New Release date for DNOTES2.0? Was supposed to be September 2017
That is correct, cf_mm. |
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Very busy day for our team working on many different areas. We now have a book publicist to promote the book, and I just signed off with a new law firm to start drafting our Reg. D 506 (c) Private Placement Memorandum to be filed with the SEC. The funding could begin as early as this April. The Reg. A+ Mini-IPO Tier 2 will be launched at the later half of this year with a great deal of up front work.
Wishing all our friends, family, and supporters around the world a Happy, Healthy, and Prosperous Chinese New Year!
That is great news, Alan! I'm really looking forward to the launching of DNotes 2.0! Thank you, wiser. I am very excited about DNotes 2.0 launch and have been actively working with our team to make the best decision at every point. Once successfully launched, I believe it will fill the "technology void" DNotes has been perceived to be lacking. What our industry may not realize is that we are very mindful of strategic timing. Our industry is still at its infancy. The technology is still evolving. Based on reports, 80 to 90% of the blockchain projects have failed or abandoned. We pretty much expected that it would be the case. We purposely waited for the technology to become more mature to avoid many pitfalls typical new industry. Meanwhile, we focused our limited resources in building our ecosystems block by block - all strategically linked. There are two remaining blocks - DNotes 2.0 and funding. They are now our two highest priorities. Once accomplished, the next phase of rapid growth will begin. Be sure to drop in with your best wishes this Sunday. It's DNotes 4th anniversary. Looking back, it's amazing what we have accomplished. |
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Very busy day for our team working on many different areas. We now have a book publicist to promote the book, and I just signed off with a new law firm to start drafting our Reg. D 506 (c) Private Placement Memorandum to be filed with the SEC. The funding could begin as early as this April. The Reg. A+ Mini-IPO Tier 2 will be launched at the later half of this year with a great deal of up front work.
Wishing all our friends, family, and supporters around the world a Happy, Healthy, and Prosperous Chinese New Year!
Excellent work Alan, finding the right team is very difficult -- especially when there are crossover skills required in the professional's field into digital currency. The Reg D 506 offering will really get things kicking off! Thanks, it has been a great day. Got a lot of important things accomplished. One major remaining task is finding a highly qualified PCAOB compliance auditor for our Reg. A+ funding. I can now appreciate why so few care to take this route and just limit the participation to accredited investors only. It has been a struggle finding qualified professionals who have a sufficient working knowledge of our industry - technical, financial, and legal. We could take the easy route of launching a Reg. D 506 (c) available only to accredited investors without any upper limits to raise adequate funding for our foreseeable needs. But that will go against our basic mission to be inclusive of all interested participants, including non-accredited investors. I am relentlessly committed to this project and have no doubt that we are doing the right thing. It will be to our benefit over the longer-term. This will further differentiate DNotes from our industry peers. |
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Very busy day for our team working on many different areas. We now have a book publicist to promote the book, and I just signed off with a new law firm to start drafting our Reg. D 506 (c) Private Placement Memorandum to be filed with the SEC. The funding could begin as early as this April. The Reg. A+ Mini-IPO Tier 2 will be launched at the later half of this year with a great deal of up front work.
Wishing all our friends, family, and supporters around the world a Happy, Healthy, and Prosperous Chinese New Year!
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Been lurking for a while on here. Really like the angle DNotes took in approaching funding and crypto in general.
Are there any plans to get marketing / more community involvement? At the moment the subreddit is totally dead and discord seems to be the primary avenue of communication these days (for good reason) where Dnotes has no presence at all. Any plans on stepping up on those fronts around the time of the launch of DNotes 2.0 next month?
Welcome doctorlw1, thank you for your interest in DNotes and suggestions. Appreciate the reminder on Reddit, I had a few updates to send over there. We do have plans for an aggressive marketing plan scheduled for our fundraising efforts and the release of DNotes 2.0. Discord - I've only looked into it briefly. It appears to be designed as a IRC / TeamSpeak / Conference type platform and seems to be a good place to send people to chat. The question is, is it worth spending resources there? How does it benefit DNotes? and, How much does it benefit DNotes? It would be very low cost / minimally resource intensive for DNotes to maintain a Discord channel as most of the heavy lifting would be done by the community itself. Obviously one employee at minimum would need to update announcements, be around to answer occasional questions, tech support.. but that's no different than maintaining a presence on bitcointalk. Yes, IRC/Teamspeak is a pretty accurate depiction. The biggest advantage is it allows the community to interact with each other very easily as well as provide an easily accessible centralized location for the most up-to-date information. Most discord channels are arranged as some variation of the following: # announcements (official announcements and links) # rules # faqs # general chat # support (for wallet issues, etc) # business / development # trading (for people to talk about price and not clog up other channels with more in depth discussion) # alternative languages # anything. I've seen a number of creative uses with these channels. A strong community is key to growth and while the DNotes bitcointalk presence is a good one, a discord channel is really key to organically growing a community. I've noticed that telegram is starting to take a back seat to Discord as people realize it's just a much better platform. I think the uses will be readily apparent if you look at some successful discords, a couple great examples of active and well run discords are (among many others): Nano https://discordapp.com/invite/JphbBasElectra - which has really taken a community coin to the next level with creative uses of Discord https://discordapp.com/invite/B8F7JdvI don't think it's necessarily a priority now, but as DNotes 2.0 get's closer to launch next month and interest starts picking up I wouldn't be overlooking a very cheap, cost effective way of attaining organic community growth. Electra in particular has been good at taking advantage of the community by quickly organizing the members to go and vote to get listed on exchanges (they almost always win community vote now). Thank you for sharing, doctorlw1. Your support for DNotes is greatly appreciated. We will take your recommendation of a discord channel seriously, as we get closer to DNotes 2.0 launch. Voting support to get DNotes listed on larger exchanges will be quite valuable. |
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Here is the current checklist. I encourage everyone to contribute. Looking good DNotes team! A couple ideas I have, that might already be part of the plan; An address book for the DNotes vault. I have many friends and family that use the vault, and it would be nice to be able to store their address so we don't have to ask each time we want to transfer. A basic phone app, if security would allow. Just a simple way to access our vault, maybe with withdraw limitations. A way to transfer DNotes within the vault, and on the blockchain. Also, maybe a shapeshift type application within to exchange currencies on the go. It's all coming together nicely. Exciting times for the DNotes community. Thanks for all the hard work Joe, Alan, Tim, Kevin and the rest of the team. Appreciate it Dan, good suggestions. Mobile definitely needs to be on the list. Shapeshift integration is a great idea as well, once we release DNotes 2.0 and start marketing it as well as getting listed on some of the bigger exchanges will be natural. Thank you, Dan. Going through that check list is a good remainder of how much our lean and agile team has accomplished in four years – that is the result of mostly volunteered time and financial contributions from a few individuals. We never asked the community for donation or used any ICOs for funding. Everything has been based on a personal commitment to do the right things for the benefits of everyone who supports our cause. DNotes will become a classic case that when common people get together with a common purpose and commitment to pursue a shared vision, uncommon result of the highest expectation can be achieved – the best in class. Recently, I have the privilege of seeing a preview of DNotesEDU, funded and managed by volunteers who are also part of the DNotes team. It was inspirational. I am certainly anxious to see the reaction of our community when it is officially launched. And as I understand, it will be very soon. The whole philosophy behind DNotes and our ecosystems is hard for most people to understand. It is especially difficult when one is only exposured to a segment of what we are about. DNotes is more than just another digital currency. It is a uniquely positioned digital currency being built with fully integrated ecosystems to the benefits of everyone. We are dedicated to educating and leading by example. We believe that for our industry to succeed, someone must contribute to those vital roles. The launching of DNotes 2.0 will mark the completion of our first phase and the beginning of an exciting phase two – one of technology enhancement and rapid scaling globally. Meanwhile, we are totally focused on two top priorities – launching DNotes 2.0 and two rounds of funding – Reg. D 506 (c) and A+ Mini-IPO in compliance with the SEC securities laws. At the right time we will active many more PR efforts, social media, and participation in other discussion channels. In the meantime, it is best for our team to remain highly focused. Thanks for your list of recommendations. Keep them coming. |
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I am not sure if everything will be normal again in two weeks. But things are certainly beginning to settle - regaining more favorable sentiments. Next Bitcoin Bull Run to Occur in 2 Weeks: Pantera By Investopedia Updated February 13, 2018 — 6:00 AM EST As bitcoin, the world’s largest cryptocurrency by market capitalization, continues to rebound from its lows reached last week, one hedge fund manager expects a major price surge right around the corner. In an interview with CNBC, Pantera Capital founder and Chief Executive Officer Dan Morehead made bullish calls on bitcoin and the cryptocurrency market in general, suggesting that despite a decline that coincided with a larger market sell-off, the digital currency space is back on track to rake in returns for investors. (See also: City of Berkeley Considers ICO to Raise Funds.) “We’re certainly aware that it’s a very speculative market,” said Morehead. “Its volatile on the upside, but it can be volatile on the downside.” 71-Day Countdown The cryptocurrency enthusiast noted that bitcoin had a 64% fall from its peak around $20,000 to its recent trough, “and that’s exactly the average decline in the bitcoin market over the last seven bear-market cycles.” Adding that while “the past doesn’t predict the future,” Morehead indicated that the dip seems like the right correction for the digital currency based on historical price fluctuations. The hedge fund CEO also said that bitcoin has had an average bear market of 71 days, and that the current cycle is in its 52nd day. “So it seems like another couple of weeks and everything will be kind of normal and it could start grinding back up,” he stated. Read more: https://www.investopedia.com/news/next-bitcoin-bull-run-occur-2-weeks-pantera/ |
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Here is another reminder that the cleaning-up process will continue, with more regulatory enforcement involving other agencies. New Jersey Halts Cryptocurrency Firm Bitstrade from Fraudulently Offering Unregistered SecuritiesFebruary 12, 2018 @ 8:32 am By JD Alois Source: https://www.crowdfundinsider.com/2018/02/128290-new-jersey-halts-cryptocurrency-firm-bitstrade-fraudulently-offering-unregistered-securities/The State of New Jersey has issued an emergency order halting Bitstrade, a firm that promised “investment profit guaranteed” via cryptocurrency related investment plans.Bitstrade posts that 960 “happy investors” have used their services. Bitstrade claims to be able to return 10% interest accrued daily if you invested $10,001 or more. The New Jersey Bureau of Securities found that Bitstrade violated the State’s Uniform Securities Law by offering investors an unregistered security in the form of an investment pool. Bitstrade is not registered to sell securities in New Jersey. “The Bureau’s action today reinforces our commitment to protecting investors as they navigate the uncharted and largely unregulated domain of cryptocurrency-related investments,” commented NJ Attorney General Gurbir S. Grewal. “We want to make sure that investors tempted to cash in on the cryptocurrency rage aren’t being lured into sending funds to an anonymous internet entity without knowing where the funds are going or how they’ll be used.” The Bitstrade website offers a “profit calculator” to lure in unsuspecting investors with outlandish claims of investment returns. Investors could participate for as little as $10.00 by backing the investment pool that claimed to be buying Bitcoin. Bitstrade said their “mission is to empower people financially and make the world more open and connected. This is the community of the people with a common cause to make bitcoin the most used payment system in the world. Our vision is to foster a trusted bitcoin community, more friendly than OTC, but [more] involved than a bitcoin broker.” Sharon M. Joyce, Acting Director of the NJ Division of Consumer Affairs, said there is no recourse for investors to recoup their losses; “We’re reminding investors to be extra vigilant about fully vetting what is being sold before investing with cryptocurrency.” Bitstrade claimed to maintain addresses in Redland, California and Scottsdale, Arizona. According to the Bureau, the California address listed on Bitstrade’s website is bogus and simply does not exist. The Arizona address listed is the headquarters of an unrelated, publicly-traded Internet domain registrar and web hosting company, the Bureau found. “Bitstrade is a prime example of a company seeking to capitalize on the cryptocurrency craze,” said Christopher W. Gerold, Chief of the Bureau of Securities. “Regulators, including the Bureau, are actively responding to fraudulent crypto-cloaked securities offerings.” The Bitstrade website does not list any names of management or firm founders. A review of WhoIsindicated “Tim Jones” ostensibly based in Washington, DC was the registrant of the domain. The Bitstrade site highlights the risk to unsophisticated investors falling for outrageous claims of investment returns in the crytpocurrency space. |
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Interesting Twist and Turn:
Despite increasing law enforcement efforts to clamp down on the offering of unregistered securities the flood of emails has not slowed down. More efforts have been spent to argue why their coin is a “utility” tokens and not securities that need to be registered or exempt with the SEC. In my opinion, if money is raised by selling tokens as an investment with an expectation of an increased return on investment based on the efforts of others in a common enterprise, it does not matter how the product is labeled. They have all the hallmarks of securities under US laws.
Here is another interesting twist:
“No regulatory authority has examined or approved of any of the information set out in this whitepaper. Thus, no action has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction. The publication, distribution or dissemination of this whitepaper does not imply compliance with any applicable laws, regulatory requirements or rules.”
Very interesting disclaimer. But I don’t see how it could help their cause, from any angle.
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I like the points being made here by RJF and MiningHabit that far too many people are excluded from private equity funding stages of the business cycle. Everybody should be able to participate. That is one reason why I have so much respect for the DNotes approach, and why I'm absolutely certain we have taken the right path. Just like the tag line we have adopted in our videos going forward:
"DNotes - the inclusive digital currency, for everyone."
I share your values and sentiments that even small investors should be given the opportunity to invest in situations they see fit and not be deprived of those rights by limiting them only to accredited investors. As part of consumer protection, I am less concerned about limiting their investment to 10% of their annual earnings or net-worth. As you may know, DNotes Global has selected the more demanding funding program using Reg. A+ Mini-IPO Title IV Tier 2 to raise up to $50 million from accredited and non-accredited investors worldwide. We could use Reg. D 506(c) to raise unlimited amount only from accredited investors. That is the most common funding vehicle at a significantly lower cost. But then, "DNotes - the inclusive digital currency, for everyone." Absolutely Alan! In order to maintain integrity, you have to "practice what you preach". Ignoring this is the downfall of so many startups and small, growing companies. In all fairness, yes, things always deviate from the the original plan but, I will argue, unless it is regulatory or legal, there is always a way to bend and reposition without loosing site of what attracted investors and customers in the first place. So many startups make the usually fatal mistake of abandoning their guiding principles and loosing site the goal when confronted with problems they see as insurmountable. It's always easier to give up or, compromise your principles to survive, but, in the long run there are no true rewards on that path. I absolutely love that comment RJF. In my view, success can be boiled down to the expression of one's vaunted principles and virtue. Many projects will likely fall by the wayside when they realise that institutional and user reluctance to use their products is the result of them taking an easy route, that has led to regulatory hurdles that can't be overcome but to begin again. Many in the ICO realm have gone with the 'easy route', that doesn't necessarily guarantee long-term success. The messaging in this forum has always praised the novelty and benefits that Initial Coin Offerings may offer, though we have always remained cautious on them with respect to our expectations of regulator responses to security checks that ICO's have historically circumvented. We have often discussed the need for sensible cryptocurrency regulation, and DCEBrief was created to aid these stakeholders as an education tool. Earlier today I submitted a proposal to one of the largest New Zealand public-sector organizations that is trying to increase their capability in the cryptocurrency space. The consultation document was created in response to a request forwarded to me that originated via the commissioner of the organization themselves, and it is my current understanding that my early session(s) may involve educating executives from other organisations / sitting board of directors. I am very privileged to be in a position to at least help out however I can in my corner of the world. The benefits of getting countries to one-by-one take sensible steps to understanding and making room for cryptocurrencies are enormous, and it is much better to get involved when the policies are being drafted, rather than after the fact. I think that New Zealand could become a huge market for DNotes, given that no cryptocurrency but NAV have a presence in the country, and all applications built in the country are created on proxy platforms like ethereum or outsourced to overseas firms, which mean less control and customizability for those organizations that commission development. That said, the first step is getting the regulations right. Allow me to deviate slightly here due to what you were saying about regulations. I wonder, how hard would it be for the SEC to create a seperate class for crypto ICOs? The regulatory structures already in place for IPOs could be culled and realigned while being repurposed to fit ICOs without an inordinate amount of work I would think. Something like "Crypto IPO Lite" for online companies. The regulations could be rather simple I would think, something along the lines of verification of the principles, some sort of bond (maybe depends on amount to be raised and final score for the project), proof of concept and usefulness of the end product along with a real white paper and business plan. Add background checks and proof of concept and permit them to raise some preset figure depending on scoring those items. Really not much work involved but the pre-qual would show commitment and follow through. It's really a shame that most of these ICOs start out with good intentions but get derailed or smothered in the amount of work required to bring their product to market. Perhaps an online ICO incubator could be available to assist with all the ins and out of turning a crypto idea into an online business. An incubator could also score a project in advance and help in making a decision to proceed or not. Just some thoughts. I like to take real world systems and project them into the crypto world. I think this will become a speciality and a profitable venture soon enough! As it stands now, DNotes stakeholders really have zero vested interest in the fate of ICO's. It would be a foolish waste of resources to lobby for lenient ICO regulation, when we have already charted a path to do an IPO that is legal by todays standards. I do agree that the ability for the little guy to invest and raise capital is important, but not when it involves do nothing schemes that sell mystery and deception to make their founders rich beyond belief. I don't think I've seen 10 projects out of the hundreds and hundreds of ICO's that have even come close to accomplishing what they set out to do. Brandon, Actually, in my opinion, you could not be more wrong. I am NOT saying Dnotes should do an ICO, I'm saying the industry and government should get together and come up with rules and acceptable guidelines for ICOs because they are NOT going to go away anytime soon no matter how much any country would them to. Like it or not, ICO's are part of our industry. Your statement sounds like the hundreds of statements from bankers and officials we have all seen over the years. So, take for example myself. I hold DNotes, I support DNotes, I introduce people to DNotes, I believe in DNotes and I have been with DNotes since the beginning but, I also hold over 50 other coins including the top ten. Some of those started as ICO's and were very successful. Remember, all this is new, it's all experimental and there will always be good and bad actors in the mix. Don't condemn something because it's popular. DNotes stakeholders can, and will, do whatever they please and none of us really knows who believes in what. No offense but, I suggest you re-read my post, it really had nothing to do with DNotes itself, it was simple a discussion point on the future of our industry. And, I don't recall asking for anyone to lobby for anything, that was simply an idea, do with it what you will. RJF, I thought your position and questions raised were very reasonable. We deeply appreciate your continued support of DNotes efforts. This will be a massive industry with plenty of room for everyone. I am doubtful if it is possible to regulate a decentralized autonomous entity, (DLT, virtual currency or some other names) that is leaderless and not controlled by an individual or a group of individuals. That explains why, to date, not a single ICO has been registered or exempt with the SEC, according to its Chairman, Jay Clayton. Whether, we like it or not, I envision that, at a minimum, future regulatory rules will require the registration of the organizers of new coins if pre-mined and sold as "securities" to fund their projects. It will require full disclosures and other continued reporting requirements. Alternatively, regulators and law makers could elect to do nothing and just apply the existing laws in the book. The later, will lead to more confusion and wrong interpretation applicable laws, and likely discourage and stifle innovations. DNotes can lead by example. In view of our mounting workload, we are not in the position to take on any leadership roles to help change the landscapes. Focusing on our top priority projects are always most important to us. At this point, launching DNotes 2.0 and our funding programs are most important to us. |
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VIDEO UPDATE Hello everyone. I have received the final version of one of the videos I have in production. This video illustrates why DNotes Global is important to DNotes visually, in a brief video. It took more than 3 weeks full time work for the animator to complete it, we are very appreciative of his efforts. The next video to release will be our first overview video based on the DNotes Global pitch deck. DNotes Global -- Ecosystem Preview I have to say the video is quite impressive and the animations were incredible. However the video raised lots of questions. How do you guys intend to make Dnotes global big and successful? Also how do you plan on making the consulting business a success? Also for accredited investors where can we see the business plan and what secondary markets will it trade on if any? Welcome acryptodealer, those are great questions. We are working on the documentation for answering those questions in great detail as we speak, including a white paper and pitch deck. I would recommend the brief description I can provide here and now does not do the overall system justice, and it will take some research as well as waiting for our detailed documentation, but I will provide a high level description: DNotes is a decentralized digital currency and in order to make the decentralized digital currency useful in the centralized world it requires third party involvement to create a 'bridge'. DNotes Global, Inc. is the bridge, and the ecosystem it is creating are all parts and pieces of that bridge, but we took it a step further by creating a cross ownership model between the currency and the company to further increase the bond between them and the interest between the two. Currently as part of the ecosystem, we have several pre-revenue generating entities, they include: DCEBrief - a news and information media outlet that delivers objective and informative news on the latest developments in the world of digital currency. News is presented in the condensed format needed by busy executives, business owners, regulators, and other decision-makers. Aside from a platform to educate this group and others on truth versus misconceptions in the digital currency industry, DCEBrief will be an invaluable media resource for global coverage of all DNotes initiatives. DNotesVault - offers the familiar custodial relationship investors are accustomed to by providing all our stakeholders with secure, guaranteed online storage for their DNotes. With its likely future evolution into an exchange / bank, it will not only operate as a trusted facilitator of everyday transactions like automatic deposits and payroll deductions into our various CRISPs (Cryptocurrency Investment Savings Plans), it will be a financial cornerstone in global commerce and small business success. CRISP - Cryptocurrency Investment Savings Plans. Currently Kids, Retirement, Employee Incentive Benefits, Students. The Four Pillars of Business Success - Revenue from “The Four Pillars of Business Success”, a book written by Alan Yong in which he shares four decades worth of business expertise, will help fund future projects and provides valuable exposure for DNotes, our CRISP program, and the rest of the ecosystem. The Four Pillars member site is an affordable e-mentorship program that provides access to Alan and his team, additional resources, and materials that expand on the concept of the book. As well as the The Four Pillars of Business Success Membership site and Video Series. CryptoMoms - addresses a great need within the industry for accurate digital currency education, straightforward and unbiased news, and representation from women. CryptoMoms, launched by DNotes in 2014, provides a digital currency learning center not just for women, but for anyone that would like to learn or ask questions in a friendly and helpful environment. It will also act as a stepping stone toward adoption of DNotes by women’s small businesses. From there we intend to expand our ecosystem providing digital currency services and platforms as well as into NextGenVC. NextGenVC will be built from a model we will be using for DNotes Global Inc, to build a successful business, identify companies in need of help. Depending on the unique situation, potentially help them raise funds, train them using the four pillars business model and work with their staff, help them create DNotes CRISP programs for their employees, help them accept DNotes for payments and B2B in-network DNotes offerings, build DNotes and DNotes based blockchain applications that help utilize our platform to improve their efficiency. Here are some links for research reference: The DNotes story, which also Chapter 15 of the Four Pillars book: http://dnotescoin.com/the-dnotes-story-an-unfolding-big-bold-idea-of-global-scale/Tim's Podcast interview on the bitcoin podcast: http://dnotescoin.com/the-bitcoin-podcast-had-tim-goggin-from-the-dnotes-team-on-the-show-to-talk-about-dnotes/Alan's CEO CFO interview: http://www.ceocfointerviews.com/interviews/DNotesGlobal17.htmThe DNotes roadmap: http://dnotescoin.com/dnotes-roadmap/Our blog: http://dnotescoin.com/blog-main-hub/I can recommend signing up for our newsletter at: http://dnotescoin.com/ When we release the documentation and videos with those greater details, our newsletter subscribers will receive them. Also, regarding your final question: We are at the early planning stages of two rounds of funding – Reg. D 506 (c) for $2.5 million, followed by Reg. A+ Mini IPO Title IV Tier 2 to raise up to $50 million from accredited and non-accredited investors worldwide, within a 12-month period. We plan to have DNotes Global, Inc.’s common stock listed on OTCQX secondary market soon after the closing of the A+ funding round. I like that you guys are starting multiple ventures. Diversification of businesses seems like a solid plan, not all of them will work out, but the ones that do will hopefully make more than the ones that failed. It seems that you guys are trying to raise quite a large amount of money. I would love to see a detailed plan with how you will be utilizing all the investor money. It seems that Alan doesn't have a motive to steal, and would be incredibly stupid for doing so, but raising such a large amount of money raises a red flag in my eye. I checked out your guys roadmap from http://dnotescoin.com/dnotes-roadmap/ and I have to say you have some very ambitious goals. I liked the specificity of all the items on the roadmap. I would like to see some proof that you guys have followed through on all the things you said you would do in 2017 that way I can know if you are people who I can trust my money with. These are the items I would like to see proof of: -Change of codebase from c++ to c# (I checked github, but I'm not familiar with the differences between c++ and c# syntax so I could not discern if the code had been re-written) -Blockchain Integrated Payment Network (haven't seen this in any DNOTES announcements) -Governance System (I have not seen this in any recent Announcements) I'm not trying to attack DNOTES, I just have questions about what is going on in this community as I have not been following it closely. Thanks again for your thoughtful questions acryptodealer. We wouldn't treat reasonable and respectful questions as an attack. It's not just diversification, although beneficial, that is a side effect of creating a profit generating business system that will drive DNotes forward, and all of the components needed to make that happen. The amount of money raised is a drop in the bucket for creating a globally accepted digital currency and building out the ecosystem, without creating a profit generating business out of it, we don't stand a chance just resting on raising up to $50m. For comparison coinbase has raised something like $217m and that is essentially just to exchange cryptocurrency for fiat. To clarify, we are not converting to c# for the initial release of DNotes 2.0 and that conversion has become a lower priority, our top priority is getting DNotes 2.0 launched for our target of mid March. The top features for the initial release will be CRISP, automated invoicing system (the first layer of the overall payment network), and potentially cold staking. The other features, such as governance system, are on our list will be later releases. The DNotes github is indeed in c++. If you found the DNotes 2.0 github version, that is one we are working on for the next release, which is c++. We will update it as we finalize the current features we are working on. The finer details will all be listed in the white paper. Our white paper is not as much of a technical document as you may be familiar with, it will show a conceptual outline of our system and all the components. It may take a while yet, once Ken and I are finished with it, Alan will have to take his pass, then find help for improving the graphics and finally get approval from legal before we can release it. Hi acryptodealer. Those are fair questions, not all of which we have details. We are still at the early planning stages of our funding – getting many things ready. Eventually, all the details will be available in our memorandum filings. This is a long and expensive process, but we feel that it is the right path for us. “It seems that you guys are trying to raise quite a large amount of money.” We are. Reg. A+ Mini-IPO Title IV Tier 2 allows registered or exempt securities to raise up to $50 million from accredited and non-accredited investors worldwide over a 12-month period. However, there are no assurances that we can raise the maximum. DNotes’ solution to some of our industry challenges is based on our Big Bold Vision of a fully integrated ecosystem as outlined in our roadmap, which can be quite capital intensive. Additionally, DNotes’ success will make it necessary for additional funding in the future. |
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No surprise here: The SEC Man Cometh for ICO AttorneysLawyers advising the booming cryptocurrency and token industry may soon face a reckoning from the federal government, former SEC officials told Bloomberg Law. The Securities and Exchange Commission is expanding its focus from the companies developing initial coin offerings to the hundreds of lawyers who are guiding them through regulatory gray areas. The industry argues it doesn’t fit neatly into existing legal frameworks as global regulators consider whether virtual tokens might be securities — which require strict regulatory compliance. Attorneys that intentionally misadvised clients or failed to advise disclosure that a token was a security to investors could be fined, prohibited from practicing before the SEC, disbarred, or criminally charged, attorneys told Bloomberg Law. “I can’t imagine this will end pretty for our sector,” said Aaron Wright, a professor at Yeshiva University’s Cardozo School of Law and chairman of the Enterprise Ethereum Alliance legal industry working group. “It could be pretty gruesome.” The pressure on practitioners stems from their role in classifying the new digital assets created by ICOs at a time when the industry is experiencing explosive growth. Coin offerings raised between $4 billion to $6 billion in 2017 alone. There are no regulations or case law that guide digital asset designation, so attorneys have relied on decades-old precedent — such as the Howey Test — to help companies decide if their assets will function like a currency, security, or a utility token, which can be redeemed for future access to a product or service such as a game. SEC Chairman Jay Clayton and other regulators have said most ICOs they’ve observed create securities, which require sellers to register with the commission and comply with more stringent laws. Clayton has repeatedly targeted ICO attorneys in recent remarks, and signaled potential action against practitioners. In at least three instances since December, he has said attorneys need to act more responsibly to uphold securities laws when advising projects and not mislead investors about the nature of a token. Clayton signaled that more token offerings should be registered, and that ICO attorneys may be failing their clients in that primary analysis because the clients are willing to take the risk. “These lawyers appear to provide the ‘it depends’ equivocal advice, rather than counseling their clients that the product they are prompting likely is a security,” Clayton said Jan. 22 in a speech to the Securities Regulation Institute in Washington. .... Some attorneys practicing in the crowded securities space have worked aggressively to market their services to the burgeoning ICO industry. A suspension or prohibition from representing clients before the SEC could be a major blow. full article - https://www.bna.com/sec-man-cometh-n57982088366/ "There are no regulations or case law that guide digital asset designation, so attorneys have relied on decades-old precedent — such as the Howey Test " Something doesn't add up here. Applying the Howey Test to virtually any of them, casts little doubt they are securities. Perhaps the "experts" didn't know as much as they thought they did, which is often the case. Or, they are basing their decision on the 'facts' they have been given... I guess we will find out when the gavel falls. It should not be a surprise that, “The Securities and Exchange Commission is expanding its focus from the companies developing initial coin offerings to the hundreds of lawyers who are guiding them through regulatory gray areas.” That warning bell has been sounded a few times. Unfortunately, regulating the virtual currency world is easier said than done. There are no quick or easy solutions. Until now, the SEC and CFTC’s enforcement actions have been focused on bad actors involved in frauds and Ponzi schemes. They pledged to “continue to work together to bring transparency and integrity to these markets and, importantly, to deter and prosecute fraud and abuse.” Most certainly. more enforcement actions are expected. Some regulations may be healthy for our industry. But how do we go about regulating leaderless decentralized entities? Who would be responsible in filing disclosure statements and keep up with the reporting requirements? I'm pretty sure the direction this is going is that it will become official that ICOs *are* securities, and as such need to be registered appropriately. If I wanted to run an ICO, I would be making that assumption. That is a good conclusion, simplified. I posted various options of November 13, 2017 on Page 93:"Among others, there are three funding options on our radar: 1. ICO Join the party. Using our new DNote 2.0, create a “token” to raise funds for a given project or all the projects. For reasons discussed and more – we are not likely to go down this route. In the United States, as in most countries, it is illegal to sell securities that are not registered or exempt. 2. Use Regulation A+ Mini-IPO of Title IV Tier II of the JOBS Act I believe that this is the most viable funding option for DNotes Global, Inc. Reg A+, Title IV, Tier II allows a private growth-stage company like DNotes Global, Inc. to raise up to $50 million from American and foreign investors. Like an IPO DNotes Global can offer shares to the public; domestic and foreign, and not just accredited investors. However, we will have to submit a filing with audited statements with the SEC and be granted approval before launching a mini-IPO. The complexities, cost, time, and reporting requirements will be significantly less burdensome than a traditional IPO. With the resources, I believe that from the time we make a commitment it can be done in six months. 3. A concurrent Reg. D & Reg S Initial Coin Offering Reg D is a United States Federal program created under the Securities Act of 1933, and adopted in 1982. It involves a private placement memorandum designed to provide an exemption for companies to sell securities under certain rules to accredited investors without registration of the securities. Regulation D consists of 9 Rules with 3 “Basic” exemption Rules. Reg D Rule 506(c) exempts offerings that are sold to investors who have been verified as accredited investors. Reg S exempts offerings made to non-US residents. They both allow for general solicitation and advertising essential to ICOs marketed globally. With professional guidance done correctly, Reg S ICO launched side-by-side with Reg D is a viable option, especially for our clients in the future. I don’t mean to bore you, but this is relevant to our road-map and the book. NextGenVC is one of our strategic building blocks to involve the corporate world. We are committed to assisting entrepreneurs to improve their chances of business success. Coupled with adequate funding it is also important to take full advantage of our emerging technologies - digital currency, blockchain technologies, and decentralized global payment systems. It is all part of the ecosystems we are building to gain mass acceptance. I know that it is not always easy to see the big picture and connect all the dots." |
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No surprise here: The SEC Man Cometh for ICO AttorneysLawyers advising the booming cryptocurrency and token industry may soon face a reckoning from the federal government, former SEC officials told Bloomberg Law. The Securities and Exchange Commission is expanding its focus from the companies developing initial coin offerings to the hundreds of lawyers who are guiding them through regulatory gray areas. The industry argues it doesn’t fit neatly into existing legal frameworks as global regulators consider whether virtual tokens might be securities — which require strict regulatory compliance. Attorneys that intentionally misadvised clients or failed to advise disclosure that a token was a security to investors could be fined, prohibited from practicing before the SEC, disbarred, or criminally charged, attorneys told Bloomberg Law. “I can’t imagine this will end pretty for our sector,” said Aaron Wright, a professor at Yeshiva University’s Cardozo School of Law and chairman of the Enterprise Ethereum Alliance legal industry working group. “It could be pretty gruesome.” The pressure on practitioners stems from their role in classifying the new digital assets created by ICOs at a time when the industry is experiencing explosive growth. Coin offerings raised between $4 billion to $6 billion in 2017 alone. There are no regulations or case law that guide digital asset designation, so attorneys have relied on decades-old precedent — such as the Howey Test — to help companies decide if their assets will function like a currency, security, or a utility token, which can be redeemed for future access to a product or service such as a game. SEC Chairman Jay Clayton and other regulators have said most ICOs they’ve observed create securities, which require sellers to register with the commission and comply with more stringent laws. Clayton has repeatedly targeted ICO attorneys in recent remarks, and signaled potential action against practitioners. In at least three instances since December, he has said attorneys need to act more responsibly to uphold securities laws when advising projects and not mislead investors about the nature of a token. Clayton signaled that more token offerings should be registered, and that ICO attorneys may be failing their clients in that primary analysis because the clients are willing to take the risk. “These lawyers appear to provide the ‘it depends’ equivocal advice, rather than counseling their clients that the product they are prompting likely is a security,” Clayton said Jan. 22 in a speech to the Securities Regulation Institute in Washington. .... Some attorneys practicing in the crowded securities space have worked aggressively to market their services to the burgeoning ICO industry. A suspension or prohibition from representing clients before the SEC could be a major blow. full article - https://www.bna.com/sec-man-cometh-n57982088366/ "There are no regulations or case law that guide digital asset designation, so attorneys have relied on decades-old precedent — such as the Howey Test " Something doesn't add up here. Applying the Howey Test to virtually any of them, casts little doubt they are securities. Perhaps the "experts" didn't know as much as they thought they did, which is often the case. Or, they are basing their decision on the 'facts' they have been given... I guess we will find out when the gavel falls. It should not be a surprise that, “The Securities and Exchange Commission is expanding its focus from the companies developing initial coin offerings to the hundreds of lawyers who are guiding them through regulatory gray areas.” That warning bell has been sounded a few times. Unfortunately, regulating the virtual currency world is easier said than done. There are no quick or easy solutions. Until now, the SEC and CFTC’s enforcement actions have been focused on bad actors involved in frauds and Ponzi schemes. They pledged to “continue to work together to bring transparency and integrity to these markets and, importantly, to deter and prosecute fraud and abuse.” Most certainly. more enforcement actions are expected. Some regulations may be healthy for our industry. But how do we go about regulating leaderless decentralized entities? Who would be responsible in filing disclosure statements and keep up with the reporting requirements? |
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I like the points being made here by RJF and MiningHabit that far too many people are excluded from private equity funding stages of the business cycle. Everybody should be able to participate. That is one reason why I have so much respect for the DNotes approach, and why I'm absolutely certain we have taken the right path. Just like the tag line we have adopted in our videos going forward:
"DNotes - the inclusive digital currency, for everyone."
I share your values and sentiments that even small investors should be given the opportunity to invest in situations they see fit and not be deprived of those rights by limiting them only to accredited investors. As part of consumer protection, I am less concerned about limiting their investment to 10% of their annual earnings or net-worth. As you may know, DNotes Global has selected the more demanding funding program using Reg. A+ Mini-IPO Title IV Tier 2 to raise up to $50 million from accredited and non-accredited investors worldwide. We could use Reg. D 506(c) to raise unlimited amount only from accredited investors. That is the most common funding vehicle at a significantly lower cost. But then, "DNotes - the inclusive digital currency, for everyone." Absolutely Alan! In order to maintain integrity, you have to "practice what you preach". Ignoring this is the downfall of so many startups and small, growing companies. In all fairness, yes, things always deviate from the the original plan but, I will argue, unless it is regulatory or legal, there is always a way to bend and reposition without loosing site of what attracted investors and customers in the first place. So many startups make the usually fatal mistake of abandoning their guiding principles and loosing site the goal when confronted with problems they see as insurmountable. It's always easier to give up or, compromise your principles to survive, but, in the long run there are no true rewards on that path. I absolutely love that comment RJF. In my view, success can be boiled down to the expression of one's vaunted principles and virtue. Many projects will likely fall by the wayside when they realise that institutional and user reluctance to use their products is the result of them taking an easy route, that has led to regulatory hurdles that can't be overcome but to begin again. Many in the ICO realm have gone with the 'easy route', that doesn't necessarily guarantee long-term success. The messaging in this forum has always praised the novelty and benefits that Initial Coin Offerings may offer, though we have always remained cautious on them with respect to our expectations of regulator responses to security checks that ICO's have historically circumvented. We have often discussed the need for sensible cryptocurrency regulation, and DCEBrief was created to aid these stakeholders as an education tool. Earlier today I submitted a proposal to one of the largest New Zealand public-sector organizations that is trying to increase their capability in the cryptocurrency space. The consultation document was created in response to a request forwarded to me that originated via the commissioner of the organization themselves, and it is my current understanding that my early session(s) may involve educating executives from other organisations / sitting board of directors. I am very privileged to be in a position to at least help out however I can in my corner of the world. The benefits of getting countries to one-by-one take sensible steps to understanding and making room for cryptocurrencies are enormous, and it is much better to get involved when the policies are being drafted, rather than after the fact. I think that New Zealand could become a huge market for DNotes, given that no cryptocurrency but NAV have a presence in the country, and all applications built in the country are created on proxy platforms like ethereum or outsourced to overseas firms, which mean less control and customizability for those organizations that commission development. That said, the first step is getting the regulations right. Tim, that must be a very exciting project to get involved. We are all proud of your involvement. It is vital that the political and regulatory leadership gained a good working knowledge of this generational opportunity that could truly change the world if we can work collaboratively together, instead of against one another. Again, I was impressed and deeply encouraged by last Tuesday CFTC and SEC Cryptocurrency Senate Banking Committee hearing testimony. Everyone involved was quite knowledgeable, forward-looking, and supportive of innovation. Chairman of the CFTC said it best, “We owe it to this new generation to respect their enthusiasm for virtual currencies, with a thoughtful and balanced response, and not a dismissive one.” |
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I like the points being made here by RJF and MiningHabit that far too many people are excluded from private equity funding stages of the business cycle. Everybody should be able to participate. That is one reason why I have so much respect for the DNotes approach, and why I'm absolutely certain we have taken the right path. Just like the tag line we have adopted in our videos going forward:
"DNotes - the inclusive digital currency, for everyone."
I share your values and sentiments that even small investors should be given the opportunity to invest in situations they see fit and not be deprived of those rights by limiting them only to accredited investors. As part of consumer protection, I am less concerned about limiting their investment to 10% of their annual earnings or net-worth. As you may know, DNotes Global has selected the more demanding funding program using Reg. A+ Mini-IPO Title IV Tier 2 to raise up to $50 million from accredited and non-accredited investors worldwide. We could use Reg. D 506(c) to raise unlimited amount only from accredited investors. That is the most common funding vehicle at a significantly lower cost. But then, "DNotes - the inclusive digital currency, for everyone." Absolutely Alan! In order to maintain integrity, you have to "practice what you preach". Ignoring this is the downfall of so many startups and small, growing companies. In all fairness, yes, things always deviate from the the original plan but, I will argue, unless it is regulatory or legal, there is always a way to bend and reposition without loosing site of what attracted investors and customers in the first place. So many startups make the usually fatal mistake of abandoning their guiding principles and loosing site the goal when confronted with problems they see as insurmountable. It's always easier to give up or, compromise your principles to survive, but, in the long run there are no true rewards on that path. Thanks for your support and encouragement, RJF. As our industry becomes more matured, I believe that more investors will appreciate that "trust" is still a very important factor when hard-earned money is at stake. |
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I like the points being made here by RJF and MiningHabit that far too many people are excluded from private equity funding stages of the business cycle. Everybody should be able to participate. That is one reason why I have so much respect for the DNotes approach, and why I'm absolutely certain we have taken the right path. Just like the tag line we have adopted in our videos going forward:
"DNotes - the inclusive digital currency, for everyone."
I share your values and sentiments that even small investors should be given the opportunity to invest in situations they see fit and not be deprived of those rights by limiting them only to accredited investors. As part of consumer protection, I am less concerned about limiting their investment to 10% of their annual earnings or net-worth. As you may know, DNotes Global has selected the more demanding funding program using Reg. A+ Mini-IPO Title IV Tier 2 to raise up to $50 million from accredited and non-accredited investors worldwide. We could use Reg. D 506(c) to raise unlimited amount only from accredited investors. That is the most common funding vehicle at a significantly lower cost. But then, "DNotes - the inclusive digital currency, for everyone." |
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I found the SEC/CFTC Senate Committee on Banking hearing in Washington on Tuesday inspiring and forward-looking. 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 by the CFTC Chairman Giancarlo’s remark that the “currency” component goes together with the underpinning blockchain technologies. He said, “It’s important to remember that if there were no Bitcoin, there would be no distributed ledger technology (DLT)”. He is correct. 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. Knowing how badly this could have gone, I think this is almost wonderful news. I'm really impressed with this: Giancarlo also expressed an understanding of the generational nature of digital currency innovation:
“We owe it to this new generation to respect their enthusiasm for virtual currencies, with a thoughtful and balance response, and not a dismissive one.”This comment was from another article in Yahoo finance: “We should regulate ICOs like we regulate securities offerings,” Clayton said. “End of story.” He noted that companies selling "tokens" in their ICOs are different than companies selling cryptocurrency. This sounds very promising for cryptocurrencies - I may have to take back my comments on regulators not knowing the difference between cryptocurrency and ICOs, and "lumping them into one big bitcoin boat".  SEC, CFTC Testify Before Senate on What's Needed for Virtual Currency - https://finance.yahoo.com/news/sec-cftc-testify-senate-apos-065435895.htmlI was generally impressed by their knowledge of the industry. Even the Senators were quite knowledgeable. Overall, it was very positive and measured. I took it as great news for our industry. “There was a clearer response when the discussion turned to the regulation of initial coin offerings. “We should regulate ICOs like we regulate securities offerings,” Clayton said. “End of story.” It is quite clear that the SEC will treat ICO tokens as securities offerings, the sale of which is a violation of U. S. Securities laws, unless registered or exempt with the SEC. He noted that companies selling "tokens" in their ICOs are different than companies selling cryptocurrency.” https://finance.yahoo.com/news/sec-cftc-testify-senate-apos-065435895.htmlThis certainly sounds confusing. I assume that he meant that ICO involves the sale of a batch of pre-mined tokens of which all or a portion of it are sold for money or other cryptocurriencies. In the second case, I guess that he was referring to other cryptocurrencies that never used their coins to raise money. Bitcoin and DNotes are good examples. “companies selling cryptocurrency”? Not sure if there is a clear and easy way to describe it. He might be trying to communicate to coins that never raised money using ICOs not to worry, since there has not been any sale of securities involved. Until there is a better term to differentiate the two, it will remain confusing. |
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I found the SEC/CFTC Senate Committee on Banking hearing in Washington on Tuesday inspiring and forward-looking. 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 by the CFTC Chairman Giancarlo’s remark that the “currency” component goes together with the underpinning blockchain technologies. He said, “It’s important to remember that if there were no Bitcoin, there would be no distributed ledger technology (DLT)”. He is correct. 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. |
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Thank you, Joe, for your relentless efforts to make this listing possible. Check it out: https://www.udemy.com/the-four-pillars-of-business-success/“Business success does not happen by accident or good fortune. It takes deep knowledge, passion, hard-work, focus, discipline, tenacity, and the right mind-sets to be successful. With passion and dedication, you can obtain the type of business mastery that will help you be the true architect of your company’s success. This course covers the vital importance of developing a clear vision of where you envision your company’s ultimate destination to be and how to build your teams to best succeed in achieving their missions, goals, and objectives to help your company get there. You gain the understanding and appreciation of all the critical components that must function well as a complete system or independently as a subsystem…. “ |
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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. |
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