbabwe, or the Atlantic; they work whether the fiat is USD, EUR, ZAR, seashells, or Rai Stones; and they work whether your counterparty is a human, an organization, a script, or a particularly intelligent dog with Internet access.
Any Fiat Type, and Highly Customizeable
Here are some examples of the types of trades you might create or find on DAIHard.
Sell 5 xDai for $5 USD, sent via TransferWise.
Sell 200 Dai for $180 USD, granted they bring the cash to you by tomorrow afternoon in Central Park, NYC.
Buy 20 Dai with a $30 gift card for Amazon AWS that you were never going to use.
Sell 20 Dai in exchange for a $20 Steam game.
While in Vietnam, sell 200 Dai to someone for €180 anytime in the next two weeks, provided they deposit it into your German bank account.
While in Germany, sell 20 Dai to someone in exchange for them refilling your pre-paid Vietnamese phone plan.
Buy 500 Dai for $550 via PayPal, but wait 3 weeks for before the Dai is released (so the paypal transaction can't be reversed).
As the DAIHard community grows, users will doubtless find much more creative ways to use the system, and we will discover together which types of trades are reliable and which are more risky. Because users can set their own prices and phase timeout settings, we expect the risky trades to charge a premium or have longer time windows, while the reliable ones rapidly multiply at close to a 1:1 price ratio, with quick turnaround times.
Extensible (with profit) by Third Parties
Not satisfied with our interface? Do you have some nifty idea for how to display and organize user reputation? Or maybe some idea for how trades could be chained togeher? Maybe you'd like to design a notification system for DAIHard? Maybe you just want a different color scheme! Well, you won't need our permission to do any of this. Any tool that watches the same Factory contract will share the pool of trades, regardless of which tool actually creates the trade. This means we don't even have to fight over network effects! And if you look closely at our fee structure, you might notice that only half of the 1% DAIHard fee is "hardcoded" into the Factory contract. The other half is set and charged by our interface. What does this mean for you? If you go out and make a better interface, you can essentially replace half of our 1% fee with your own fee--it's up to you whether it's smaller or larger than the replaced 0.5%. The reason for this is to explicitly welcome other developers to extend what we've built. For as long as our team is the only one improving the platform, a threat to us is a threat to future upgrades. But if others begin extending the DAIHard platform too, then DAIHard will not only be unstoppable as it is today, but also grow unstoppably.
(For Real This Time) This Is a Big Fucking Deal
DAIHard is a turning point in crypto and a breakthrough in decentralized markets, and is an irreversible augmentation of the Ethereum platform. What we've built is a gateway to crypto completely devoid of centralized components--rendering entry and exit to crypto unkillable, flexible, borderless, and private. Centralized exchanges, and the control they impose, can now be bypassed by anyone with Dai and a web3 wallet.
What's New in v0.9.2
There have been many changes made since our first failed launch, but there are two rather important ones: xDai support and reputation tools.
DAIHard is now operational on xDai, a sidechain whose native token (xDai) is pegged to the Dai (and therefore $1). Add the xDai network to your Metamask (or just install Nifty Wallet), then switch to the xDai network in your wallet, to try it out. xDai has some pretty incredible benefits, compared to vanilla Ethereum:
Price: On xDai, a single DAIHard trade costs on the order of $0.01 to run start-to-finish, rather than the accumulated $2.40 (with the best-case-scenario 1gwei gas price) you'll spend on vanilla Ethereum.
Speed: Trade actions mine much faster, and don't require ERC20 'approve' transactions, making the whole process way snappier.
Gas priced in xDai: the main benefit here is that you only need one token (xDai) rather than two (Dai and Eth). Also, it's just nice having the gas cost expressed in (essentially) USD!
We now have a few reputation tools. First, on any open trade, there is a widget showing the number of releases, aborts, and burns the given address has been involved in as that role (buyer or seller). Clicking on this expands the widget to show more detailed information, and also provides a link to a page that lists each trade this user has been or is involved in.
We have tons of ideas on how to improve the product--too many, in fact, to commit to any before we get a good chunk of user feedback. Here are some of our favorite ideas:
A "QuickTrade" page, offering Trade Templates as an alternative to the current Create Offer page.
Big Exciting Features
Bootstrapping people with no DAI via other mechanisms and community outreach.
Partial commits to trades. eg. Place a 10,000 DAI trade and allow it to be picked up in blocks larger than 500 DAI at a time.
More chains, get this thing working on Bitcoin via Rootstock, on Ethereum Classic and Binance Chain.
A lot of the above features will be prioritized more clearly as we get user feedback, and we will be posting fairly frequent updates and articles on our info site. If you don't want to miss anything, note the subscribe widget and sign up!
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