If anyone had a chance to watch the CFTC/SEC hearing today in Washington, I'd be curious to hear your opinion. In my opinion, this hearing in general was positive for the future of cypto currencies. While still pretty vague in many aspects, there appears to be support for moving this technology forward. A majority of the concern was with scams and "unregulated" ICO's. While I couldn't agree more, I doubt many of these are in their jurisdiction. My hope, as time goes on, we'll see a self regulating body come to the surface. These blockchains are world wide, and obviously no one country can govern this space.
One of the points made, was how not one ICO has come to the SEC for their approval. I can only imagine the hurdles that must be jumped over to even get this far. I know the DNotes team has at some level, looked at this avenue in the past. Can you share your thoughts on what it would take to be the "first" company to apply for this ICO approval, and possibly why DNotes has chosen not to take this road? We see the many benefits of the Reg A+, title IV, tier II, mini IPO offering, however this approval process is expensive and time consuming. Could the application for an ICO, through the SEC/CFTC achieve the same results, and less headache perhaps, as what is trying to be achieved through the Reg A+, title IV, tier II, mini IPO offering?
While this would not offer DNotes Global Inc. the exposure to the OTC, and traditional market participation, could this be an alternative for future funding while gaining notoriety for being the "first" ICO application? Could it also cut down on the burdensome expenses, audits and compliance hurdles? What about a relationship with potential banking partnerships needed to move forward in the future? ie future exchange, on/off ramp. (Pretty sure I know the answers to last couple questions)
To take this a little further, as crypto currencies become more excepted and banks possibly feeling threatened and auditors not necessarily willing to risk their name on the dotted line, how could this effect DNotes Global Inc.'s ability to be/stay in compliance? Could an legitimate ICO eliminate this? (Is that an oxymoron?) Something tells me any path taken here in the U.S., will have nothing but red tape and hurdles.
I believe 100% DNotes is taking the right path, but my hope is third parties wont make it too difficult to achieve a third party-less system.
Denver Dan, thanks for sharing. I had the opportunity to watch an extensive portion of the SEC/CFTC Senate Committee on Banking hearing in Washington today. Although, it was by no means definitive or comprehensive, I felt that it was positive, fair and objective. It was acknowledged that what we are witnessing could be transformational and become very big. I took it that timely attention in confronting the challenges while preserving opportunities for the innovative technologies to flourish was warranted. I was also encouraged to recall a remark that the currency component go together with the underpinning blockchain technologies. Just one or the other would not have gained my attention or justification to characterized it as the greatest technology revolution since the Internet.
There is a frequent lack of understanding, that under existing rules and regulations there are no provisions for the SEC to register or grant an exemption to a cryptocurrency, as we know it. Being a decentralized autonomous entity, no one controls it. It is self-governing by algorithm with embedded rules.
As it is today, the SEC can only interface with human individuals, partnership, companies, etc., using it as its only means of getting full disclosure of all relevant materials, representations, and reporting requirements. In most cases it is very burdensome complex, costly, and time consuming.
From my prospective, it is not possible for a coin to be a registered or exempt ICO with the SEC. A third party must be involved as an individual, partnership or company. This should clearly explain why not one single ICO is registered or exempt with the SEC, according to Chairman Jay Clayton. If there is a way around it, I certainly will be all out to have DNotes launch the first ICO with the SEC approval registered or exempt.
The path that we chosen is certainly burdensome, costly, and time consuming, but the best path in consideration of available options and our long-term vision. My biggest challenge so far has been recruiting a team of professionals who have sufficient working knowledge to assist us with sufficient comfort of the realities of our industry. It has not been easy, and the current state of our industry is certainly not helpful. Nonetheless, I am totally committed to make it happen. I trust that the launching of DNotes 2.0 on March 18, 2018 will give us great momentum to move our Reg. A+ Mini-IPO forward.