Buying BNK on spectro doen't work

The BNK price plunged as expected. It is a short term trend, until people find the small yet steady trickle of ETH dripping from the coin, which is a bonus in itself.

I do believe that the project is poorly managed. I do not know how do they call it in business circles but it basically suffocated when expanding. Exhibit 1 - number of spectrocoin emplyees  https://rekvizitai.vz.lt/imone/spectro_finance/darbuotoju-skaicius/ (You will see the exact point when this project lost its proper social media support). Expansion is one of the most difficult business cycles and I do believe Bankera is suffering from a string of horrendous decisions. Why did they list the coin on hitbtc prior to launching their own trading plaform? Why is social media so poorly managed. It does look like a company managed by engineers, who are a bit optimistic about their own abilities, and very bad at communicating with the public.

On the plus side - a new law on electronic money is in the pipelines in Lithuania, it will be both very liberal and transparent (so - it will be not a garage type operation, but an entity working within a legal framework, which will give people who invested in the company reassurance.). Kegal grey areas will be no longer there. Which is good for any long time investor.
Sooner or later Bankera will bring their exchange to life. It will boost the ETH trickle to BNK holders. And I do hope that Bankera/Spectro management will learn from their mistakes (one of which is paradoxically - to give very precise dates of their future plans, not rushing to please the anonymous and libelous commenters). Actually - with the capital you have, you can afford a seriuos business model audit from pwc or whatever big auditing company you choose. That would give confidence, which is lacking at this moment.

There will be an initial dump of BNK's from those who are fed up. Any predictions on how low will the price go?

White paper has been removed form the Bankera page?

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Hello,

We do not need to register any prospectus because we have never promoted Bankera in the Lithuanian territory. Also, our law company is in process to answer all relevant questions.
What you read in the article is basically a warning for news agencies; they should not promote ICO's in Lithuania.
[/quote]

Well you should have consulted a lawyer, as Spectrocoin and Bankera are (1) physically operating in Lithuania (2) have given interviews in Lithuanian press regarding the ICO (Verslo žinios if I remember) (3) owners are incredibly naive if they believe that they will be able to get away with "the ICO is not intended for the sale in Lithuania". Because if Bankera/spectro will take this thread of reasoning, the Bank of Lithuania might take the line of shutting your offices down for selling securities without the prospectus and the possibility that the funds will be stolen (and they already have the know how of doing it over the weekend like with SNoras/Ūkio banks and certain Credit Unions). So if you are not taking the legal requirements seriously, then there will be no bank here, as banking does not exist outside of the Law.

Now, we really need some good explanations. One of the largest news sites in Lithuania published this article today, which I took time to summarise and translate.

Questions for Bankera:
1. Have you registered the prospectus?

"The Bank of Lithuania has sent inquiries to Bankera regarding the ICO, whether the ICO follows the legal requirements established in Lithuanian law.

„According to the official position expressed by the Bank of Lithuania, in those cases when virtual currency coins contain features of securities, requirements stated in the Law on Securities are applicable, which include provisions regarding advertisments of the emmission of securities. Fines or other means could be applicable if the provisions of the Law are not followed" - stated  Vaidotas Cibas, Head of the Regulatory Market Surveillance Division of the Bank of Lithuania

On October 10, 2017 the Bank of Lithuanian approved its position "Regarding virtual currencies and initial coin offerings", states the press release. This position states, that in those cases, when ICO coins contain features of securities (e.g. grants property rights, share of the profit or a say in management,  interest, of the coins are to be redeemed ), and also there is an option to sell the coin and to trade it in a secondary market or at organized trading venues, the requirements of the Law on Securities must be applied. One of the main requirements is that before selling coins in our country the company has to prepare a prospectus and the prospectus must be approved by the Bank of Lithuania or relevant authority within the European Union.

Then some general information regarding the ICO.

According the features stated in the position and according to the information stated in Bankera business plan (white paper?) we come to conclusion that this ICO is covered by the regulations of the Law on Securities, therefore is considered a public offering, therefore it must follow established regulations. Law on Securities state, that should the persons organise and conduct public offering without the approval of the prospectus or the public offering and trading in the regulated market is prohibited, stopped or do not follow the the Law on Securities, a maximum fine could be applied, which may exceed the common nominal value of the publicly offered securities. The Regulator have a right to apply sanctions to the company and its directors and other persons responsible for the transgresion, including subjects which disseminate the advertismens of illegaly conducted ICO."
https://www.delfi.lt/verslas/verslas/lietuvos-bankas-ispeja-del-virtualiuju-zetonu-platinimo.d?id=77185697

And just a couple of links with information, that is publicly available on Spectro and Bankera where you can check the number of employees, wages,  etc.

https://rekvizitai.vz.lt/imone/spectro_finance/darbuotoju-skaicius/

https://rekvizitai.vz.lt/imone/bankera/

There are actually some things that would make Bankera look even better.

1) Scaling and the success of the scaling process. As I am based in Lithuania, so I see that they (both Spectro and Bankera) started a hiring spree. As any user of a big web platforms you will know that maintaining a growing platform will cost more in terms of customer support, various web resources etc. So it would be reassuring to get a report on how is the entire project coping with the increased number of customers and complexity.

2) Burn rate. As this venture is using what it collects to finance itself when growing and pooling resources to start the bank it would give more confidence to see that it uses it's resources efficiently.

3) Regulation. As the entire venture will go into an area where regulation is important and elaborate (if you read the whitepaper you will see that Bankera will get into lending and investment banking), so when the regulatory enviroment will be chosen (If I understand correctly it will be EU , but the decission will be taken on where exactly - with Lithuania, Estonia, Malta, and the tax-havens as options) then some more detailed document on how this decision changes the project would be a positive sign.

4) More detailed timetables on the trading plaform. The sooner the better, as the coinholders will experience a bump in their returns.

The whitepaper explicitly states that they promise nothing in transparency on the abovementioned points. But IMHO they would help as honesty at this point in time is the best policy.
The entire crypto entering the traditional and investment banking idea is interesting, and could be wildly successful.

If this machine is up and running I do see a future where the Bankera will at some point in the future buy out the coins and will become a successful bank.

The entire accusation that these people are scammers is unfounded. I have read through all of the material they have added and already have a plausible explanation.

Spectrocoin is not an imaginary company working from anonimity, but they are a physical company with that do have to follow the law. Lithuanian law in particular, as all of those who have used their services agreed to their terms and conditions. And these sob stories are propagated here because the people in question have not read terms and conditions. Why?  Because as Spectrocoin is a registered financial institution they have to abide to the laws which regulate money transfers regarding the prevention of terrorist financing, tax fraud,  money exchange and laundering. In Lithuanai you have to provide a real ID if you want to exchange money. The people in question who wrote these sob stories deposited their money onto their accounts (and therefore they have parked them, for all legal purposes on Lithuanian soil). 100 bitcoins or 40 bitcins is a sum that exceeds all the limits that add extra conditions for the regulations for additional scrutiny regarding the transfers of funds to kick in. We do not know if the funds in question are obtained legally or illegaly - neither does Spectrocoin, as we see from all the comments by their representative. Spectrocoin abides by the law and should the value of funds exceed a certain amount additional questions are to be asked and additional proofs of identity or the origin of funds (they are obligated to do this by the law). The laws requiring to provide ID and aditional proofs are to be made stricter soon, and should the ammount exceed 3000 EUR, than the company will be obligated to ask additional questions.

For all intents and purposes (if the money exists) it is in a legal limbo - until the proof of legality of how the funds were obtained and the origin of the funds is provided in a document that would be accepted by the law enforcement agencies it still belongs to owner, but cannot be moved without the proof that the person exists and/or funds were obtained legally .

After all is said and done - the company have been accused of folowing the law.

I have no comments regarding Bankera, although should it fail it will reflect badly on MEP A. Guoga, who attached his name with this projects.

P.S. I am in no way related to the company, have been using them for couple of years, no complaints, although their exhange is a bit pricey.