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.
The next XVG? Microcap 100x potential actually supported by fundamentals!
What’s up team? I have a hot one for you. XVG returned 12 million percent in 2017 and this one reminds me a lot of it. Here’s why: Mimblewimble is like Blu-Ray compared to CD-ROM in terms of its ability to compress data on a blockchain. The current BTC chain is 277gb and its capacity is limited because every time you spend a coin, each node needs to validate its history back to when it was mined (this is how double spending is prevented). Mimblewimble is different - all transactions in a block are aggregated and netted out in one giant CoinJoin, and only the current spending needs to be verified. This means that dramatically more transactions can fit into a smaller space, increasing throughput and lowering fees while still retaining the full proof of work game theory of Bitcoin. These blockchains are small enough to run a full node on a cheap smartphone, which enhances the decentralization and censorship resistance of the network. The biggest benefit, though, is that all transactions are private - the blockchain doesn’t reveal amounts or addresses except to the actual wallet owner. Unlike earlier decoy-based approaches that bloat the chain and can still be data mined (XMR), Mimblewimble leaves no trace in the blockchain, instead storing only the present state of coin ownership. The first two Mimblewimble coins, Grin and Beam, launched to great fanfare in 2019, quickly reaching over $100m in market cap (since settled down to $22m and $26m respectively). They are good projects but grin has infinite supply and huge never-decreasing emission, and Beam is a corporate moneygrab whose founding investors are counting on you buying for their ROI. ZEC is valued at $568m today, despite the facts that only 1% of transactions are actually shielded, it has a trusted setup, and generating a confidential transaction takes ~60 seconds on a powerful PC. XMR is a great project but it’s valued at $1.2b (so no 100x) and it uses CryptoNote, which is 2014 tech that relies on a decoy-based approach that could be vulnerable to more powerful computers in the future. Mimblewimble is just a better way to approach privacy because there is simply no data recorded in the blockchain for companies to surveil. Privacy is not just for darknet markets, porn, money launderers and terrorists. In many countries it’s dangerous to be wealthy, and there are all kinds of problems with having your spending data be out there publicly and permanently for all to see. Namely, companies like Amazon are patenting approaches to identify people with their crypto addresses, “for law enforcement” but also so that, just like credit cards, your spending data can be used to target ads. (A) Coinbase is selling user data to the DEA, IRS, FBI, Secret Service, and who knows who else? (B) What about insurance companies raising your premiums or canceling your policy because they see you buying (legal) cannabis? If your business operates using transparent cryptocurrency, competitors can data mine your customer and supply chain data, and employees can see how much everyone else gets paid. I could go on, but the idea of “I have nothing to hide, so what do I care about privacy?” will increasingly ring hollow as people realize that this money printing will have to be paid by massive tax increases AND that those taxes will be directly debited from their “Central Bank Digital Currency” wallets. 100% privacy for all transactions also eliminates one HUGE problem that people aren’t aware of yet, but they will be: fungibility. Fungibility means that each coin is indistinguishable from any other, just like paper cash. Why is this important? Because of the ever-expanding reach of AML/KYC/KYT (Anti-Money Laundering / Know Your Customer / Know Your Transaction) as regulators cramp down on crypto and banks take over, increasingly coins become “tainted” in various ways. For example, if you withdraw coins to a mixing service like Wasabi or Samourai, you may find your account blocked. (C) The next obvious step is that if you receive coins that these chainalysis services don’t like for whatever reason, you will be completely innocent yet forced to prove that you didn’t know that the coins you bought were up to no good in a past life. 3 days ago, $100k of USDC was frozen. (D) Even smaller coins like LTC now have this problem, because “Chinese Drug Kingpins” used them. (E) I believe that censorable money that can be blocked/frozen isn’t really “your money”. Epic Cash is a 100% volunteer community project (like XVG and XMR) that had a fair launch in September last year with no ICO and no premine. There are very few projects like this, and it’s a key ingredient in Verge’s success (still at $110m market cap today despite being down 97% since the bubble peak) and why it’s still around. It has a small but super passionate community of “Freemen” who are united by a belief in the sound money economics of Bitcoin Standard emission (21m supply limit and ever-decreasing inflation) and the importance of privacy. I am super bullish on this coin for the following reasons:
Only $400k market cap
Supply started at zero, so there are no VC’s and team to dump on you into the pumps - all coins are mined into existence, just like Bitcoin.
It just had its first halving, reducing emission from 16 to 8 per block. Between now and 2028 there are FOUR (!) more halvings, from 4 to 2 to 1 and then finally 0.15 (I guess that would be an 85%-ing :p) and at this point the supply is the same as BTC and stays in sync forever until the last coin is mined in 2140. This simple supply curve is already accepted by the market as a winner, so why mess with success? (I)
Meets Andreas Antonopolous’ 5 pillars of open blockchains test: Public, Open, Borderless, Neutral, and Censorship Resistant. (How many coins can say this?)
Unlike Bitcoin, Epic created a multi-algorithm approach that enables people to mine on ordinary computers - 60% for CPU on RandomX, 38% for GPU on ProgPow, and 2% for ASIC’s on Cuckoo31+. The algorithms don’t compete with one another. This is essential for leveling the playing field and preventing massive farms from dominating. These percentages can change over time and new algorithms can be easily dropped in. You can mine today using an old laptop and in 5 years you will still be able to. Incidentally, there is nothing standing in the way of adding mobile phone-based mining, which ETN showed there’s a huge demand for.
Based off the excellent Grin codebase, which means they continue to pull in ongoing core code enhancements and focus on ease of use and market penetration instead. (Smart!)
Litecoin’s Charlie Lee is out there daily talking about their move to Mimblewimble, which provides free publicity. What people don’t realize is that you can’t just bolt on Mimblewimble to a legacy blockchain, that’s like putting a Ferrari engine into a school bus - it’s still a school bus, not a race car! LTC is doing it as an optional soft fork via “extension blocks” which will not be supported by all wallets and exchanges. Also, anyone using “optional” privacy features is declaring themselves to be suspicious, which kind of defeats the point for people who care about privacy.
The community is friendly and welcoming to new people coming in, with lots of helpful (independently created) tutorials and guides. (F)
It’s already a global phenomenon, with the whitepaper in 20+ languages (G) and (not bot-infested) active local-language communities on not only Telegram but also Wechat, LINE, QQ and other messenger platforms.
It’s only on two random little exchanges currently, Citex and Vitex. Vitex is actually a pretty good DEX with no KYC and a great mobile wallet.
They are very creative - since centralized exchanges want huge money to list, they created a non-inflationary ERC20 tracker token that’s exchangeable 1:1 for coins so that Uniswap trading is possible (H)
Because it doesn’t have a huge marketing budget in a sea of VC-funded shitcoins, it is as-yet undiscovered, which is why it’s so cheap. There are only 4 Mimblewimble-based currencies on the market: MWC at $162m, BEAM at $26m, GRIN at $22m, and EPIC at $0.4m. This is not financial advice and as always, do your own research, but I’ve been buying this gem for months and will continue to. This one ticks all the boxes for me, the only real problem is that it’s hard to buy much without causing a huge green candle. Alt season is coming, and coins like this are how your neighbor Chad got his Lambo back in 2017. For 2021, McLaren is a better choice and be sure to pay cash so that it doesn’t get repossessed like Chad!
$1,000 invested in Top 10 Cryptos of 2019 now worth $1,260 (UP +26%)
EXPERIMENT - Tracking Top 10 Cryptos of 2019 - Month Eighteen - UP +26% See the full blog post with all the tableshere. tl;dr - Tether (as it's designed to do) holds its ground, all others finish the month in negative territory. Tron finishes June in second place, down -2%. BSV loses nearly 25% of value in June. Overall, since January 2019, BTC in lead, ETH takes over second place, XRP still worst performing. The 2019 Top 10 is up +26% almost equal to the the gains of the S&P 500 over the same time period (+24%).
According to a June article citing unnamed sources, which two FinTech companies are planning to allow their users to buy and sell crypto directly?
A) Paypal and Venmo B) Square and Cashapp C) Robinhood and Revolut D) Sofi and Coinbase Scroll down for the answer.
Ranking and June Winners and Losers
XRP and Stellar slipped one place each in the rankings in June, now at #4 and #14 respectively. EOS fell two spots to #11 and joins Stellar and Tron as the only three cryptos to have dropped out of the 2019 Top Ten since January 1st, 2019. They have been replaced by Binance Coin, Cardano, and newcomer CRO. Tether was the only crypto to move up in rank in June. Not a good sign when Tether is the only crypto to move up. Not a good sign when Tether enters the Top 3. June Winners – Tether. Second comes Tron, which basically held its ground at -2%. June Losers – BSV lost -23% of its value in June making it the worst performing of the 2019 Top Ten portfolio. EOS had a rough month as well, down -17%, dropping two spots in the rankings, and falling out of the Top Ten. If you’re keeping score, here is tally of which coins have the most monthly wins and loses during the first 18 months of the 2019 Top Ten Experiment: Tether is still in the lead with six monthly victories followed by BSV in second place with three. BSV also holds the most monthly losses, finishing last in seven out of eighteen months. The only crypto not to win a month so far? XRP. (In fairness, XRP has also not lost any month yet).
Overall update – BTC in lead, ETH takes over second place, XRP still worst performing
BTC is out front for the second straight month and ETH has taken over second place from BSV. Ahead until April, BSV has simply not keep up with the pack over the last two months. Bitcoin is up +144% since January 2019. The initial $100 investment in BTC is currently worth $249. Eighteen months in, 50% of the 2019 Top Ten cryptos are in the green since the beginning of the experiment. The other five cryptos are either flat or in negative territory, including last place XRP (down -50% since January 2019).
Total Market Cap for the entire cryptocurrency sector:
The crypto market as a whole is down about $20B in June, but still up +106% since January 2019.
BitDom finally wobbled in June, but not by much – it’s been in a very familiar zone for months now, indicating a lack of excitement (or at least a low risk tolerance) for altcoins. Taking a wider view, the Bitcoin Dominance range since the beginning of the experiment in January 2019 has ranged between 50%-70%.
Overall return on investment since January 1st, 2019:
The 2019 Top Ten Portfolio lost almost $175 in June. After the initial $1000 investment, the 2019 group of Top Ten cryptos is worth $1,259. That’s up about +26%. Here’s a look at the ROI over the life of the first 18 months of the 2019 Top Ten Index Fund experiment, month by month: 18 months of ROI, mostly green Unlike the completely red table you’ll see in the 2018 Top Ten Experiment, the 2019 crypto table is almost all green. The first month was the lowest point (-9%), and the highest point (+114%) was May 2019. How does the 2019 Top Ten Index Fund Portfolio compare to the parallel projects?
Taking the three portfolios together, here’s the bottom bottom bottom line: After a $3000 investment in the 2018, 2019, and 2020 Top Ten Cryptocurrencies, the combined portfolios are worth $2,710. That’s down about -10% for the three combined portfolios. Last month that figure was +4%. Better than a few months ago (aka the zombie apocalypse) where it was down -24%, but not yet back at January (+13%) or February (+6%) levels. Here’s a new table to help visualize the progress of the combined portfolios: ROI of all three combined portfolios - not exactly inspiring How do crypto returns compare to traditional markets?
Comparison to S&P 500:
Good thing I’m tracking the S&P 500 as part of my experiment to have a comparison point with other popular investments options. Even with unemployment, protests, and COVID, the US market continued to rebound in June. It’s now up +24% in the last 18 months. The initial $1k investment I put into crypto would be worth $1,240 had it been redirected to the S&P 500 in January 2019. As a reminder (or just scroll up) the 2019 Top Ten portfolio is returning +26% over last 18 months, just about equal to the return of the S&P 500 over the same time period. Just last month the ROI of the 2019 Top Ten crypto portfolio was nearly double the S&P 500 since January 1st, 2019. But what if I took the same world’s-slowest-dollar-cost-averaging/$1,000-per-year-in-January approach with the S&P 500? It would yield the following:
$1000 investment in S&P 500 on January 1st, 2018: +$170
$1000 investment in S&P 500 on January 1st, 2019: +$240
$1000 investment in S&P 500 on January 1st, 2020: -$40
Taken together, here’s the bottom bottom bottom line for a similar approach with the S&P: After three $1,000 investments into an S&P 500 index fund in January 2018, 2019, and 2020, my portfolio would be worth $3,370. That $3,370 is up over+12%since January 2018, compared to the $2,710 value (-10%) of the combined Top Ten Crypto Experiment Portfolios. Here’s another new table that compares the ROI of the combined crypto portfolios to a hypothetical similar approach with the S&P 500: We see in June the largest difference in favor of the S&P since the beginning of 2020: a 22% gap. Compare that February, when there was only a 1% difference in ROI.
Since January 2019, the crypto market as a whole has gained +106% compared to the 2019 Top Ten Crypto Portfolio which has gained +26%. That’s an 80% gap. At this point in the 2019 Experiment, an investor would have done much better picking different cryptos or investing in the entire market instead of focusing only on the 2019 Top Ten. Over the course of the first 18 months of tracking the 2019 Top Ten, there have been instances this was a winning strategy, but the cases have been few and far between. The 2018 Top Ten portfolio, on the other hand, has never outperformed the overall market, at least not in the first thirty months of that Experiment. And for the most recent 2020 Top Ten group? The opposite had been true: the 2020 Top Ten had easily outperformed the overall market 100% of the time…up until the last two months.
As the world continues to battle COVID, traditional markets seem to be recovering. Will crypto make a significant move in the second half of 2020? Final word: Stay safe and take care of each other. Thanks for reading and for supporting the experiment. I hope you’ve found it helpful. I continue to be committed to seeing this process through and reporting along the way. Feel free to reach out with any questions and stay tuned for progress reports. Keep an eye out for the original 2018 Top Ten Crypto Index Fund Experiment and the recently launched 2020 Top Ten Experiment.
And the Answer is…
A) Paypal and Venmo According to a Coindesk report in June, three sources familiar with the matter say that Paypal and Paypal-owned Venmo are planning to allow their users to buy and sell crypto. Paypal has declined to comment.
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.
Weekly Update: 2gether has 40k users, $BOMB on Uniswap, Ghost data service, Constellation State of the Union…– 5 Jun - 11 Jun'20
Hey everyone! This is Part IV of VI from our May-June update catchup series (5 Jun - 11 Jun'20): Yosma's Cheerful Cassowary beat Eva's Bright Beetle in a quick finale to win this week's Parena which had a massive $PAR pot thanks to a generous donation from Tony. Gamer Boy’s “Random Gk” and “Renewal from January” quizzes in Tiproom were fun as always. Plus, there were 10k $PAR in prizes. Cool! Charlotte’s “Mega Trivia” got everyone scratching their heads. CoD Mobile gamers were in for an epic time this week with Tavo hosting a tournament with a 3k $PAR pot in the Parachute War Zone. Two-for-Tuesday slid into the "rap, reggae and reggaeton" mode this week. Click here to listen to the playlist. Thanks Sebastian for setting it up! If you have been around for a while, you’ll know that Clinton’s charity, For Living Independence, does some amazing work. So the next time you shop on Amazon, don’t forget to show some love though AmazonSmile. Cap and crew made their voices heard in NYC this week in solidarity with George Floyd Congratulations to 2gether for crossing the 40k user mark this week. A new way for account top ups was introduced as well. This week’s CEO email covers news on the latest UX and the 2GT token. Youtuber Funontheride featured the email in his video. Filippo Angeloni covered the latest updates in his newest video as well. Founder Savador Casquero wrote about crypto staking in an Investing.com article. MakerDAO covered the 2gether card in its blog post on crypto debit cards. Following the XIO dApp update from last week, Citizens brainstormed about the UI this week. Citizens also talked about some of their contrarian beliefs in crypto. Bomb community started a Uniswap rewards program. Voyager raised USD 2.1M through a private placement from investors such as Streamlined Ventures, Susquehanna, Market Rebellion etc. Their stock has seen some enormous growth this year too. CEO Stephen Ehrlich shared his thoughts on the crypto market in a recent Bloomberg article. The team also took inputs from the community on which crypto to list next. John McAfee announced a Ghost cell phone data service to be released in September. Check out how the eSIM will work from the sneak peek video. The list of supported phones is mentioned here. And hope you had good fun in ParJar Gaming while winning some cool $ESH. A new set of upgrades were pushed to the Fantom Wallet. For the latest technical update on the project, click here. This week, I also wrote a Hackernoon article (with my co-author Rohit) exploring projects which had unique variations to Proof-of-Stake for their chain consensus. Among the projects featured were Fantom, COTI and Harmony. Jeff from Uptrennd will be speaking at the LA Blockchain Summit in October this year. The winners of the Blockchain Awards were announced. The newest Opacity release allows expired accounts to be revived within 2 months of expiry. Fantom, Harmony and COTI take up a tiny but growing slice in the global staking pie Catch up on the latest District0x weekly update and dev update from here and here respectively. The Q1 2020 report was released as well. The project is still sitting on a healthy crypto asset base of USD 4M+. Hydro team shared a guide to choosing a prepaid debit card program manager. Their PaaS report was also covered by Finovate this week. A new research page for featuring all of Hydro’s fintech research material was released. The successful applicants of the Project Hydro Decentralization Ambassador Program (which started in May) were voted upon this week and 7 DAs were elected. Silent Notary, Ubikiri and IDL integrations were completed this week with Silent Notary now appearing in Applications section of Ubikiri. A roundup of the latest updates was published as well. Sentivate founder Thomas Marchi sat down for an interview with MineYourBiz Monday’s NrdGrl007. Mycro announced that Chaia.io will be hosting a campaign on the Mycro Hunter App soon. SelfKey’s Data Breach compendium was updated this week. And if you’re a Product Designer looking for remote work, don’t forget to check out this opening at SelfKey. What next for Constellation? Watch the Constellation Network State of The Union to find out. Their educational group Startdust Collective made a brand video and a high level explainer article on the HyperGraph Transport Protocol. Pynk is thinking about doing a global crowdfunding campaign as opposed to one that is restricted to certain countries only. In light of this, the Pynk Crowd Wisdom was put to work to find out the best way to go about this. Results of the Project Hydro DA Elections Wibson’s latest app update was covered by Cointelegraph and Europe World News. Click here to catch up on this week’s detailed work thread from the Harmony project. A recent Harmony ecosystem is the SmartStake dashboard to check staking stats. Sprout Wallet now supports core utilities of HRC20 tokens. The team sat down for an AMA with Binance India and KuCoin this week. Next week they will be doing another AMA with the larger Binance community. Some insights about the Harmony grants were shared in this week’s community call. Read up on Intellishare founder Raymond Xiong’s thoughts on DAOs which he shared as part of a speaker panel at the 2020 Digital Innovation Project Exchange Conference. The team also published a post on how they aim to solve the DeFi congestion. The TestNet is expected to arrive soon as well. After the latest livestream of DI-RECT’s concert which saw ~10k attendees, GET Protocol announced that they will be facilitating tickets to the follow-up show as well. A recap of the COTI journey was published to mark the one-year anniversary of the project and the occasion was celebrated with a fun trivia. DoYourTip community voted to have liquidity rewards for pooling $DYT on Uniswap. And with that, it’s a wrap! See you again with another update. Ciao!
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.
Crypto Banking Wars: Can Non-Custodial Crypto Wallets Ever Replace Banks?
Can they overcome the product limitations of blockchain and deliver the world-class experience that consumers expect? https://reddit.com/link/i8ewbx/video/ojkc6c9a1lg51/player This is the second part ofCrypto Banking Wars— a new series that examines what crypto-native company is most likely to become thebank of the future. Who is best positioned toreach mainstream adoptionin consumer finance? --- While crypto allows the world to get rid of banks, a bank will still very much be necessary for this verypowerfultechnology to reach the masses. As we laid out in our previous series, Crypto-Powered, we believe companies that build with blockchain at their core will have the best shot at winning the broader consumer finance market. We hope it will be us at Genesis Block, but we aren’t the only game in town. So this series explores the entire crypto landscape and tries to answer the question, which crypto company is most likely to become the bank of the future? In our last episode, we offered an in-depth analysis of big crypto exchanges like Coinbase & Binance. Today we’re analyzing non-custodial crypto wallets. These are products where only the user can touch or move funds. Not even the company or developer who built the application can access, control, or stop funds from being moved. These apps allow users to truly become their own bank. We’ve talked a little about this before. This group of companies is nowhere near the same level of threat as the biggest crypto exchanges. However, this group really understands DeFi and the magic it can bring. This class of products is heavily engineer-driven and at the bleeding-edge of DeFi innovation. These products are certainly worth discussing. Okay, let’s dive in.
Users & Audience
These non-custodial crypto wallets are especially popular among the most hardcore blockchain nerds and crypto cypherpunks.
“Not your keys, not your coins.”
This meme is endlessly repeated among longtime crypto hodlers. If you’re not in complete control of your crypto (i.e. using non-custodial wallets), then it’s not really your crypto. There has always been a close connection between libertarianism & cryptocurrency. This type of user wants to be in absolute control of their money and become their own bank. In addition to the experienced crypto geeks, for some people, these products will mean the difference between life and death. Imagine a refugee family that wants to safely protect their years of hard work — their life savings — as they travel across borders. Carrying cash could put their safety or money at risk. A few years ago I spent time in Greece at refugee camps — I know first-hand this is a real use-case. https://preview.redd.it/vigqlmgg1lg51.png?width=800&format=png&auto=webp&s=0a5d48a63ce7a637749bbbc03d62c51cc3f75613 Or imagine a family living under an authoritarian regime — afraid that their corrupt or oppressive government will seize their assets (or devalue their savings via hyperinflation). Citizens in these countries cannot risk putting their money in centralized banks or under their mattresses. They must become their own bank. These are the common use-cases and users for non-custodial wallets.
Let’s take a look at some of the strengths with non-custodial products.
Regulatory arbitrage Because these products are “non-custodial”, they are able to avoid the regulatory burdens that centralized, custodial products must deal with (KYC/AML/MTL/etc). This is a strong practical benefit for a bootstrapped startup/buildedeveloper. Though it’s unclear how long this advantage lasts as products reach wider audiences and increased scrutiny.
User Privacy Because of the regulatory arbitrage mentioned above, users do not need to complete onerous KYC requirements. For example, there’s no friction around selfies, government-issued IDs, SSNs, etc. Users can preserve much of their privacy and they don’t need to worry about their sensitive information being hacked, compromised, or leaked.
Absolute control & custody This is really one of the great promises of crypto — users can become their own bank. Users can be in full control of their money. And they don’t need to bury it underground or hide it under a mattress. No dependence, reliance or trust in any third parties. Only the user herself can access and unlock the money.
Now let’s examine some of the weaknesses.
Knowledge & Education Most non-custodial products do not abstract away any of the blockchain complexity. In fact, they often expose more of it because the most loyal users are crypto geeks. Imagine how an average, non-crypto user feels when she starts seeing words like seed phrases, public & private keys, gas limits, transaction fees, blockchain explorers, hex addresses, and confirmation times. There is a lot for a user to learn and become educated on. That’s friction. The learning curve is very high and will always be a major blocker for adoption. We’ve talked about this in our Spreading Crypto series — to reach the masses, the crypto stuff needs to be in the background.
User Experience It is currently impossible to create a smooth and performant user experience in non-custodial wallets or decentralized applications. Any interaction that requires a blockchain transaction will feel sluggish and slow. We built a messaging app on Ethereum and presented it at DevCon3 in Cancun. The technical constraints of blockchain technology were crushing to the user experience. We simply couldn’t create the real-time, modern messaging experience that users have come to expect from similar apps like Slack or WhatsApp. Until blockchains are closer in speed to web servers (which will be difficult given their decentralized nature), dApps will never be able to create the smooth user experience that the masses expect.
Product Limitations Most non-custodial wallets today are based on Ethereum smart contracts. That means they are severely limited with the assets that they can support (only erc-20 tokens). Unless through synthetic assets (similar to Abra), these wallets cannot support massively popular assets like Bitcoin, XRP, Cardano, Litecoin, EOS, Tezos, Stellar, Cosmos, or countless others. There are exciting projects like tBTC trying to bring Bitcoin to Ethereum — but these experiments are still very, very early. Ethereum-based smart contract wallets are missing a huge part of the crypto-asset universe.
Technical Complexity While developers are able to avoid a lot of regulatory complexity (see Strengths above), they are replacing it with increased technical complexity. Most non-custodial wallets are entirely dependent on smart contract technology which is still very experimental and early in development (see Insurance section of this DeFi use-cases post). Major bugs and major hacks do happen. Even recently, it was discovered that Argent had a “high severity vulnerability.” Fortunately, Argent fixed it and their users didn’t lose funds. The tools, frameworks, and best practices around smart contract technology are all still being established. Things can still easily go wrong, and they do.
Loss of Funds Risk Beyond the technical risks mentioned above, with non-custodial wallets, it’s very easy for users to make mistakes. There is no “Forgot Password.” There is no customer support agent you can ping. There is no company behind it that can make you whole if you make a mistake and lose your money. You are on your own, just as CZ suggests. One wrong move and your money is all gone. If you lose your private key, there is no way to recover your funds. There are some new developments around social recovery, but that’s all still very experimental. This just isn’t the type of customer support experience people are used to. And it’s not a risk that most are willing to take.
Integration with Fiat & Traditional Finance In today’s world, it’s still very hard to use crypto for daily spending (see Payments in our DeFi use-cases post). Hopefully, that will all change someday. In the meantime, if any of these non-custodial products hope to win in the broader consumer finance market, they will undoubtedly need to integrate with the legacy financial world — they need onramps (fiat-to-crypto deposit methods) and offramps (crypto-to-fiat withdraw/spend methods). As much as crypto-fanatics hate hearing it, you can’t expect people to jump headfirst into the new world unless there is a smooth transition, unless there are bridge technologies that help them arrive. This is why these fiat integrations are so important. Examples might be allowing ACH/Wire deposits (eg. via Plaid) or launching a debit card program for spend/withdraw. These fiat integrations are essential if the aim is to become the bank of the future. Doing any of this compliantly will require strong KYC/AML. So to achieve this use-case — integrating with traditional finance —all of the Strengths we mentioned above are nullified. There are no longer regulatory benefits. There are no longer privacy benefits (users need to upload KYC documents, etc). And users are no longer in complete control of their money.
One of the great powers of crypto is that we no longer depend on banks. Anyone can store their wealth and have absolute control of their money. That’s made possible with these non-custodial wallets. It’s a wonderful thing. I believe that the most knowledgeable and experienced crypto people (including myself) will always be active users of these applications. And as mentioned in this post, there will certainly be circumstances where these apps will be essential & even life-saving.
However, I do not believe this category of product is a major threat to Genesis Block to becoming the bank of the future.
They won’t win in the broader consumer finance market — mostly because I don’t believe that’s their target audience. These applications simply cannot produce the type of product experience that the masses require, want, or expect. The Weaknesses I’ve outlined above are just too overwhelming. The friction for mass-market consumers is just too much. https://preview.redd.it/lp8dzxeh1lg51.png?width=800&format=png&auto=webp&s=03acdce545cd032f7e82b6665b001d7a06839557 The winning bank will be focused on solving real user problems and meeting user needs. Not slowed down by rigid idealism like censorship-resistance and absolute decentralization, as it is with most non-custodial wallets. The winning bank will be a world-class product that’s smooth, performant, and accessible. Not sluggish and slow, as it is with most non-custodial wallets. The winning bank will be one where blockchain & crypto is mostly invisible to end-users. Not front-and-center as it is with non-custodial wallets. The winning bank will be one managed and run by professionals who know exactly what they’re doing. Not DIY (Do It Yourself), as it is with non-custodial wallets. So are these non-custodial wallets a threat to Genesis Block in winning the broader consumer finance market, and becoming the bank of the future? No. They are designed for a very different audience. ------ Other Ways to Consume Today's Episode:
The power players of consumer finance in the 21st century will be crypto-native companies who build with blockchain technology at their core.
The crypto landscape is still nascent. We’re still very much in the fragmented, unbundled phase of the industry lifecycle. Beyond what Genesis Block is doing, there are signs of other companies slowly starting to bundle financial services into what could be an all-in-one bank replacement. So the key question that this series hopes to answer:
Which crypto-native company will successfully become the bank of the future?
We obviously think Genesis Block is well-positioned to win. But we certainly aren’t the only game in town. In this series, we’ll be doing an analysis of who is most capable of thwarting our efforts. We’ll look at categories like crypto exchanges, crypto wallets, centralized lending & borrowing services, and crypto debit card companies. Each category will have its own dedicated post. Today we’re analyzing big crypto exchanges. The two companies we’ll focus on today are Coinbase (biggest American exchange) and Binance (biggest global exchange). They are the top two exchanges in terms of Bitcoin trading volume. They are in pole position to winning this market — they have a huge existing userbase and strong financial resources. Will Coinbase or Binance become the bank of the future? Can their early success propel them to winning the broader consumer finance market? Is their growth too far ahead for anyone else to catch up? Let’s dive in. https://preview.redd.it/lau4hevpm7f51.png?width=800&format=png&auto=webp&s=2c5de1ba497199f36aa194e5809bd86e5ab533d8
The most formidable exchange on the global stage is Binance (Crunchbase). All signs suggest they have significantly more users and a stronger balance sheet than Coinbase. No other exchange is executing as aggressively and relentlessly as Binance is. The cadence at which they are shipping and launching new products is nothing short of impressive. As Tushar Jain from Multicoin argues, Binance is Blitzscaling. Here are some of the products that they’ve launched in the last 18 months. Only a few are announced but still pre-launch.
Binance is well-positioned to become the crypto-powered, all-in-one, bundled solution for financial services. They already have so many of the pieces. But the key question is:
Can they create a cohesive & united product experience?
Binance is strong, but they do have a few major weaknesses that could slow them down.
Traders & Speculators Binance is currently very geared for speculators, traders, and financial professionals. Their bread-and-butter is trading (spot, margin, options, futures). Their UI is littered with depth charts, order books, candlesticks, and other financial concepts that are beyond the reach of most normal consumers. Their product today is not at all tailored for the broader consumer market. Given Binance’s popularity and strength among the pro audience, it’s unlikely that they will dumb down or simplify their product any time soon. That would jeopardize their core business. Binance will likely need an entirely new product/brand to go beyond the pro user crowd. That will take time (or an acquisition). So the question remains, is Binance even interested in the broader consumer market? Or will they continue to focus on their core product, the one-stop-shop for pro crypto traders?
Controversies & Hot Water Binance has had a number of controversies. No one seems to know where they are based — so what regulatory agencies can hold them accountable? Last year, some sensitive, private user data got leaked. When they announced their debit card program, they had to remove mentions of Visa quickly after. And though the “police raid” story proved to be untrue, there are still a lot of questions about what happened with their Shanghai office shut down (where there is smoke, there is fire). If any company has had a “move fast and break things” attitude, it is Binance. That attitude has served them well so far but as they try to do business in more regulated countries like America, this will make their road much more difficult — especially in the consumer market where trust takes a long time to earn, but can be destroyed in an instant. This is perhaps why the Binance US product is an empty shell when compared to their main global product.
Disjointed Product Experience Because Binance has so many different teams launching so many different services, their core product is increasingly feeling disjointed and disconnected. Many of the new features are sloppily integrated with each other. There’s no cohesive product experience. This is one of the downsides of executing and shipping at their relentless pace. For example, users don’t have a single wallet that shows their balances. Depending on if the user wants to do spot trading, margin, futures, or savings… the user needs to constantly be transferring their assets from one wallet to another. It’s not a unified, frictionless, simple user experience. This is one major downside of the “move fast and break things” approach.
BNB token Binance raised $15M in a 2017 ICO by selling their $BNB token. The current market cap of $BNB is worth more than $2.6B. Financially this token has served them well. However, given how BNB works (for example, their token burn), there are a lot of open questions as to how BNB will be treated with US security laws. Their Binance US product so far is treading very lightly with its use of BNB. Their token could become a liability for Binance as it enters more regulated markets. Whether the crypto community likes it or not, until regulators get caught up and understand the power of decentralized technology, tokens will still be a regulatory burden — especially for anything that touches consumers.
Binance Chain & Smart Contract Platform Binance is launching its own smart contract platform soon. Based on compatibility choices, they have their sights aimed at the Ethereum developer community. It’s unclear how easy it’ll be to convince developers to move to Binance chain. Most of the current developer energy and momentum around smart contracts is with Ethereum. Because Binance now has their own horse in the race, it’s unlikely they will ever decide to leverage Ethereum’s DeFi protocols. This could likely be a major strategic mistake — and hubris that goes a step too far. Binance will be pushing and promoting protocols on their own platform. The major risk of being all-in on their own platform is that they miss having a seat on the Ethereum rocket ship — specifically the growth of DeFi use-cases and the enormous value that can be unlocked. Integrating with Ethereum’s protocols would be either admitting defeat of their own platform or competing directly against themselves.
The crypto-native company that I believe is more likely to become the bank of the future is Coinbase (crunchbase). Their dominance in America could serve as a springboard to winning the West (Binance has a stronger foothold in Asia). Coinbase has more than 30M users. Their exchange business is a money-printing machine. They have a solid reputation as it relates to compliance and working with regulators. Their CEO is a longtime member of the crypto community. They are rumored to be going public soon.
Let’s look at what makes them strong and a likely contender for winning the broader consumer finance market.
Different Audience, Different Experience Coinbase has been smart to create a unique product experience for each audience — the pro speculator crowd and the common retail user. Their simple consumer version is at Coinbase.com. That’s the default. Their product for the more sophisticated traders and speculators is at Coinbase Pro (formerly GDAX). Unlike Binance, Coinbase can slowly build out the bank of the future for the broad consumer market while still having a home for their hardcore crypto traders. They aren’t afraid to have different experiences for different audiences.
Brand & Design Coinbase has a strong product design team. Their brand is capable of going beyond the male-dominated crypto audience. Their product is clean and simple — much more consumer-friendly than Binance. It’s clear they spend a lot of time thinking about their user experience. Interacting directly with crypto can sometimes be rough and raw (especially for n00bs). When I was at Mainframe we hosted a panel about Crypto UX challenges at the DevCon4 Dapp Awards. Connie Yang (Head of Design at Coinbase) was on the panel. She was impressive. Some of their design philosophies will bode well as they push to reach the broader consumer finance market.
Early Signs of Bundling Though Coinbase has nowhere near as many products & services as Binance, they are slowly starting to add more financial services that may appeal to the broader market. They are now letting depositors earn interest on USDC (also DAI & Tezos). In the UK they are piloting a debit card. Users can now invest in crypto with dollar-cost-averaging. It’s not much, but it’s a start. You can start to see hints of a more bundled solution around financial services.
Let’s now look at some things that could hold them back.
Slow Cadence In the fast-paced world of crypto, and especially when compared to Binance, Coinbase does not ship very many new products very often. This is perhaps their greatest weakness. Smaller, more nimble startups may run circles around them. They were smart to launch Coinbase Ventures where tey invest in early-stage startups. They can now keep an ear to the ground on innovation. Perhaps their cadence is normal for a company of their size — but the Binance pace creates quite the contrast.
Institutional Focus As a company, we are a Coinbase client. We love their institutional offering. It’s clear they’ve been investing a lot in this area. A recent Coinbase blog post made it clear that this has been a focus: “Over the past 12 months, Coinbase has been laser-focused on building out the types of features and services that our institutional customers need.” Their Tagomi acquisition only re-enforced this focus. Perhaps this is why their consumer product has felt so neglected. They’ve been heavily investing in their institutional services since May 2018. For a company that’s getting very close to an IPO, it makes sense that they’d focus on areas that present strong revenue opportunities — as they do with institutional clients. Even for big companies like Coinbase, it’s hard to have a split focus. If they are “laser-focused” on the institutional audience, it’s unlikely they’ll be launching any major consumer products anytime soon.
Coinbase Wrap Up
At Genesis Block, we‘re proud to be working with Coinbase. They are a fantastic company. However, I don’t believe that they’ll succeed in building their own product for the broader consumer finance market. While they have incredible design, there are no signs that they are focused on or capable of internally building this type of product. Similar to Binance, I think it’s far more likely that Coinbase acquires a promising young startup with strong growth.
Other US-based exchanges worth mentioning are Kraken, Gemini, and Bittrex. So far we’ve seen very few signs that any of them will aggressively attack broader consumer finance. Most are going in the way of Binance — listing more assets and adding more pro tools like margin and futures trading. And many, like Coinbase, are trying to attract more institutional customers. For example, Gemini with their custody product.
Coinbase and Binance have huge war chests and massive reach. For that alone, they should always be considered threats to Genesis Block. However, their products are very, very different than the product we’re building. And their approach is very different as well. They are trying to educate and onboard people into crypto. At Genesis Block, we believe the masses shouldn’t need to know or care about it. We did an entire series about this, Spreading Crypto. Most everyone needs banking — whether it be to borrow, spend, invest, earn interest, etc. Not everyone needs a crypto exchange. For non-crypto consumers (the mass market), the differences between a bank and a crypto exchange are immense. Companies like Binance and Coinbase make a lot of money on their crypto exchange business. It would be really difficult, gutsy, and risky for any of them to completely change their narrative, messaging, and product to focus on the broader consumer market. I don’t believe they would ever risk biting the hand that feeds them. In summary, as it relates to a digital bank aimed at the mass market, I believe both Coinbase and Binance are much more likely to acquire a startup in this space than they are to build it themselves. And I think they would want to keep the brand/product distinct and separate from their core crypto exchange business. So back to the original question, is Coinbase and Binance a threat to Genesis Block? Not really. Not today. But they could be, and for that, we want to stay close to them. ------ Other Ways to Consume Today's Episode:
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