[HAVELOCK] Crypto Financial (CFIG) Official Thread

[kleeck]

Priority in Dividends issued to Havelock Investments Shareholders
Public Update to our prospectus:

DIVIDEND POLICY
revised August 16, 2013

On a monthly basis Crypto Financial will distribute dividends solely to unit holders on Havelock until the accumulated dividends total BTC0.15 per unit.
Moving forward from that point, dividends will be distributed equally among Havelock unit holders and private unit holders.
One Hundred Percent (100%) of all net income derived from the exchange of Fiat Currency to Crypto Currencies and vice versa by Crypto Financial will be paid out in dividends.

To be clear, would the use of your debit cards for cash (i.e. ATM withdraws or sales requiring a BTC to Fiat conversion) be considered exchanging crypto currency to fiat and thus fall be paid out as part of the monthly dividend?

Thank you.

Crypto Financial will generate two types of revenue streams.

1. Fees from operating as a Financial Services provider: In and Out wire fees, conversion from Fiat to Fiat EUR > USD > JPY, Debit card fees etc.. These fees will pay for the day to day operation and growth of the company and will continue to be reinvested in the company. We will try to keep those fees to a minimum as to allow for our services to be offered at the lowest rate possible for Crypto Currencies customers and merchants. As the volume of our Active customers rise the fees will be lowered and vice versa.

Please remember that our company will only serve Crypto Currency customers and not the general population that just wants to open an international Bank account. This is in essence a Financial Services company by Bitcoiners for Bitcoiners. As more and more financial institution are closing their doors to Bitcoin users, we would like to be the company that provides Financial Services support to the Bitcoin community.

2. All net income derived from Profit Sharing agreements with Software Exchanges Platforms and Direct Purchase companies will be paid in turn to the Shareholders. Some of that income will be reinvested in future integration cost with said Exchange companies.

So to sum it up, think of Crypto Financial as a global "Credit Union" Allowing any Bitcoin related business that needs to interact with Fiat work with us.

We have revised our Dividends Policy to reflect the fact that our shareholders through Havelock Investments will receive priority for paid dividends until the price of ฿0.15 is reached.


Thank you,

Crypto Financial

Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.

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[Crypto Financial]

Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.

Thank you kleeck,

We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone.
Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday.

Crypto Financial

[jedunnigan]

Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.

Thank you kleeck,

We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone.
Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday.

Crypto Financial

Are you registered with the SEC?

[canth]

Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.

Thank you kleeck,

We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone.
Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday.

Crypto Financial

Are you registered with the SEC?

Really? Just to clarify, you're asking if a company without a US presence, listed on a Canadian crypto currency exchange and accepting bitcoin investments from 'anonymous' participants is registered with the SEC? And if the answer were yes, would you view this as a positive aspect?

[realrover]

Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.

Thank you kleeck,

We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone.
Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday.

Crypto Financial

Are you registered with the SEC?

Really? Just to clarify, you're asking if a company without a US presence, listed on a Canadian crypto currency exchange and accepting bitcoin investments from 'anonymous' participants is registered with the SEC? And if the answer were yes, would you view this as a positive aspect?

+1
LOL

[jedunnigan]

Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.

Thank you kleeck,

We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone.
Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday.

Crypto Financial

Are you registered with the SEC?

Really? Just to clarify, you're asking if a company without a US presence, listed on a Canadian crypto currency exchange and accepting bitcoin investments from 'anonymous' participants is registered with the SEC? And if the answer were yes, would you view this as a positive aspect?

Lol, perhaps you missed the entire thread. These guys are trying to be above-board, as is reflected in their [supposed] backing by a Panamanian bank. As an extension of this you would assume they are trying to run a legit operation, so it's only fair I ask. Or perhaps you would prefer me to just assume one way or the other. That always ends well.

Regardless, what I think really shouldn't matter to you, as we should deduce our own judgments about these guys, so I'm curious as to why you really care what I think anyway? Not to mention you have no idea why I asked the question (as is very clear by your response) in the first place, so again, thanks for that worthless post!

To be clear, the reason I asked is because I want to start a dialogue with them. I assume they aren't and want to ask why.

+1
LOL

[Crypto Financial]

To be clear, the reason I asked is because I want to start a dialogue with them. I assume they aren't and want to ask why. getitnow?

Dear jedunnigan,

If you would like to have a dialogue with us please feel free to contact us at:
contact@cryptofinancial.io or call us! The number is on our site.

Thank you,

Crypto Financial

[jedunnigan]

To be clear, the reason I asked is because I want to start a dialogue with them. I assume they aren't and want to ask why. getitnow?

Dear jedunnigan,

If you would like to have a dialogue with us please feel free to contact us at:
contact@cryptofinancial.io or call us! The number is on our site.

Thank you,

Crypto Financial

Sorry, that wasn't clear. I've already started a dialogue with you outside the forum, but the question I asked (are you registered with the SEC) I would prefer a public response.

[Crypto Financial]

Sorry, that wasn't clear. I've already started a dialogue with you outside the forum, but the question I asked (are you registered with the SEC) I would prefer a public response.

This question has been answered on the first page of our Prospectus, as it states the following:

"Neither the Securities and Exchange Commission nor any state securities commission has approved or disapproved of these securities or determined if this prospectus is truthful or complete. Any representation to the contrary is false."


Thank you,

Crypto Financial

[jedunnigan]

Sorry, that wasn't clear. I've already started a dialogue with you outside the forum, but the question I asked (are you registered with the SEC) I would prefer a public response.

This question has been answered on the first page of our Prospectus, as it states the following:

"Neither the Securities and Exchange Commission nor any state securities commission has approved or disapproved of these securities or determined if this prospectus is truthful or complete. Any representation to the contrary is false."


Thank you,

Crypto Financial

Ah missed that, thanks.

[Crypto Financial]

Ah missed that, thanks.

No Problem!

We have issued a lot of statements through our Prospectus and Business Plan.  It is easy to miss or misunderstand some of them. We are here to work as a team and many of the members of this forum have been a great help. Feels like we are running an open source Financial Services if you ask me.

Thank you,

Crypto Financial

[DeathAndTaxes]

Have you (or is it your intent) to register with FinCEN as a Money Service Business?
If not do you intend to exclude US customers?

[jedunnigan]

Have you (or is it your intent) to register with FinCEN as a Money Service Business?
If not do you intend to exclude US customers?

I thought [international] licensing was implicit in their relationship with a bank, no? If not this whole thing is a wash.

[DeathAndTaxes]

Have you (or is it your intent) to register with FinCEN as a Money Service Business?
If not do you intend to exclude US customers?

I thought [international] licensing was implicit in their relationship with a bank, no? If not this whole thing is a wash.

Well the prospectus and business plan doesn't indicate they plan to. Maybe they do but the omission just simply means another thing clients need to assume.

If they intend to register with FinCEN how to they intend to deal with potentially expensive state licensing?
If they don't intend to register with FinCEN because they are not accepting US based clients then why isn't that explained?
If they don't intend to register with FinCEN or exclude US customers, what is the rational and what are the potential risks?

Right now it is simply left open ended.

[jedunnigan]

Have you (or is it your intent) to register with FinCEN as a Money Service Business?
If not do you intend to exclude US customers?

I thought [international] licensing was implicit in their relationship with a bank, no? If not this whole thing is a wash.

Well the prospectus and business plan doesn't indicate they plan to.  CFIG not the bank is the one engaged in the business of money transfer (accepting funds from clients and depositing those funds into the exchange's account).

Right, but the bank is allowing them to be agents of their license it appears. That's my assumption. If I am wrong I will be very shocked, because even if they have the funds to get licenses, (as you know) it will be a year minimum before they can get approved. And that's if they are lucky.

guess we just wait for them to clarify

[Crypto Financial]

If they intend to register with FinCEN how to they intend to deal with potentially expensive state licensing?
If they don't intend to register with FinCEN because they are not accepting US based clients then why isn't that explained?
If they don't intend to register with FinCEN or exclude US customers, what is the rational and what are the potential risks?

Dear DeathAndTaxes (Relevant username for a relevant question),

We will serve U.S based customers. Crypto Financial is not located within the U.S so it is not subject to State by State Jurisdiction of those states. All funds that any of our customers will transfer to us or receive by us will be transferred via your Bank institution directly to us, or via an intermediary partner Bank that we work within your country.

We are not an MSB or require a different Money Transmitter License. We will however comply with all BSA (Bank Secrecy Act) Requirements, which is also controlled by FinCen. Any Financial Services provider regardless of their location worldwide comply with the countless U.S Government entities when dealing with U.S Citizens or U.S based corporations.  That is why it is getting harder and harder for U.S Citizens to open Bank accounts in foreign Banks, the paperwork and related cost just lowers the incentive. Which I believe is the ultimate goal of the U.S, not to have foreign Banks provide services to U.S customers.


Thank you,

Crypto Financial

[DeathAndTaxes]

If they intend to register with FinCEN how to they intend to deal with potentially expensive state licensing?
If they don't intend to register with FinCEN because they are not accepting US based clients then why isn't that explained?
If they don't intend to register with FinCEN or exclude US customers, what is the rational and what are the potential risks?

Dear DeathAndTaxes (Relevant username for a relevant question),

We will serve U.S based customers. Crypto Financial is not located within the U.S so it is not subject to State by State Jurisdiction of those states. All funds that any of our customers will transfer to us or receive by us will be transferred via your Bank institution directly to us, or via an intermediary partner Bank that we work within your country.

We are not an MSB or require a different Money Transmitter License. We will however comply with all BSA (Bank Secrecy Act) Requirements, which is also controlled by FinCen. Any Financial Services provider regardless of their location worldwide comply with the countless U.S Government entities when dealing with U.S Citizens or U.S based corporations.  That is why it is getting harder and harder for U.S Citizens to open Bank accounts in foreign Banks, the paperwork and related cost just lowers the incentive. Which I believe is the ultimate goal of the U.S, not to have foreign Banks provide services to U.S customers.


Thank you,

Crypto Financial

Well glad you put that out there in black and white.  Investors can judge the merit of those arguments themselves.

On July 21, 2011, the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a final rule on definitions and other regulations relating to money services businesses (Final Rule).1 The Final Rule amended the definition of "money services business" at 31 CFR 1010.100(ff). An entity may now qualify as a money services business (MSB) under the Bank Secrecy Act (BSA) regulations based on its activities within the United States, even if none of its agents, agencies, branches or offices are physically located in the United States. The Final Rule arose in part from the recognition that the Internet and other technological advances make it increasingly possible for persons to offer MSB services in the United States from foreign locations.2 FinCEN seeks to ensure that the BSA rules apply to all persons engaging in covered activities within the United States, regardless of the person's physical location.

http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-A001.html

It seems confusing to say you will comply with the requirements of the BSA and won't register as a MSB as registration is one the requirements.  

However for the sake of the argument lets say you are right (quote from FinCEN notwithstanding) and foreign entities aren't subject to US federal and state regulations even when offering products & services to US residents then .... why would foreign exchanges need your service?  If you aren't subject to the definition of MSB then they aren't either so they might as well accept funds directly from customers and cut out the expensive middle man (CFIG).

I have to say I am disappointed, I was at least hoping for some clever legal "loophole".

[Crypto Financial]

Hi DeathAndTaxes,

We believe you are confusing two issues when it comes to FinCen. An MSB is a business like Western Union or Money Gram. They handle your money in a temporary matter and transmit it somewhere else on your behalf. They are required to be licensed as a Money Transmitter since they accept "funds" at their location, they must be licensed by someone in their jurisdiction to garner trust that they will be responsible for your funds and not just walk away with it.

On the other hand a Fiduciary Financial Service provider accepts Deposits on your behalf, Provide Loans and Credit (We won't), and may hold those funds indefinitely until you instruct them otherwise. Those Financial Service providers are not MSBs, but actually operate their business as a Bank and therefore are required to comply with the BSA when working with U.S Citizens.

You may perform a search under the FinCen MSB search page and look for "Registered Entities" and put Panama as the location or any other country for that matter. You will only find some
Money Exchanges and Transfers there. You will not see HSBC or Citibank there.

Also any Software Exchange Platform that will offer their services to our customers will not be required to follow any AML/KYC/SAR regulations, since we will take care of that. They will only offer the Exchange as a trading platform from crypto to fiat and vice versa. They will not have any personal information related to our customers.

We hope this clears it up.

Crypto Financial

[DeathAndTaxes]

Hi DeathAndTaxes,

We believe you are confusing two issues when it comes to FinCen. An MSB is a business like Western Union or Money Gram.

No a MSB is what the regulations say an MSB is.  You are accepting funds from a customer and transferring them to an exchange for a profit.  That is a money transmitter.  It is the very definition of money transmission.

(5) Money transmitter —(i) In general. (A) A person that provides money transmission services. The term “money transmission services” means the acceptance of currency, funds, or other value that substitutes for currency from one person and the transmission of currency, funds, or other value that substitutes for currency to another location or person by any means. “Any means” includes, but is not limited to, through a financial agency or institution; a Federal Reserve Bank or other facility of one or more Federal Reserve Banks, the Board of Governors of the Federal Reserve System, or both; an electronic funds transfer network; or an informal value transfer system; or

(B) Any other person engaged in the transfer of funds.

Are you saying accepting USD from a client and transferring those USD at the direction of the client to an exchange is NOT money transmission?  This is pretty cut and dry.  The regulatory status of Bitcoin may be vague but USD to USD transactions are not.  Then again i am just some guy so let me ask it another way.  Do you have any statement by legal counsel or FinCEN (via administrative ruling) that the activity is not regulated as a MSB?

[jedunnigan]

Hi DeathAndTaxes,

We believe you are confusing two issues when it comes to FinCen. An MSB is a business like Western Union or Money Gram.

No a MSB is what the regulations say an MSB is.  You are accepting funds from a customer and transferring them to an exchange for a profit.  That is a money transmitter.  It is the very definition of money transmission.

(5) Money transmitter —(i) In general. (A) A person that provides money transmission services. The term “money transmission services” means the acceptance of currency, funds, or other value that substitutes for currency from one person and the transmission of currency, funds, or other value that substitutes for currency to another location or person by any means. “Any means” includes, but is not limited to, through a financial agency or institution; a Federal Reserve Bank or other facility of one or more Federal Reserve Banks, the Board of Governors of the Federal Reserve System, or both; an electronic funds transfer network; or an informal value transfer system; or

(B) Any other person engaged in the transfer of funds.

Are you saying accepting USD from a client and transferring those USD at the direction of the client to an exchange is NOT money transmission?  This is pretty cut and dry.  The regulatory status of Bitcoin may be vague but USD to USD transactions are not.  Then again i am just some guy so let me ask it another way.  Do you have any statement by legal counsel or FinCEN (via administrative ruling) that the activity is not regulated as a MSB?

They are trying to say this: If you are a bank you don't need to register as an MSB because you are an MSB and more. You have the licensing (under BSA) necessary to do these transactions and will be doing KYC/AML implicitly.

I think you are misreading their posts, it's partially the language barrier on their part.