Camp BX Hacker / Compliance Security Audit

[Keyur @ Camp BX]

Dennis,
      We have updated the company name in the footer - Camp BX is our product name.  You can verify the registration now!

Thank you,
     Keyur

A Camp BX search does still not generate any reccords at "Department of Banking & Finance" in Georgia http://dbf.georgia.gov or at "Georgia Business Licenses Directory" http://publicrecords.onlinesearches.com/Georgia-Business-Licenses.htm or at the FDIC "Bank find" http://www2.fdic.gov/idasp/main_bankfind.asp.

Try http://corp.sos.state.ga.us/corp/soskb/CSearch.asp

Keep in mind, other public records take time to update.

I think there is a misunderstanding about the role of FDIC in international customers.  FDIC insures bank accounts, not businesses.  Our accounts are insured by FDIC.

Hope this helps,
      Keyur

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[Jaime Frontero]

Dennis,
      We have updated the company name in the footer - Camp BX is our product name.  You can verify the registration now!

Thank you,
     Keyur

A Camp BX search does still not generate any reccords at "Department of Banking & Finance" in Georgia http://dbf.georgia.gov or at "Georgia Business Licenses Directory" http://publicrecords.onlinesearches.com/Georgia-Business-Licenses.htm or at the FDIC "Bank find" http://www2.fdic.gov/idasp/main_bankfind.asp.

did you try the company name?

Bulbul Investments LLC

not that i'd have much confidence in the timeliness of a gov't website...

[Keyur @ Camp BX]

this looks promising.

i'd much rather have my money compliant to all the various things that money needs to be compliant with, than potentially anonymous but in the hands of amateurs.

if i want anonymity, i'll do BTC > BTC transactions over Tor.

if i want a bank or an exchange, i'll go with staid and boring and all tied up with legal niceties.

i'm looking forward to your launch.  i'll be there.

These were exactly our thoughts when we made the business plan, Jamie!  Thank you and look forward to having you at Camp BX!

[dennis_sweden]

Try http://corp.sos.state.ga.us/corp/soskb/CSearch.asp

Keep in mind, other public records take time to update.

I think there is a misunderstanding about the role of FDIC in international customers.  FDIC insures bank accounts, not businesses.  Our accounts are insured by FDIC.

Hope this helps,
      Keyur

Bulbul Investments LLC is registered as a Limited Liability Company, which affords "limited personal liability for the debts and actions of the LLC". Regarding FDIC, as you state, "FDIC insures bank accounts". I read this as the bank accounts that Bulbul Investments LLC hold are insured in the bank where the account of Bulbul is held. Despite funds held in accounts by Bulbul being insured, if Bulbul were to apply for bankruptcy, any deposits to Camp BX that are not in the account would not be redeemable due to the limited personal liability, and depositors to Camp BX are unsecured creditors - is this a correct understanding or not?

The Georgia Code - Corporations and Partnerships - Title 14, Section 14-11-201 states: "(a) A limited liability company may be formed under this chapter for any lawful purpose. If the purpose for which a limited liability company is formed makes it subject to a special provision of law, the limited liability company shall also comply with that provision."

As Bulbul Investments LLC operates an exchange market, I am under the impression that Bulbul is subject to other special provision of law, which again I am under the impression would require further licenses. Would you care to elucidate on this point? As Camp BX will potentially hold/transfer millions of USD, further information on the subject matter would allow for a better understanding of the risks involved when trading on Camp BX.

I transferred 500 Euro to Mtgox which literally arrived on the eve of the crash/hack. Of course the funds are not more than I can afford to lose, however the risk factor when dealing on Bitcoin exchanges has been perfectly exposed (of course the risk factor always existed) and I am considering wehter to withdraw completely as, with hindsight, I consider myself foolish to have transferred funds to an entity with a very unclear legal framework, however novel and benign the concept of Bitcoins is.

[dennis_sweden]

I have no idea how the previous post had many crossed over lines; i shall resubmit the entire post as I could not edit it successfully.

I must type parts of message again; will update soon.

“Try http://corp.sos.state.ga.us/corp/soskb/CSearch.asp

Keep in mind, other public records take time to update.

I think there is a misunderstanding about the role of FDIC in international customers.  FDIC insures bank accounts, not businesses.  Our accounts are insured by FDIC.

Hope this helps,
      Keyur”

Bulbul Investments LLC is registered as a Limited Liability Company, which affords "limited personal liability for the debts and actions of the LLC". Regarding FDIC, as you state, "FDIC insures bank accounts". I read this as the bank accounts that Bulbul Investments LLC hold are insured in the bank where the account of Bulbul is held. Despite funds held in accounts by Bulbul being insured, if Bulbul were to apply for bankruptcy, any deposits to Camp BX that are not in the account would not be redeemable due to the limited personal liability, and depositors to Camp BX are unsecured creditors - is this a correct understanding or not?

The Georgia Code - Corporations and Partnerships - Title 14, Section 14-11-201 states: "(a) A limited liability company may be formed under this chapter for any lawful purpose. If the purpose for which a limited liability company is formed makes it subject to a special provision of law, the limited liability company shall also comply with that provision."

As Bulbul Investments LLC operates an exchange market, I am under the impression that Bulbul is subject to other "special provision(s) of law", which again I am under the impression would require further licenses. Would you care to elucidate on this point? As Camp BX will potentially hold/transfer millions of USD, further information on the subject matter would allow for a better understanding of the risks involved when trading on Camp BX.

I transferred 500 Euro to Mtgox which literally arrived on the eve of the crash/hack. Of course the funds are not more than I can afford to lose, however the risk factor when trading on Bitcoin exchanges has been perfectly exposed (of course the risk factor always existed) and I am considering whether to withdraw completely as, with hindsight, I consider myself foolish to have transferred sums to an entity with a very unclear legal framwork, however novel and benign the concept of Bitcoins is.

The problem with the crossed over lines occured when I attempted to type "provision(s)" with [].

[brendio]

Short selling? Color me suspicious. Are you going to allow naked short sales?

Befuddled,
     We do not allow naked shorts - you have to put 52% coins towards the trade.  Also the trade maximum size is capped.  So $1B government money will not do any good here.

To clarify, we DO NOT borrow from user accounts and only the user can move the coins out of his/her wallet.  There is a dedicated "house account" funded by us for shorts.  This account is risk-managed based on liquidity available in the market to limit our risk exposure.

Will there be an option for account holders to rent their bitcoin to the short seller house account in return for a daily fee?

[goldmar]

Hi Keyur,

I think your site looks very promising, I'm looking forward to see it in action! However, please make sure to provide a payment option for us Europeans. SEPA bank transfers (like with empty gox) would be nice; and you can also have a look at Bitcoin7, they offer the possibility to use Ebank transfers which make the payment appear within seconds in their system. The only thing that sucks with Bitcoin7 is their withdrawal concept: they demand ridiculously high fees (12-22 EUR which is about 17-31 $).

Cheers,
Mark

[ErgoOne]

this looks promising.

i'd much rather have my money compliant to all the various things that money needs to be compliant with, than potentially anonymous but in the hands of amateurs.

if i want anonymity, i'll do BTC > BTC transactions over Tor.

if i want a bank or an exchange, i'll go with staid and boring and all tied up with legal niceties.

i'm looking forward to your launch.  i'll be there.

+10  I'm with Jaime.  I firmly believe that the Bitcoin standard itself should allow anonymity (such as cash does), but I'm not interested in playing games with U.S. law either.  Any trading I do will be above-board.

I might well acquire my first bitcoins here. :-)

[Keyur @ Camp BX]

I have no idea how the previous post had many crossed over lines; i shall resubmit the entire post as I could not edit it successfully.

I must type parts of message again; will update soon.

“Try http://corp.sos.state.ga.us/corp/soskb/CSearch.asp

Keep in mind, other public records take time to update.

I think there is a misunderstanding about the role of FDIC in international customers.  FDIC insures bank accounts, not businesses.  Our accounts are insured by FDIC.

Hope this helps,
      Keyur”

Bulbul Investments LLC is registered as a Limited Liability Company, which affords "limited personal liability for the debts and actions of the LLC". Regarding FDIC, as you state, "FDIC insures bank accounts". I read this as the bank accounts that Bulbul Investments LLC hold are insured in the bank where the account of Bulbul is held. Despite funds held in accounts by Bulbul being insured, if Bulbul were to apply for bankruptcy, any deposits to Camp BX that are not in the account would not be redeemable due to the limited personal liability, and depositors to Camp BX are unsecured creditors - is this a correct understanding or not?

The Georgia Code - Corporations and Partnerships - Title 14, Section 14-11-201 states: "(a) A limited liability company may be formed under this chapter for any lawful purpose. If the purpose for which a limited liability company is formed makes it subject to a special provision of law, the limited liability company shall also comply with that provision."

As Bulbul Investments LLC operates an exchange market, I am under the impression that Bulbul is subject to other "special provision(s) of law", which again I am under the impression would require further licenses. Would you care to elucidate on this point? As Camp BX will potentially hold/transfer millions of USD, further information on the subject matter would allow for a better understanding of the risks involved when trading on Camp BX.

I transferred 500 Euro to Mtgox which literally arrived on the eve of the crash/hack. Of course the funds are not more than I can afford to lose, however the risk factor when trading on Bitcoin exchanges has been perfectly exposed (of course the risk factor always existed) and I am considering whether to withdraw completely as, with hindsight, I consider myself foolish to have transferred sums to an entity with a very unclear legal framwork, however novel and benign the concept of Bitcoins is.

The problem with the crossed over lines occured when I attempted to type "provision(s)" with [].

Dennis,
       Sorry to hear that you were among those affected by the Mt. Gox incident.

What you describe sounds like SIPC, not FDIC. Unfortunately Bitcoins and Camp BX are not covered under SIPC.  You can do additional research at:
http://www.sipc.org/

Hope this helps,
     Keyur

[dennis_sweden]

Dennis,
       Sorry to hear that you were among those affected by the Mt. Gox incident.

What you describe sounds like SIPC, not FDIC. Unfortunately Bitcoins and Camp BX are not covered under SIPC.  You can do additional research at:
http://www.sipc.org/

Hope this helps,
     Keyur

Securites Investor Protection is not what my question relates to. Camp BX claims under section "Is my money safe" that all funds are maintained in FDIC-insured bank accounts. As Bulbul Investments LLC is not a "Bank" it cannot hold any funds for its registered users in FDIC-insured bank accounts, so the only remaining option, as I see it, for any funds to be covered by FDIC insurance would be in accordance with my previous entry; i.e. that funds deposited with Bulbul Investments LLC are insured in such bank accounts held by Bulbul, but do not afford any registered users safety in the event of Bulbul filing for bankruptcy, or any other event that negavtively affects assets held by Bulbul.

[NO_SLAVE]

well, youre light years ahead of mtgox already if your actually doing security audits.
This is how we do stuff, not live tesing with other peoples money.
more power to you my friends.

I think your name could have been better, but hey I suppose thats beside the point.

[dennis_sweden]

Elggawf,
      I apologize if some of the answers came across as shady - that was never the intention.

Keep in mind that answers to seemingly simple questions come after long discussions with lawyers, scanning through policy fine print, and back and forth communications with government agencies like Department of Banking and Finance.  These answers represent a competitive advantage for a business.  I have to straddle a fine line between sharing and open-sourcing the business to competition.

If communication with government agencies like the Department of Banking and Finance has taken place, Camp BX/Bulbul Investments LLC would be in compliance with U.S. Code CHAPTER 18—BANK SERVICE COMPANIES § 1861

(2) the term “bank service company” means:

(B) any limited liability company—
(i) which is organized to perform services authorized by this chapter; and
(ii) all of the members of which are 1 or more insured depository institutions.

(4) the term “depository institution” means, except when such term appears in connection with the term “insured depository institution”, an insured bank, financial institution subject to examination by the Director of the Office of Thrift Supervision or the National Credit Union Administration Board, or a financial institution the accounts or deposits of which are insured or guaranteed under State law and are eligible to be insured by the Federal Deposit Insurance Corporation, the Federal Savings and Loan Insurance Corporation, or the National Credit Union Administration Board;

These provisions essentially state that a “limited liability company” “must be eligible to be insured by the FDIC” to obtain insurance. As Bulbul Investments LLC is not registered at the "Department of Banking & Finance" in Georgia, it is inconceivable that Bulbul is eligible to participate in FDIC insurance, or in compliance with State of Georgia - Department of Banking and Finance regulations.

Grant asked on June 22, 2011, 05:17:30 pm in thread Camp BX Platform in Beta: Margin Trading, Short Selling, and Advanced Orders (http://forum.bitcoin.org/index.php?topic=20777.0;all)

“So, basically if i deposit upto $250,000 to your exchange and you become insolvent (for whatever reason that could be) i am guaranteed my deposit by your government ?

Can you point me to some documents that proof your registration ? (might be i overlooked it, but i looked through your site and couldn't find anything)”

Whereas elggwf asked on June 23, 2011, 12:35:26 am in the same thread

“What do you mean by you're "FDIC insured" - did you get the FDIC to insure all your USD holdings? What about the BTC holdings, will those be insured too?”

and neither Grant nor elggwf received an answer; so I will make a very clear statement: the information on Camp BX website under "Is my money safe" is simply not true, which also applies to the information under “Legal compliance”:

“The foundation of our operations is an active and prominent compliance program, and we are committed to maintaining full compliance with State of Georgia - Department of Banking and Finance regulations.”

Camp BX might have an exchange that is far superior to Mtgox (of which I am not capable of making any judgement upon), but regarding providing accurate and relevant information in a timely manner, I fail to see any material difference.

[Keyur @ Camp BX]

Elggawf,
      I apologize if some of the answers came across as shady - that was never the intention.

Keep in mind that answers to seemingly simple questions come after long discussions with lawyers, scanning through policy fine print, and back and forth communications with government agencies like Department of Banking and Finance.  These answers represent a competitive advantage for a business.  I have to straddle a fine line between sharing and open-sourcing the business to competition.

If communication with government agencies like the Department of Banking and Finance has taken place, Camp BX/Bulbul Investments LLC would be in compliance with U.S. Code CHAPTER 18—BANK SERVICE COMPANIES § 1861

(2) the term “bank service company” means:

(B) any limited liability company—
(i) which is organized to perform services authorized by this chapter; and
(ii) all of the members of which are 1 or more insured depository institutions.

(4) the term “depository institution” means, except when such term appears in connection with the term “insured depository institution”, an insured bank, financial institution subject to examination by the Director of the Office of Thrift Supervision or the National Credit Union Administration Board, or a financial institution the accounts or deposits of which are insured or guaranteed under State law and are eligible to be insured by the Federal Deposit Insurance Corporation, the Federal Savings and Loan Insurance Corporation, or the National Credit Union Administration Board;

These provisions essentially state that a “limited liability company” “must be eligible to be insured by the FDIC” to obtain insurance. As Bulbul Investments LLC is not registered at the "Department of Banking & Finance" in Georgia, it is inconceivable that Bulbul is eligible to participate in FDIC insurance, or in compliance with State of Georgia - Department of Banking and Finance regulations.

Grant asked on June 22, 2011, 05:17:30 pm in thread Camp BX Platform in Beta: Margin Trading, Short Selling, and Advanced Orders (http://forum.bitcoin.org/index.php?topic=20777.0;all)

“So, basically if i deposit upto $250,000 to your exchange and you become insolvent (for whatever reason that could be) i am guaranteed my deposit by your government ?

Can you point me to some documents that proof your registration ? (might be i overlooked it, but i looked through your site and couldn't find anything)”

Whereas elggwf asked on June 23, 2011, 12:35:26 am in the same thread

“What do you mean by you're "FDIC insured" - did you get the FDIC to insure all your USD holdings? What about the BTC holdings, will those be insured too?”

and neither Grant nor elggwf received an answer; so I will make a very clear statement: the information on Camp BX website under "Is my money safe" is simply not true, which also applies to the information under “Legal compliance”:

“The foundation of our operations is an active and prominent compliance program, and we are committed to maintaining full compliance with State of Georgia - Department of Banking and Finance regulations.”

Camp BX might have an exchange that is far superior to Mtgox (of which I am not capable of making any judgement upon), but regarding providing accurate and relevant information in a timely manner, I fail to see any material difference.

Dennis,
       You seem painfully new to USA rules and regulations, but I will make one final attempt to elaborate.

We keep our cash deposits in a bank account that is insured by FDIC.  If the bank fails (there were 140 bank failures in 2009) then your money is safe.  However in USA there is no insurance for business solvency.  If the business goes under, than that is the risk you take with your investment.

In other words, we are a business not a bank.  Banks don't accepts Bitcoins so far.

Take care,       
     Keyur

[Keyur @ Camp BX]

well, youre light years ahead of mtgox already if your actually doing security audits.
This is how we do stuff, not live tesing with other peoples money.
more power to you my friends.

I think your name could have been better, but hey I suppose thats beside the point.

Thank you NS! 

Stay tuned for the results!
      - Keyur

[dennis_sweden]

Dennis,
       You seem painfully new to USA rules and regulations, but I will make one final attempt to elaborate.

We keep our cash deposits in a bank account that is insured by FDIC.  If the bank fails (there were 140 bank failures in 2009) then your money is safe.  However in USA there is no insurance for business solvency.  If the business goes under, than that is the risk you take with your investment.

In other words, we are a business not a bank.  Banks don't accepts Bitcoins so far.

Take care,      
     Keyur

This information is the exact information I asked with my post at June 26, 2011, 10:53:29 pm

Bulbul Investments LLC is registered as a Limited Liability Company, which affords "limited personal liability for the debts and actions of the LLC". Regarding FDIC, as you state, "FDIC insures bank accounts". I read this as the bank accounts that Bulbul Investments LLC hold are insured in the bank where the account of Bulbul is held. Despite funds held in accounts by Bulbul being insured, if Bulbul were to apply for bankruptcy, any deposits to Camp BX that are not in the account would not be redeemable due to the limited personal liability, and depositors to Camp BX are unsecured creditors - is this a correct understanding or not?

and received the answer

Dennis,
       Sorry to hear that you were among those affected by the Mt. Gox incident.

What you describe sounds like SIPC, not FDIC. Unfortunately Bitcoins and Camp BX are not covered under SIPC.  You can do additional research at:
http://www.sipc.org/

Hope this helps,
     Keyur

So it is very inaccurate to state that I am painfully new to U.S. regulations. However, having now received an answer to my original question, and recieving an unequivocal answer to whether Camp BX is regulated solely by business regulations or by business and banking regulations, I retract my statement that "the information on Camp BX website under "Is my money safe" is simply not true".

[qualia8]

If margin trading is allowed, then chances are, your deposits will be used to lend.  Essentially, margin trading = fractional reserve banking + trading.  So, the FDIC thing may be irrelevant, because *your* deposit will be lent to other Camp BX users.  Am I wrong?

Cool platform, btw.  I'll be there, but still won't trust it with sums I can't afford to lose.