Bitcoin Forum

I have registered with a couple of the bitcoin lending sites and am waiting for my validation to complete.  In there interim I was wondering if anyone here might want to talk bitcoin startup.  (edit: This is not a request for a loan, just a discussion)

I put up a poll in the newbie section:

Would you use an ATM machine to buy Bitcoins?
Yes   - 26 (83.9%)
No   - 0 (0%)
Maybe   - 5 (16.1%)
Total Voters: 31

https://bitcointalk.org/index.php?topic=286114.0


My business partner has been programming ATM machines for years.  We are highly confident we can use a state of the art "money recycling" ATM machine to sell bitcoins directly to the public.  We are both in Colorado and so, naturally, we'd like to place the ATM machine in Denver.  Denver is the state capital and largest city in Colorado.  The state is home to 5 million people and more than 57 million visitors throughout the year.

We have permission from a busy retail chain store owner to place ATM machines on his properties.  
We have the skills to manage the project.  

What we are seeking is a 6-12 month loan to purchase a few ATM machines and test the concept.  The ATM machines, which hold their value well, become the collateral for the loan.

We would purchase a "SelfServ" model with a "cash recycler"  from this product line: http://www.ncr.com/products/banking/atm-machine

We will be seeking 150 BTC to start and will pay a fixed interest rate each month until the loan is paid in full.  

September 2, 2013:
At the moment this is not an offer to enter a loan agreement but an exploration of interest in the idea.  We are not seeking lenders right now but we would like to start conversations with anyone who might be interested or have questions.

notes:

-Need competent council to determine what laws apply and how to avoid breaking them.

No.
Scams involving third-party secure private (but deleted right away, promise!) key generation are getting old, now.

https://bitcointalk.org/index.php?topic=278220.0

This is one of the latest examples. I'm afraid this kind of business has no future.
Bitcoins are supposed to go to one peer to another.

No trusties in the middle.

How else can bitcoin be distributed? (Through a kiosk / machine).  I was thinking the private key distribution made sense. 

You could have the BTC sent to a wallet but you'd need to tell the machine your wallet address.

If you are suggesting that the owner of the machine (me) would scam because owner of the machine (me) knows the private key I think it's unlikely given the enormous expense of the machine and installation.  If it cost me $20k to put the machine in a location and I scammed the first user and they reported that here in the forum I would never recover my investment, so I think it's unlikely the machine operator would steal.  Right?

 

How do you plan on dealing with the regulatory issues?  How do you plan on identifying and verifying customer identities.  The tech is trivial, the laws/regulations not so much.  If you intend to just operate above the law, well consider how incredibly easy it is to seized an expensive public fixed asset like an ATM.

Why would bitcoin need to be distributed through a kiosk/machine?
Why having a portable wallet device holding the private keys you chose to upload to it wouldn't be enough?

First, we don't intend to operate outside the law.  I am unaware of any law that requires a "seller of bitcoin" to do anything special.  I am aware of MSB laws but I am not sure they apply unless I am selling bitcoin that I mine or buying and selling like an exchange.  

As only a seller of "numeric codes" I'm not sure what regulations specifically apply.  FWIW these are the kind of questions we need to address before we launch so I really appreciate you asking.  


I agree the tech is trivial.  In my mind it's no different than an automatic movie ticket vending machine I see at Fandango theaters, except we won't accept credit cards ;-)




It does not, obviously since you and I have bitcoin and we have never used such a machine.  My poll in the newbie section, however, demonstrates people are interested in using such a device.  

Your selling Bitcoins.  MSB regulations apply.  Depending on the exact business model and the wording of state laws money transmitter requirements in one or more states apply.  It is a very complicated issue and likely will require legal counsel.

Not sure why you conditioned your explanation with "like an exchange".  By FinCEN's guidance if you are exchanging BTC for USD or USD for BTC then you are a money service business.

[quote[As only a seller of "numeric codes" I'm not sure what regulations specifically apply.[/quote]

Most US dollar are simply numeric codes.  That isn't much of a legal defense for anything.

Only because the only action I'm aware at the federal level was the Mt Gox seizure and I assume the problem there was they are acting as an exchange.  I'm not a lawyer and I recognize the need for one.  

Other than filing as an MSB what do you think we'd need to do?  (And what do we need to do as an MSB?)

Comply with the Bank Secrecy Act.  At a minimum know your customers, collect identitifcation, record transactions, report suspicious transactions to FinCEN and develop an AML program.

If Walmart doesn't need to check ID when selling prepaid visa's, surely a machine can do the same, right?

Can't I just adopt the same policy Walmart uses where they don't check ID up to $300 per day per person?

Asking for investments/loans seems a bit premature until you get your legal act together.

From the OP

You might get more potential discussion if you move this to project development. You're not discussing a loan here.

I hope to be soon and I value input from this forum in creating a workable structure.  The larger community does not have your insight, Vod.

Then get input from the community!

You will not get the proper information here.  The people that read this forum want to lend coins - they have little interest in the laws of a bit coin ATM.

Move to project development forum and you will get higher quality responses.  :-)

If some "for obvious reasons we stay anonymous" company runs it, I would certainly not invest.
If my brother runs it, I would invest.
With anybody in between these two, I would invest more or less time to decide if it's worth the hassle.

This is wrong. For most people who are selling bitcons, MSB regulations do NOT apply. However, if you are selling AND buying bitcoins for fiat (e.g. exchanging) and doing it as a business they probably will, depending on State, blah, blah, extensive legal morass, etc.

+1

Not a lawyer but I think you're gonna need some big hitter investors to comply with all 50 state laws for MSBs. You're gonna need someone w/ deep pockets that shares the same vision. It's onerous but dem's the breaks.

I would def. invest with one that did the above.

FinCEN makes no distinction between selling Bitcoins, buying Bitcoins or buying and selling Bitcoins.   

I would invest FOR CERTAIN.  If you guys are really intent on doing this (despite the stiff competition from other bitcoin atm companies [I believe there are now to at the moment in pre-order stage]), then perhaps consider putting together 5btc and then beggining an asset of shares to trade on bitfunder.  This way, you could get startup capital, and have a way to publicly trade your company like an asset. 

Yes, please, not only in US

not in US... other countries yes

Sorry one and all (Vod) the admins moved this back to the lending section.  I'll try again....

You can edit the first post.  At first glance it still appears you are looking for a loan rather than looking for information.  Cleaning up the OP will likely prevent future (mis)moderation.

As pointed out, you'll definitely have to register with FinCen, but the nice thing about an ATM is that you won't have to deal with 50 state MSB licensure all at once. If you start in Colorado you'll likely only need the federal registration and a Colorado MSB license (if required). Anyway, you should definitely obtain legal advice from an experienced MSB attorney because this isn't like selling any old widget. Check out the legal forum (https://bitcointalk.org/index.php?board=74.0), as at lease one attorney posts there regularly.

Also, you might want to check out this project, which I believe has now started manufacturing.
https://lamassu.is/

I would invest if you

a) had 1 working prototype (hence they don't sell premade, fully functional Bitcoin ATMs, yet ;D)
b) could get this arms-length agreement to multiple retail locations, in writing
c) had a rock solid plan to tackle the legal issues
d) you could prove you had some other type of collateral to recoup my investment, if the "ATM as collateral" idea goes south
d) elaborated further on you and your partner's backgrounds/experiences

Robocoin and Lamassu seem to be moving right along with this same concept. If you're serious about it, I'd get started on it ASAP


Good luck!  ;)

the idea is great. i think personally i would use it. if installed in shopping centre it could draw attention for new potential users. though you might have issues with authorities when they find out that bunch of drug dealers dumping their dollars into your atm. i would also recommend you to seek professional advise. ohh and btw... good luck with the project!

Bitcoin ATM already exists.

get MSB license and buy one; place in that store this fall:

https://lamassu.is/

I don't know, maybe I need glasses but I see "pre-order now" and not "on stock".

We all know that businesses scare competitors by announcing products just around the corner. BFL anybody?

I sense a difference here

I've placed an initial loan request on BTCJam:
https://btcjam.com/listings/6769

If you have any interest in this project, please consider lending.

Actually I'd say I am quite aware of the requirements.  Kindly read this post and it's replies.. I welcome followup questions there:


https://bitcointalk.org/index.php?topic=289952.0

Coin ATM. We should talk. I will be operating a Lamassu and be fully compliant in Atlanta, GA in October.


atlantabitcoin.com (http://atlantabitcoin.com)

You lucky bastard! (being in Georgia).

590-4-2-.08 Invest Georgia Exemption.
http://rules.sos.state.ga.us/docs/590/4/2/08.pdf

We have a commitment from an investor, thank you swordv2!

Come join us: https://btcjam.com/listings/6769

I hope you find investors, as I find the idea of BTC ATMs to be magical.  But I'd be scared of the federales.

Regulation is an issue but I think it will be resolved shortly, Great Idea!
I would invest!

We are currently 10% of the way toward our goal.

Please come join us! https://btcjam.com/listings/6769

Have you thought about putting ATMs in other countries with less stable currencies? BTCs could be a good alternative if you educated the people.