I spoke with Peter Vessenes on the phone yesterday (and also sent an email about these concerns, part of which is quoted below). It would be nice to have an FAQ with answers to the following questions made public (*hint hint* to CoinLab
).
1. What is the reason why US customers can no longer use Mt. Gox to hold their funds and are required to only use CoinLab? Is it mainly to help Mt. Gox avoid dealing with Foreign Account Tax Compliance Act (FATCA) compliance? I believe Japan has agreed to begin compliance in 2014, so I would assume Mt. Gox would be covered by this regulation, and it makes sense that they would want to avoid dealing with it. If it is part of the contract between CoinLab and Mt. Gox that all US & Canadian customers' funds are held with CoinLab, how exactly do CoinLab and Mt. Gox benefit from this agreement if our trading fees stay the same?
2. If Mt. Gox is simply trying to offload compliance risk, how will CoinLab comply with US regulations and avoid seizure of customer funds by law enforcement? Specifically, will CoinLab report customers' information to the IRS, and if so what information? Also, what other kind(s) of reporting/regulation, if any, will take place? Will CoinLab assist customers in tracking trading profits & losses, and if necessary, assist in reporting any information for tax purposes?
3. If/how will US customers' funds be insured at Silicon Valley Savings Bank? Will they be FDIC insured, SIPC insured, or something else?
4. As you are likely aware, Dwolla changed their Terms of Service policy stating that Dwolla users will not "act as a marketplace and/or exchange for virtual currency products without prior written consent." In light of this policy change, has CoinLab received prior written consent from Dwolla's compliance department, as did Mt. Gox, through their US corporation, Mutum Sigillum LLC (see
https://mtgox.com/press_release_20120808.html)?5. If CoinLab has received written permission from Dwolla, will Mt. Gox's US customers be able to immediately use Dwolla for deposits & withdrawals, and function in the same manner with a seamless transition without delays?
6. Will all current Mt. Gox APIs keys stay the same after the transition? Specifically, will I still be able to trade with my Mt. Gox Mobile 3.2 Android app, using the same PIN (see
http://mtgoxlive.com/mobile/)? Also, will all market data feeds and tools function in the same manner after the transition, including the ones at the following links:
http://mtgoxlive.com/orders, SierraChart bridge plugin realtime Mt. Gox data feed by slush (
https://bitcointalk.org/index.php?topic=6019.0;all),
http://bitcoin.clarkmoody.com/ streaming trades & market depth (
https://bitcointalk.org/index.php?topic=43514.0;all), BitcoinCharts.com:
http://bitcoincharts.com/charts/mtgoxUSD#rg180zigDailyztgSzbgBza1gSMAzm1g10za2gSMAzm2g60zxzi1gVolzi2gMACDzi3gRSIzcv, etc.? I am highly dependent on those data feeds for trading every day, so if any of them stop working properly, it will be a serious problem.
7. I am a verified (level 1) customer with Mt. Gox, and after requesting an increase to my withdrawal limits, my limits are currently as follows: 4,000 BTC per 24 hours, and $10,000 per 24 hours ($50,000 per 30 days). Will I be allowed to keep these same withdrawal limits seamlessly as a CoinLab customer, or will I need to go through the AML process all over again? If I am required to go through all of the AML headache over again before being able to retrieve my USD funds, I may decide to switch to a different exchange. Also, will BTC deposits & withdrawals be as rapid as they are for Mt. Gox, and will they include the same abilities (i.e., use a "green address," etc.)?
8. What is CoinLab's privacy policy? Mt. Gox clearly states the following on their AML verification page in regard to all personal information submitted for AML purposes: "Any information submitted is subject to Mt.Gox's privacy policy and as such will not be shared with any 3rd party, corporate partner, or agency external to Mt.Gox under any circumstances. Documents collected via this form will be accessed by Tibanne's staff only. Please note that we will only release your information if we are subpoenaed by the Supreme Court of Tokyo" (see
https://mtgox.com/forms/verification). Since I am a verified (level 1) Mt. Gox customer, there any chance that I would be forced to provide personal information again, or additional information for AML, IRS/government spying/reporting, or other purposes? Is there any chance that my old information would be retained, and if so, what kind of personal information would be retained? Also, is there a way to determine exactly what information CoinLab has retained about me, or request deletion of my personal information? Mt. Gox addressed some of these questions and several more questions in their full length privacy policy:
https://mtgox.com/privacy_policy (even though they conflict with the above AML statement), and I would like to know CoinLab's position on these issues before the transition takes place.
In our phone conversation, Peter had some answers, but from what I've heard, it seems there may be some delays with the Mt. Gox to CoinLab transition. I signed up for the alpha transition, and just got an email this morning (quoted below) indicating that the alpha? transition could take up to three weeks:
