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.
- Over $200m has been stolen impersonating users of cryptocurrency platforms by one group alone. Here's a list of 10 social engineering attacks against corporate companies. Here's an even larger case. While verification methods are improving, so are methods of identity theft and social engineering. We now have sim swapping and deep fake videos to contend with. Hackers have massive database sets of personal information they can utilize. As the sums at stake increase, so to will the level of effort criminals are willing to undertake. Obscurity for an insecure system will only postpone an attack until the "jackpot" is large enough.
- 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.
Thank you for participating in the AMA session with Pundi X co-founder and CEO Zac Cheah.
For those of you who may have missed it, the live recording of the AMA session held on July 3 at 10:00 am GMT+8, tackling Q2 progress and addressing questions and concerns by the community members, can be viewed here. A side note that today’s AMA video quality and setting was not ideal. We acknowledge this situation and will make improvement for our next AMA session.
You may also find a summary of the Q2 progress presentation as well as all the detail Q&A below.
## Pundi X Q2 2019 Highlights
* Pundi X has integrated more public chains into our products. In Q2, we completed integration of Binance Chain. NEM chain is in the work. As of today we’ve launched BNB, the Binance Chain native Coin and XEM, NEM native coin on Pundi X payment platform. We will integrate at least one more public chain in Q3.
* The transactions on XPOS for Q2 is 15.5 million in USD, which is close to 300% quarterly growth. The number of transactions is 29,367, which leads to a 11% growth QoQ.
* XPOS has successfully received FCC and KC certifications. A new certification for Latin American market is on the way. * To expand XPOS footprint, Pundi X’s integration with a new leading mainstream point-of-sales device is in the work. Stay tuned for the announcement.
* Pundi X Open Platform was launched in May, 2019, which now supports ERC20 and BEP2 token listing. Moving forward, we will continue to support tokens from other public chains.
* A 3,000 XPASS order from DigiX, a gold-based token, and a 10,000 XPASS order from BitCobie this quarter.
* XPOS is spread in use in over 30 countries. We’ve published a map of XPOS location of self-report XPOS merchant directory. You can find a list of selected XPOS merchants at [https://www.pundix.com/products\](https://www.pundix.com/products)
. * The QoQ growth of XWallet is tremendous at 43%. In the previous quarter, we have less than 20k users, whereas in Q2 we have hit 297k XWallet users. More updates on XWallet:
* Supported BNB and NEM tokens; 2FA, face ID, and optimized SMS serviceAvailable on iOS, Android as well as in Samsung Galaxy Store
New features coming up in Q3:- DApp integration - Decentralized wallet- In-app crypto payments - Chat service, which will be compatible with a commonly used chat app- f(x) testnet features to be rolled out first in XWallet
## Other notices coming up in Q3 2019
* The Q2 token removal will take place on July 14, 2019, which will involve in total 34 billion of NPXS and NPXSXEM (22 million worth in USD) removal. In the past 365 days, we’ve removed a total of 36.1 million US dollar worth of NPXS and NPXSXEM.
Before Q2 removal, the total supply of NPXS ERC20 is 266,962,422,906.53 and NPXSXEM is 95,816,218,929. [See Q1 removal here.](/pundix/recap-of-ama-with-zac-on-july-3-and-q2-report-a23de165dd28)
* [NPXSXEM will be ported to Binance Chain from July 20](/pundix/npxsxem-will-be-on-binance-chain-c6485f17726b). * XPhone pre-order will start in late July with a new product name. Stay tuned. Check out the teaser video that we are releasing it across our communication channels. ## Q&A ## On XPOS
* **Where are we on official global location of XPOS?**
Zac: We have made a map on our official website that merchants can self report and feature their locations. It’s at [https://www.pundix.com/product\](https://www.pundix.com/product)
. We’ll be increasing and updating the map once we have permission form the merchants to update their locations.
* **The marketing from pundi has shifted from 100,000–700,000 xpos units by 2021 to 100,000. I understand the bear market has affected this but please share the strategy moving forward to hit your goal. How do you feel about hitting this goal?**
Zac: The 100K XPOS target has always been the initial goal and it’s stated in our whitepaper. And we are still working on achieving the goal by the end of 2021. Part of our growth strategy is to also explore the possibility to port our platform to traditional POS manufacturers to increase the adoption, which is ongoing at the moment.
* **1 year ago you sent 5000 XPOS somewhere. When, at least half of them, will be working? 3 year target was 100,000 by 2021. Now we have only 150 units, how do you expect to reach this goal?**
Zac: Yes, we have shipped thousands of XPOS to over 30 countries in the world. The 150 you’ve mentioned are the featured merchants which are published on the map. The active XPOS devices are deployed over 33 countries and we are actively talking to B2B partners to have higher wholesale and big deployments.
* **How many XPOS are live and used?**
Zac: We have gone through a very serious bear market, and some of the initial inbound requests for XPOS are not delivered. However, we are working slowly but surely with our Business Development team to not just roll-out into individual buyers, such as what we did on Pizza Day, but also to B2B partners. With the certifications approved, that will also help us to officially roll out to some of the key markets.
Individual merchants can use XWallet collection feature to accept crypto payment with QR code. For the merchants who have physical offline storefronts, they can use XPOS to enable the instant crypto transaction seamlessly. Moreover, as mentioned previously, we are exploring the integration on leading traditional POS terminal so that their distributors have option to enable crypto transaction feature. As for the challenge to adopt XPOS, it is the regulatory compliance in different countries. For this, our legal team think ahead and encourage our merchants to complete KYC.
I must be very honest to say the activation takes longer time than we expect but it will be worth at the end.
* **What’s the average number of transactions per xpos in use?**
Zac: The transaction number has increased very well. The number of each XPOS differs, due to the frequency of using crypto currency to purchase item or crypto assets. There’s no standard answer to this, but overall we see the transaction number and volume are going up.
* **How do you plan to reach the target of 100,000 by 2021?**
Zac: One of the challenges that we have is regulatory compliances in different countries. There are certain markets that do not allow crypto currencies and some require a clear approval for us to deploy XPOS. We are working on both challenges by talking to governments and applying for certifications. So how we plan to reach 100,000 XPOS user by 2021 is to work with distributors, B2B partners on a government / business level, and with existing POS companies to integrate our software solution into the system.
* **We understand as there was bear market and hence Xpos usage demand was low. Are you guys seeing growth of Xpos usage with current market conditions. Can you guys put some statistics comparison like last 30 days Xpos usage vs any month from bear market usage?**
Zac: It is very clear that as we moved out from the bear market, the demand for XPOS has been increasing. As we’ve shared just now both the transaction number and volume of Q2 have beaten Q1. We’ll be able to share more transaction numbers once we receive approval from our XPOS merchants.
One exciting thing is that, with the listing of different tokens, we also see users using these tokens as a way to transact on XPOS, which means we will be having more ways to transact and this is a growth point for XPOS.
* **When will there be more details for XPHONE and XPOS HANDY?**
Zac: For XPOS handy, we have finished production and it will be released in Q3
* **When will the iOS version of XWallet and XPOS be fully translated to other languages?**
Zac: Right now, the XWallet has Traditional Chinese, Korean, Spanish, German and English. With the latest version update, it now includes Portuguese. XPOS also comes with many languages and we hope to finish with more language, either working with professionals or volunteers. If you’re interested in volunteering, please contact us.
* **When will the Merchant back office have Product Registration and SKU id ability and also integrate with other POS software?** * **When will the top-up feature go away for XPOS to allow liquidity for XPOS**
Zac: We constantly update features in XPOS and merchant backend to make it easier for distributors and merchants to use. We understand that one of the ways for mass adoption is to enhance our distributor management system. With that, the distributors can manage manay XPOS at one time with different merchants.
Please stay tuned as we announce more and more functions of this feature. ## On Dubai
* **When will we see the deployment of the XPOS in Dubai?** * **Can we spend NPXS on the Dubai XPOS?**
Zac: As with all big projects there are a lot of moving parts, that includes working very closely with the local government, in Dubai’s case, the Credit Bureau of the Finance Ministry. Things are progressing for the Dubai project but due to confidentiality agreements with the parties involved, we cannot reveal much. All we can say is that we and our Dubai partners are working hard to have XPOS roll-out in the Dubai market and the UAE.
We are also discussing aggressively with Dubai partners whether to include crypto assets in the XPOS in Dubai. That clearly will involve local compliance and legal for that to happen.
* **Your system upgrades expect merchants to have downtime on their XPOS terminals, can you explain if you plan to run a business why this would be considered feasible (specially at the rate you have been doing your upgrades)?**
Zac: Yes, the benefit / strength of the XPOS is that most of the updates can be done on the fly. For example, when we have a token update on our XPOS where developers submit their tokens on Open Platform, the updates of this token are on the fly, which means that once we approve the token on our Open Platform, it will automatically appear on XPOS without any software updates.
The great thing that we believe about XPOS is not just the support of crypto assets, but also the ability to update most things on the fly, which means that whenever we have a good feature or a new token, the updates will be done instantaneously.
* **Can you guys arrange at least a community voting which is the next blockchain we would like to see next in XPOS? Voting will help to prioritize to chose the projects.**
Zac: One of the reasons why BNB is being listed on the XPOS is simply because of its popularity and also our user demand, in a way that we are already answering to our community’s request.
Right now, our main focus is getting all the tokens submitted on Open Platform to be listed on the XPOS. The submission process includes legal and compliance valid, so our legal and compliance teams are working hard to make sure that we have more tokens to roll out onto Open Platform, which means that they will be on XPOS, XWallet, and XPASS.
As to a specific voting mechanism, we’d like to consider that and hopefully we’ll be able to run a specific voting for the chain which users would like to see.
* **While comparing Xpos handy to Square POS devices at least with mobile it’s very cheap like under $30 and easy to use. When can we expect such light weight and cheaper version for XPOS? Is team working on such devices ?**
Zac: There are different POS companies around the globe and pour focus is to work with these POS companies with our software, so that a crypto sales feature will be part of the existing POS system. The more support of crypto asset usage using our software on existing POS, the better it is for global adoption.
We actually strongly believe that the pricing of our POS system is competitive in the market. And one of the great features of the XPOS is that the merchants will not need not to pay a certain percentage to existing acquirer but to be able to earn certain percentage from each transaction. That is the key differentiator for merchant to want to adopt this.
* **From the website with some of the key Countries for XPOS adoption looks great. However, the concern is for Venezuela, there is no reference link like the others have. Can you guys add the link with details to clear the ambiguity?**
Zac: Let’s give a little bit more patience so that we can actually release more information about our Venezuelan partnership. The good news is that we expect concrete news from Venezuela in the coming 2 weeks. So stay up-to-date about our Venezuelan roll out on XPOS, the best way is to subscribe to our telegram group for Venezuela. ## On Partnerships
* **Are there some major partnership in the works? I’m also interested in how you do immediate transactions? Do you anticipate scaling issues?**
Zac: The way XPOS is being designed is that when you use your crypto assets to purchase, it will have instantaneous confirmation because the action is an off-chain process. An on-chain action happens when a user who owns crypto assets in our system transferring the assets out of the Pundi X ecosystem to their own wallets; or to transfer crypto assets in Pundi X from an off-chain to a private wallet, which we will have very soon on XWallet itself.
That is why we are able to handle scaling. When a person wants to use crypto currency to buy a coffee, the transaction will happen instantaneously.
For specific partnership, especially with B2B partnership, we oblige to the NDA that we have signed. But if you follow us closely, you’ll know that we go to different parts of the world, talking to major companies to try to land more deals so that NPXS usage will increase dramatically.
* **Any big partnerships for making xphone or using the software for xBlockchain?**
Zac: These partnerships are also subjected to NDA, so please be patient for us to release more news.
* **When will XPOS have approval to process Visa and MasterCard payments?**
Zac: We have met representatives from these players including some of the key management people. They are obviously looking into crypto currency attentively, and we hope that there’s something we can do with MasterCard and/or Visa.
This is something that the community has suggested and we agree fully. Please allow us with some time to work on this. We have also showcased XPOS to the CEO of MasterCard. For what or when will anything happen, please wait for our official announcement.
* **What’s the status on Quantum fund and their contribution or involvement with Pundi’s project?**
Zac: We announced last year that we are creating a fund to invest in projects beneficial to our ecosystem. We’ve identified some interesting projects, and we have invested in at least 1 project. The reason why we’re investing in that project is because of the services that it will bring onto the Pindi X ecosystem. So the purpose of the investment of the companies is that these companies in turn will benefit on our ecosystem. This is our key consideration.
The team has evaluated the projects that will benefit the Pundi X / Function X ecosystem. Vic and his team will be able to reveal more details on the companies we have invested in and how they will contribute to our ecosystem in Q3.
* **Recent update on NPXSXEM is highly ambiguous as mentioned that it will be now BEP token and later once FX goes live it will get back to Fx platform. Why you guys had so rush to use Binance chain only for few months? Isn’t you guys switching to much in a short time span?**
Zac: Liquidity and utility have been an issue for NPXSXEM. Due to the design philosophy and the limit of token that can be created on NEM’s smart contract, we are only able to create a small number of tokens on NPXSXEM. By moving into the Binance chain for NPXSXEM, the BEP2 token version will be able to support all the NPXSXEM tokens, which means that we’ll migrate and also be able to make sure all the NPXSXEM tokens are under the same contract address.
We believe with the strong liquidity, we will be able to give our NPXSXEM token holders a good reason of what the token holders have been waiting for. We hope to bring NPXSXEM to match the level of NPXS.
* **When #XRP?**
Zac: Our OpenPlatform is a currency agnostic platform, which means that we will work on integrating public chain as well as tokens that are most requested by the users. We’ll also be looking into the listing of different tokens that are being mentioned by the community.
As said, we will have at least one more public chain integration in Q3, perhaps even more.
* **Are you as a company going to try and connect with libra? If they have said they want to be a payment remittance service, have Square, PayPal, Visa on board I as an investor would prefer you try to join them rather than beat such large competitors**
Zac: Of course, we’ll be delighted to work with Facebook and also the Libra coin. Pundi X and XPOS is a currency agnostic / currency neutral platform, if there’s opportunity to list Libra coin or work with Facebook in different ways to promote crypto currency adoption, we’ll certainly look into that and work on reaching out to them. ## On Trading
* **Can you confirm during AMA, Pundi team is not involved with any trading with their own token like selling over time to manage the fund to run the company.**
Zac: All the wallet addresses of the team holdings are disclosed and transparent. This is one of the first things that we did after ICO. Hence, our token holdings are transparent and everyone can monitor our fund transactions. Also, we have strict internal financial regulation and compliance, shows that we are here to build a long-term project.
The best way to make NPXS or the NPXSXEM to rise is real daily life use case.
* **When will you stop manipulating NPXS chart?**
Zac: Our focus has always been and will be building great products. The more product usage, the demands for NPXS and NPXSXEM will increase. Let’s address again that, Pundi X the company is NOT involved in any manipulation of the NPXS price.
There are trading teams, market makers, financial institutions that profit from the drop and rise of token prices in the crypto market. The good thing about NPXS is that we have managed to create a high liquidity by listing on 40+ exchanges and having global trades and demand from all over the world. We hope this and coupled with the fact that we are a solid product and roll out the use cases, the demand of NPXS will only continue to rise and will be able to deter any of the traders or speculators there is for NPXS.
These traders gain profit from manipulating tokens whether BTC or other tokens. In fact, the traditional financial markets have similar challenges as well. What I want to stress is that, we at Pundi X, do NOT speculate or manipulate the price. We work very hard to create demands for NPXS and as a company, it is only beneficial for us to see the prices of NPXS and NPXSXEM rise.
* **Can we please address the elephant in the room which is the Binance bot with huge sell walls and buy walls causing huge distress and concern among users?**
Zac: First, I cannot confirm nor deny that whether Binance has a bot. I think this is something that you need to ask Binance. We need to work with Binance because Binance has one of the biggest liquidities, if not the greatest liquidity, for NPXS. The best way to counter manipulators is to create more use case, more demand and more acceptance of our tokens.
* **Why on almost all exchanges do you not offer a USDT trading pair?**
Zac: We have USDT trading pairs on Bittrex, Bittrue, and more. In addition, we have fiat pairs in Korean Won, IDR, INR, and Turkish liras. We will continue to work on adding trading pairs for NPXS to make it more liquidate.
* **Why don’t you offer a stable coin sell and purchase on the xpos to help with adoption? Places in Africa with volatile currencies would go crazy for this.**
Zac: It’s a great observation. This is a request that’s been asked from many users. We’re working on stable coin listing on XPOS and hopefully it’ll come soon. Stable coin requires a greater compliance and legal validate, which we have been working on since months ago and we hope to have the stable coin up in XPOS soon.
* **When will you add an active tracker for coin burn, whether its measured in usd, NPXS or whatever you choose. The community has been asking for this on twitter, reddit and telegram for this entire year.**
Zac: It will be hard for us to have a daily tracker of the coin burn, but what we might be able to work on is a tracker which have shown all of the tokens that have been removed from the usage. Thank you for giving us this great suggestion and we will work on it in some form.
Zac: Our token supply has always been specified in our white paper, and as promised in our white paper, we will continue to remove tokens through usage and use cases, which we’re working on all the time.
* **Price movement. When will NPXS go to which price?**
Zac: We cannot comment on the change of the price. Our focus is on building products. We hope by doing that the NPXS value will go up. Again, there’s no way that we can comment on the price.
**I believe that burning tokens every 14 weeks keeps the price suppressed and will only lead to huge pumps and dumps. Imo, If the burns were more frequent, the price would move organically.**
Zac: We continue removing tokens quarterly per advised by our legal and compliance team.
**Is it mandatory npxs swap? What happens for token we have in binance?**
Zac: No it’s not a mandatory NPXS swap for FX.
**How many NPXS or NPXSXEM was converted?**
Zac: In Q2, we will remove 29B NPXSXEM and 9B NPXS. ## On XWallet
* **Why not put in XWallet like the place where we can buy and sell like restaurants and shops?**
Zac: You are correct. In fact, if you look at XWallet, there is a merchant feature, whereby you can register as a merchant. By becoming a merchant, you will be able to print out your QR code and stick it on your restaurant. People are able to make payment through this QR code. This will act like a mini-XPOS.
* **In addition to that having multiple different blockchain in XWallet will increase the XWallet adoption. Hence, we would like to see aggressive game plan and execution from the team and would like to hear that**
Zac: That’s a great suggestion. Every day we want to increase use cases for XWallet. In fact, our XWallet update is one of the most frequent in the market. Within 5 months, we have over 10 updates on iOS and Google Play. This does not include soft update which happens every several days. In my view, the effort is very tremendous.
* **Is there any plan to add Swap option within XWallet so that people can trade the coins within XWallet?**
Zac: Yes, there’s such plan and in fact there is an upcoming feature that people will be able to use coins in XWallet to exchange into other things. The exact form and format have not been reviewed. We hope to share more when we have concrete example. But what you suggested is what we are planning for months ago.
* **When will XPOS and XWallet have fiat on ramps?**
Zac: This is a good question. It’s not only involved with regulatory compliance but also involved the technical part. This is also something we are planning for months. Once approved, hopefully we are able to support fiat currency on ramps and off ramps on XWallet.
* **How is the internal organization doing? Currently how many employees work for Pundi? Currently how many job positions are open?**
Zac: Pundi X has grown tremendously. We are now having over seven offices around the globe. I’m sitting in the Singapore office. We have office in Jakarta, Taiwan, Tokyo, Shenzhen, São Paulo and London. These are the places we have physical offices and house approximately 100 full time employees of Pundi X.
The positions open from Pundi X are legal associate in Singapore and other offices. We are looking for more R&D people, especially in Taiwan. We are looking at marketing and PR people in different parts of the world. And we are looking for POS distributors. As a POS distributor, you will work with our business development team and also our technical team to roll out many XPOS which you have a network to control in your local market.
* **Would you consider removing the KYC to allow u.s. holder to stake and be rewarded?**
Zac: We would love to have more users, including US. However, our compliance and legal advisors have not allowed us to accept US holders to stake and be rewarded.
I’m sorry to say that but this is after serious consideration to make such a decision. In fact, it is a very hard decision because we have healthy user base in the US.
will continue to monitor the situation in the different markets and be compliant. There are also ways to be rewarded when using XWallet service without KYC. We are looking into to explore more on this and launch new features. Hopefully we are able to bring the beta version for you to test this week or next. **On XPhone*\
* **Where are we on pre-sale announcement of Xphone? It was highlights of Q2 goal. If we are getting delay, that’s ok. But at least community will have some clarification why it’s getting late and when approximately it coming?**
Zac: Pre-sale order will start this month. It’s likely the end of July. Pre-sale will take place in different channel including the official website and XWallet. Apart of our own channel, the pre-sale will go live on a 3rd party channel. People will be able to pre-order crypto either in crypto or in fiat.
* **Can you discuss in AMA, is participants can pay with Crypto or Credit/debit card or in both ways?**
Zac: As a crypto company, we prefer payment in crypto, but fiat, Visa, MasterCard, and other traditional payment methods will be accepted on different pre-order channels. Stay tuned for pre-order which will happen in late July.
* **Will the Xphone be open to purchase in all regions of the world?**
Zac: Yes, pre-orders will be able to be done on-line, and products will be shipped from our offices to users in different parts of the world.
* **Will the blockchain mode on the Xphone be operable during the testnet or will this function not work until mainnet?**
Zac: XWallet and XPhone are the first channel and avenue for Function X testnet, so once the testnet is operateble, we will start to engage certain services on XWallet and XPhone into Function X testnet, and ultimately into mainnet. Slowly but surely.
* **Does Xphone have hard protective cover,extra Sim slot, also is it enhanced with ip68 water rating?**
Zac: XPhone will not be waterproof, so please do not submerge XPhone into water. XPhone will definitely be eavesdrop-proof because we’re using a blockchain mode, only you and you control your own conversation.
* **Which country accept the Xphone?** * **Will I also be able to use the SIM-card?** * **The blockchain modus will work in every country (what in the absense of nodes)?** * **Will the XPhone I buy now support updates in the future?**
Zac: People from any country will be able to buy XPhone on-line. You will be able to use a SIM for we have built a SIM slot. Wherever you are, the XPhone can be turned on to become a node.
Will XPhone support future updates? Yes, of course. Just like the XPOS, we support silent update. It will be like how we support XPOS, many updates. The updates will always be supported on XPhone. **On Function X*\
* **When is the detail white paper coming for FunctionX? Why the team is very resistive to have well documented white paper? We need scientific approach and well documentation on FunctionX to have developers to be more involved.**
Zac: Yes, developer involvement is a key criterion of the growth of Function X. We have done 2 things, one is that we have set up Function X Foundation which is led by David Ben Kay and will involve third party adviser and board members. Second, we have set up a developer relations team led by one of our own members as well. This team will work on creating developer documents, developer demos and sample, so that excellent developers can tap into working with Function X resources.
The first version of developer documentation is ready in English and Chinese. We are still polishing up the documents and hopefully to release them soon.
We are also working with third party developers, and are engaging at least 2 third party developer companies, so that we can help create their services on Function X and also XWallet.
We are hoping to showcase a smooth and usable service to the audience, we think this is the key criterion of the Function X growth.
Thank you for this suggestion. We need to update more often on github developer documentation as well.
As for the white paper, we did not have one per se because Function X did not do an ICO. But we will continue to update our white paper and include not only technical details, but also details on the chain and how we can get more developers and users so that the future hardware will be added as a node and you will be rewarded financially, at least through our ecosystem genesis fund. Please stay tuned and there are a lot of things going on in the company. Each and one of us is working hard.
* **Why does the FX ecosystem need a decentralized OS?**
Zac: The mantra of Function X is decentralization and having private control of your data. A full private control of your data comes with a decentralized system not just in transmission of your data, but with the operating system built fully for decentralization , which includes a transmission protocol replacing http. The apps uploaded into Function X will be decentralized as well as the data that is stored on the app, which means that how BitCoin or crypto assets are verified on different nodes will also be part of the way we store data and content.
The decentralized OS is key to fulfilling a decentralized environment for a more private and free usage.
* **What about FX are you most excited about?**
Zac: We are actually creating a shift of how people view of blockchain and how decentralization is not just about transacting commercial commodity, but also data, including your identity, are all decentralized. That is what we are most excited about.
The only way for us to achieve this is to have developer support, for we need the developers to build on the foundation we have to offer those exciting services.
* **We understand that developing a new blockchain is time consuming. As a community we are in a dark space to understand where exactly the development of FX right now.**
Zac: We are working hard on creating the testnet and eventually the mainnet. For the latest updates of Function X, what I can encourage you to do is to go on and subscribe to the Function X telegram group where discussions are made. We have formed the Function X Foundation and created the developer relations team, so that the Function X progress will go smoother and with more partnership from outside, whether it’s developers, third party companies, teleco, etc.
* **When FX goes live on the mainnet, will FX coin be used to stake and earn NPXS? how will staking work on that new mainnet?**
Zac: The NPXS/NPXSXEM staking will last till March 9, 2020 as announced. What we are committed is to create more use cases. For FX tokens, the use cases will be focusing on the Function X Chain and the use cases on Function X that include DApp on Function X and different hardware/software services.
* **When fx testnet will be available?**
Zac: First I would like to thank you for your constant support. In Q3, we plan to open Function X testnet so that we will be migrating and creating certain use cases that can be used on Function X testnet, starting with our own XWallet. Which means, the XWallet will migrate some features into Function X testnet, and slowly followed by our other Pundi X products, including XPhones, XPASS, Open Platform and Function X own developer related products from third parties.
What’s up everyone!
Yeah, it’s another one of “those”. But honestly, after being in the game for long enough, you end up developing an eye for the good coins. Not the “good” ones, the GOOD ones. Believe it or not, research and common sense is the name of the game!
A little bit more about me: I come from a business & logistics management background. I started investing in cryptocurrencies and trading a little more than six months ago. As a person, I am very detail oriented and I’ve been researching all kinds of cryptos, for hours a day, for the past six months. The more I researched, the more I learned, the more I became hungry for knowledge, and therefore the more i researched. From trading to cryptocurrency basics, their economics, their political implications, the technology revolution they represent, the human psychology aspect as well as emotional trading behaviours (FOMO, FODO, etc.), all of it!
I’ve purchased Ethereum at 150$ (when I first started in crypto). Then NEO back when it was still AntShares and trading under 3$. Gas (Antcoin back then) at 30c, OMG when it was sub-1$, and ETP at exactly a dollar (selling it later at 5$). This was all before I even knew how to do a basic margin trade & was still in the process of learning about crypto (and while tether still had a “reasonable” market cap! LOL)
My approach is pretty simple when it comes to crypto. I split coins into seven main categories:
-Store of Value (BTC)
-Payment (DASH, BCH, LTC)
-Pure Anonymity and/or Evil Stuff (XMR)
-Platform/platform’ish (ETH, NEO, LISK, CARDANO, ETP, Iota, Factom and the likes)
-Shitcoins (99% of ERC20 tokens)
-Absolute Shitcoins (Boolberry, Embercoin et al.)
-Fee Split / Dividend Coins
That last category is my favorite. While I do strongly believe in diversification (10% store of value, 10% payment, 5% anonymity, 25% platform in my case), I always have a “lean” towards coins that make business sense. Coins that derive their value directly from the amount of usage the platform gets (Factom, for example). Coins such as NEO, BNB, Kucoin, Coss, ICN, TenX and the likes, basically coins that either have a direct “dividend-paying” property (NEO generating gas, Kucoin/Coss awarding holders with a % of the exchange’s trading fees) or an indirect “dividend paying” property such as BNB, ICN, TenX using quarterly profits to buy back their own coins and burn them, thus raising the value of the rest of the coins in circulation over time.
Now let’s look at market caps of these direct and indirect “dividend” coins.
Kucoin: 44M (68M at ath, not too long ago)
You see that odd one there with only 5M market cap? Yeah. That’s the great buy right now. That’s the x10, x20 or even x30 that most people haven’t realized yet. That’s also the “dividend coin” you can scoop a ton of while it’s on the cheap, and make massive recurring revenue from as the exchange solidifies and evolves.
What is COSS? COSS stands for Crypto One Stop Solution. They’re a Singapore based cryptocurrency exchange with an amazing team that’s currently expanding. They aim at becoming the “One Stop” solution for crypto, meaning A) an exchange, B) a payment gateway for merchants to accept crypto payments, and probably sometime in the future C) crypto debit/credit cards. They offer their own coin (COSS coin), and holders of this coin receive 50% of the trading fees generated by the exchange (more on this later).
Now, what a lot of people still don’t realize in crypto, you don’t invest in the bigger market cap coins expecting to make a killing (“the moonshot”). Sure, they’ll bring you nice long term growth as the whole market matures, and that’s where you want to diversify and solidify your portfolio, solid coins with a purpose. But what if you want more thrill? An actual opportunity to “moon”? You find a project that makes business sense, that has at least a working product, and a good team. Buying NEO at 2.5B market cap? You missed the boat, it was a dollar a few months ago and already went x60 (“mooned”), and now stabilized at roughly x38. OMG had it’s x10-15 already. BNB as well. Their market caps are big, and a lot of buying needs to happen to even double in price.
Antshares (NEO) back then was a steal at 1, 2 and 3$. It was a huge risk, with huge rewards. They didn’t even have a product other than their blockchain. No dApp running or even being built on it, no english resources to even figure out how to code on it and deploy a smart contract, no marketing, hell we didn’t even know if Da Hongfei was still alive. All it was is a Chinese based smart contract platform, with an innovative dBFT concensus algorithm. It was a 100M market cap coin that early adopters believed in, and essentially invested in when it was not much more than a website and a blockchain. Look where it’s at now, with more than a dozen dApps being built on it, a solid team of roughly 10 devs, with the NEO council also funding City of Zion (team of 20+ NEO devs). NEO has grown into an incredible community, and is now launching coding dApp contests left and right, with the latest one in partnership with Microsoft china & offering half a million dollar’s worth in prizes.
NEO holders get rewarded with GAS on a daily basis. When NEO gets further adoption, all fees such as registering an asset, deploying a contract, changing an asset, etc. will be redistributed to NEO holders as well on a pro rated basis. Only transaction fees are not, as those will go out to MasterNodes. If you got yourself a thousand NEO’s back when they were a dollar or two a piece, you’re now generating 7 gas per month. That’s roughly 161$ USD per month, on a recurring basis, at current gas prices, out of a 1000$ investment. That’s a whopping 16.1% PER MONTH on original investment, and not even counting the fact that you pretty much made 37000$ profit on the NEO’s themselves. Today? Well, you gotta dish out 38000$ to buy a thousand neos and make 161$ per month, basically bringing you 0.4% per month on original investment.
Same with bitcoin. Early adopters that got it at pennies. It just hit $10K USD a piece. For every 30 cent spent purchasing bitcoin in 2009, you’d have $10K USD in the bank account. Invested 3$? 100K. Invested 30$? 1M.
Ethereum? From a dollar to half a grand now.
Moral of the story? Early adoption pays off.
History repeats itself, and it will continue to do so. Bitcoin was digital money for nerds, ethereum was a cool project that nobody really gave a crap about until they got EEA which showed credibility (early adopters of eth had a great vision, I’ll give them that!). Neo was chinese vaporware. What do they all have in common? Their.Early. Adopters. Made. A. Killing.
Look where they stand now. Look where a lot of coins stand now. Even a lot of ERC20 tokens that don’t even really have a reason to exist have market caps over 100M. And for what? They don’t reward you with anything other than price increasing because more people buy (greater fool theory)? They don’t reward you with dividends from the project/platform itself? Their value isn’t derived directly from the amount of usage it gets (a la Factom, PaulSnow
you genius.)? They still don’t even have a minimum viable product to show? When you ask yourself why does it need a coin, and the answer is either “uhh…” or “oh it grants you voting rights” (that nobody gives a crap about, let’s be honest), you should reconsider your investment strategy. Cause I can tell you a lot of people don’t know what the hell they’re doing, and they’d be better off diversifying in the top 5 or 10 coins and holding than investing in the shitcoinfest that crypto has become.
And that’s why COSS is a pretty buy right now. You’re investing in a platform that’s already up and running,
not a whitepaper or vaporware. Hell even Eth and Neo were riskier investments for early adopters. Let’s go over the cons first:
It’s ugly. The UI sucks.
It doesn’t have API’s yet, meaning there’s no bots to create liquidity, and therefore low volume.
It’s been fudded to death by KuCoin shills (and their referral links you’ve seen everywhere a month ago).
Charts are horrible
That’s about it. Whenever you read up about coss, those are the cons you’ll find. But what about the pros? Well, all of this is in the process of being fixed, as we speak.
Singapore has lax laws about cryptocurrencies and issued a statement it does not feel the need to regulate them.
It’s securing exclusive ICO’s already despite being a tiny exchange, and has mentioned being able to secure from 4 to 6 per month.
The team listens to the community’s feedback and takes it seriously. This is Gold
. One of the first things they were criticized about was trying to do too many things at once (an exchange, a payment gateway, a full one-stop solution for crypto, etc.) and they’ve taken the community’s advice and decided to focus solely on the exchange for now and build it properly, before branching out to the rest. “Better excel at one thing and build from there, than be mediocre at multiple things at once”
Also following community feedback, they are implementing trading promotions “a la Binance”. Part of the total supply of COSS tokens will be donated to charities
(the community votes to who they go). First of all, that’s just plain nice. Secondly, I find it pretty damn cool that we donate this for good causes, and they basically keep “generating” income from it. It’s basically like a “perpetual donation” on behalf of COSS and all of its users, and definitely will make a lot of people feel good about using the exchange. Thirdly, this pretty much guarantees millions of COSS tokens are going to be in perpetual “HODL” mode, essentially taking them off the market. They will be implementing a FIAT gateway sooner than later. We all know FIAT gateways are game changers.
They are constantly hiring. The team growing is definitely a good sign.
They are revamping the overall UI and charts, once again following the community’s advice, and the proposed new look is fantastic!
Check it out here, as well as other great announcements: https://medium.com/@runeevensen/coss-io-7379b7628d93 EDIT: It has been brought to my attention that there is a UI upgrade scheduled for tomorrow (Dec. 3rd), although it isn't clear if it's a minor one or the actual major overhaul, might wanna keep an eye out on that! They are upgrading the matching engine and releasing API’s soon to allow bots to create liquidity and significantly raise the trading volume. Unlike KuCoin, the revenue split (COSS token holders) will always receive 50% of the fees, whereas kucoin will start decreasing it in 4-6months and it will bottom out at 10-15% The revenue split from trading fees is controlled by a DAO, meaning the COSS team cannot arbitrarily decide to change it later down the line
, unlike KuCoin where the control over the fee split is centralized and they decrease it as they please. The DAO model also avoids it being labeled a security
. First of all, those aren’t really “dividends” as dividends would require them to calculate income minus expenses to determine profit, and then distribute this profit to shareholders, and obviously that’s a legal nightmare. With the DAO model, you don’t get a percentage of the “profits”, you get a revenue split from the exchange fees, and it’s done by clicking a “distribute” button which makes a call to the smart contract and distributes your coins. COSS itself is not giving you anything COSS is still in Beta. It has a tiny market cap.
Now’s the time to pick it up, not when it’s out of beta and has become successful, or you’ll be in another Antshares/NEO situation. A ridiculously small move from 5M to 50M in Mcap and that’s x10, a move from 5M to 150M (still under binance levels) and that’s x30.
In the long run, COSS aims to be more than just an exchange. Holders of the token, who currently get 50% of the exchange’s trading fees, will also get 50% of other fees charged from coss. This includes their eventual payment gateway.
Merchants around the world wishing to accept crypto payments will be able to use COSS’s gateway and COSS will charge a 0.75% fee per transaction. We, as COSS holders, also get 50% of that. You believe crypto is the future and going mainstream? Well your COSS will entitle you to the revenue generated by tens of thousands, if not hundreds of thousands of businesses accepting crypto payments via COSS Point-Of-Sale.
COSS also mentioned that all other COSS “fee generating” products to come will all be subject to the same DAO/50% split. Logically, If they have 1) The trading platform, and 2) the payment gateway, then the third step is solving the problem of spending the crypto in places that don’t accept direct crypto payment, AKA a crypto credit/debit card. Well, guess what? Users of such cards will be charged a small fee as well when their crypto is being converted to fiat in real time for payment at a gas station. We as COSS holders are, again, getting 50% of that fee.
As you can see, this is a coin that makes business sense to invest in. Unless you really, reaaaaaally care about a coin being the “Future of decentralized prediction markets” or “the future of decentralized dating” or the “decentralized gambling coin” and whatnot. Smart money is smart. It's only a matter of time before savvy investors discover this coin.
What do the dividends look like (credits to lickmypussy28
Here’s an excel showing the Yearly %ROI based on the COSS exchange volume and your COSS token buy-in price: https://i.imgur.com/XKjjCbZ.png
Here’s another one showing how much you’d make in USD per year based on how many COSS tokens you own, again all relative to the volume on the left: https://i.imgur.com/p15DKAr.png
Lastly, here’s another showing the exact same as above but on a weekly basis: https://i.imgur.com/ezp5FCV.png
ALTHOUGH, keep in mind, the calculations above take into consideration an average trading fee of 0.2% and while this fee is accurate right now, it will most likely average 0.1% once API’s are released and liquidity/market maker bots start operating on the platform. Also, the calculations above do NOT take into consideration that in 4 years from now, there will be 200M (hard cap) COSS tokens on the market. HOWEVER, these calculations also do not take into consideration that by then, COSS will have a fully up and running payment gateway, crypto credit cards, and other revenue-generating products such as a crowdfunding platform, smart contract deployment platform, etc. that are also generating revenue for COSS holders.
All in all, if all goes as planned, the payment gateway/cards/other products will negate the additional COSS tokens released in the market as well as the average trading fee of 0.1%, and therefore the numbers presented in the excel docs will remain sensibly the same. Also, if crypto really takes off in the mainstream, then the revenue split to coss holders from the payment gateway & credit card spending could very well double, triple or quadruple all the numbers you’re seeing in these excel sheets, and that’s on the low end.
Remember, the exchange only charges 0.2% (0.1% average once we have bots) out of which we get half, but the payment gateway on the other hand charges a flat 0.75% (7.5x the what the exchange’s fee), out of which COSS holders get half.
This could be a massive revenue driver, easily surpassing the exchange itself, and honestly if at that point in time this coin is NOT valued at 3B+ (I mean, even ethereum classic is over that right now..
), then I’ll just give up on the whole notion of logical thinking.
Quick example, assuming in 4 years 50M in gateway processing daily (18B yearly), 0.375% of that would be 187.5K USD daily for COSS holders. With 200M Coss tokens total supply, if you hold 10K coss you’d generate 9.375$ per day (65$ per week, 282$/mo.), and that’s purely from the gateway (totally excluding the exchange revenue, crowdfunding revenue, credit card revenue, etc.). If you have 100K coss you’d generate 93.7$/day, 650$/week, 2820$/mo, again purely from the gateway.
If you’d rather assume more conservative figures (let’s say 25M in daily gateway processing on COSS, all around the globe, or 9B yearly), then simply divide these figures by half. If you wanna go balls to the walls, double them (100M daily, 36B yearly). Play around, have fun with the numbers! To keep things in perspective, square has processed 50B’s worth of transactions in 2016. Therefore I believe using 9B, 18B and 36B for our calculations isn’t too far fetched, and actually pretty reasonable.
Anyway, to sum this up, no matter how you look at it, COSS is an extremely promising project with huge potential, and actually has working math (and a working beta!) behind it. It’s only a matter of a month or two before they’re out of their Beta, have upgrades to their UI and engine, and start really growing from there. The team listens to the community, which is super important, and they’re working on a multitude of revenue streams, out of which not only them, but all coss holders will benefit from, fifty fifty.
Their crowdfunding platform will be a competitor to indiegogo, gofundme, kickstarter, and they’ll have a small percentage fee (50% of which goes to COSS holders). The crypto Point-Of-Sale will be a competitor to Square and the likes (50% revenue to COSS holders). The crypto credit card (also 50% revenue to COSS holders). It is truely an admirable project. Shovel manufacturers made a killing during the gold rush, and COSS is positioning itself as the shovel manufacturer in the crypto adoption gold rush. This is a coin that makes sense to invest in, it is ultra tangible, and will give greater returns than any type of “decentralized [insert function here]” type coins. On a personal note: Honestly, I believe this is the proper way to ICO, by NOT giving people worthless tokens that only go up in value due to speculation (looking at you, 99% of ERC20 tokens). Let investors guide you, let them reap 50% of the rewards as THEY are the ones funding you. This’ll keep the investors interested in the project, and every single one of them will have a direct incentive to vouch for your product. It’s only right for the investors to get rewarded with something tangible, I’d take that any day over a speculative shitcoin who’s only purpose was to put money in the project’s founders pockets
Oh, and cherry on the sundae: they are planning on launching massive marketing campaigns
as soon as UI and trading engine are ready, Q1 2018, as you can see in Rune’s Nov 27th update. I suggest you read it, it puts us up to date on a lot of exciting new things: https://medium.com/@runeevensen/coss-io-update-november-27th-fa74f1237062 Quoted directly from said link: “For those that are most interested in discussions regarding the trading price of COSS. Please have in mind that when we entered our token sale, our clear sales message was a 3–5 year road-map, and not a 3–5 months pump and dump. We are a small team, doing our utmost to deliver and all we ask is for you to continue to give us feedback and also for you to give us some time to deliver. *
That being said. We still aim to be out of BETA as soon as possible with a new engine for the exchange in Q1 2018. New UI should be in place well before that.** Once we feel we have this in place we will roll out massive marketing campaigns to attract users and increased volume. So although we have a 3–5 year road-map ahead, you should expect to see 2018 being “our year”. The 3–5 year plan is more on the complete roadmap when we proudly can call ourselves a one-stop solution.
For now it is all about the exchange, and there we will see rapid changes over the coming weeks/months.”*
All in all, i’d like to thank the COSS team for actually caring about their investors, keeping them in the loop, listening to their feedback and giving them a unique and tangible opportunity. I’d also like to thank all the other COSS investors, who see a huge potential in this project and support the team, and lastly, all of you crypto-heads for reading through!
Happy hodling, and hopefully see you all at 500M+ market cap by late 2018 :)
-Some random guy on Reddit.
PS: Not investment advice. Always do your due diligence.
Also, if you’d like, you can join the discussion at /cossIO
Friendly reminder: ETH is the quickest way to get your funds on the COSS exchange, and COSS/ETH pair has 4x the volume of the COSS/BTC pair.
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