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Author Topic: [IPVO] [Multiple Exchanges] Neo & Bee - LMB Holdings  (Read 658692 times)
hasher87
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September 08, 2013, 04:18:08 AM
 #81

Question is, why Cyprus?
jedunnigan
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September 08, 2013, 04:32:32 AM
 #82

Hmmm, the risks section seems dangerously sparse. I am specifically concerned with the "Regulatory Risks" section. As you dutifully mention on the third page of the prospectus the following restriction has been placed on Cypriots:
Quote
● Overseas transactions may not exceed €5,000 per month per person, and only if the transaction is sending money to a student or completing payment of an invoice related to a business.
Bitcoin subverts this unequivocally. How will you explain to regulators that once the user has withdrawn their Bitcoins there is no way to manage where they are sent? You can't. This disproves one of your points in the regulatory risk section:

Quote
By holding assets in Bitcoin outside of the legacy banking system, there is no current legal framework or technical means for the Central Bank of Cyprus or the European Central Bank to seize Neo’s customer deposits.

The law that would allow them to freeze (or maybe even seize) would [in this case] be that they couldn't be sure where funds are actually being sent once the coins are in the wild.

From that perspective it would not be a far to leap to think that Cyprus wouldn't necessarily make Bitcoins illegal, but they could put a temporary ban on any Cyprus-based Bitcoin business. On the flip side you say

Quote
Neo will work closely with regulators and the government to ensure the impact of our operations shall be a benefit to the economy of Cyprus, thus preventing the need to declare the use of Bitcoin as illegal.

So do you have any actual relationships with these regulators? Wouldn't it be sensible, given the enormity of your business and the source of funding, to be absolutely sure that one day xyz agency doesn't coming knocking on your doors and shut you down without notice? At least have some measure of govoernment sentiment before you dive head first into such an ambitious operation.

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September 08, 2013, 05:00:50 AM
 #83

We currently do not require a Banking License
You'll be taking deposits off people, you absolutely will need a banking licence unless your retirement plans include 'free room and board in jail' Wink

We are still determining the AML/KYC solution that we shall proceed with.
Will drop you a PM

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TsuyokuNaritai
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September 08, 2013, 05:14:51 AM
 #84

What are the real reasons behind the 'virtual entity' nonsense when you could be selling the real shares in the real legal entity ?
The virtual entity is to ensure current American SEC regulations are not being broken by investors from America.
Why are you sure that calling it virtual will definitely exempt you from all SEC regulations?

jedunnigan
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September 08, 2013, 05:18:20 AM
 #85

What are the real reasons behind the 'virtual entity' nonsense when you could be selling the real shares in the real legal entity ?
The virtual entity is to ensure current American SEC regulations are not being broken by investors from America.
Why are you sure that calling it virtual will definitely exempt you from all SEC regulations?

This IP"V"O absolutely is under the purview of the SEC if this caters to US citizens. Any claim to the contrary is misinformed or a lie.
TsuyokuNaritai
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September 08, 2013, 05:24:11 AM
Last edit: September 08, 2013, 05:57:54 AM by TsuyokuNaritai
 #86

What are the real reasons behind the 'virtual entity' nonsense when you could be selling the real shares in the real legal entity ?
The virtual entity is to ensure current American SEC regulations are not being broken by investors from America.
Why are you sure that calling it virtual will definitely exempt you from all SEC regulations?
This IP"V"O absolutely is under the purview of the SEC if this caters to US citizens. Any claim to the contrary is misinformed or a lie.
I'd be particularly interested to hear TAT's opinion on this, after his many condemnations of Burnside for doing something very similar.

Edit: added quote below from the BTC-TC thread:

Your perspective is short-sighted, in my opinion.

Yes, it is easier to think and behave how you recommend, but that does not make it healthy or right or smart or necessary.

This is not a question of shoddy legalese, it is calling a duck a spade for the preservation of the duck trade.

He can afford KYC hoops, and there are services that can help with that. Why assume he has made any effort at all in that regard?

No one expects a bitcoin financial service effort to be totally SEC-proof at this point, but the SEC does indeed value good faith efforts to operate within the law. They do not, however, respect deception and the contrary.

Yes, I can acknowledge that legal developments take time, I know this first hand. But I do not see how asserting a false position is wise, nor how a legal team could recommend such.

jedunnigan
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September 08, 2013, 05:36:26 AM
 #87

What are the real reasons behind the 'virtual entity' nonsense when you could be selling the real shares in the real legal entity ?
The virtual entity is to ensure current American SEC regulations are not being broken by investors from America.
Why are you sure that calling it virtual will definitely exempt you from all SEC regulations?
This IP"V"O absolutely is under the purview of the SEC if this caters to US citizens. Any claim to the contrary is misinformed or a lie.
I'd be particularly interested to hear TAT's opinion on this, after his many condemnations of Burnside for doing something very similar.

Why bother? Just read the exemptions section of the Securities Act of 1933. There is no exemption for virtual securities.

http://www.sec.gov/about/laws/sa33.pdf
Ninshatamoto
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September 08, 2013, 05:49:45 AM
 #88

Curious as to why this isn't being featured on Havelock.  I had hoped that XBOND being placed on Havelock was a sign that TAT was planning to house future ventures there.
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September 08, 2013, 06:37:22 AM
 #89

1. How exactly do you intend to cover losses (and make profits) in case of dramatically falling of BTC--EUR exchange rate? Please explain it in a simple way like I'm 10 years old.

2. Why do you choose to relate on third-party company (TAT Investments) for managing your IPO? Is it too difficult for you to cope with such a simple task for yourselves?

3. Exactly what services will you provide for you customers?
cryptocyprus (OP)
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September 08, 2013, 08:45:01 AM
 #90

Something here reminds me of Garr255 scamzor. Maybe its the smell.

We are taking extra verification steps with all parties involved to demonstrate we are who we say we are coupled with evidence of our strategic partnerships.

I was shocked too that it took 5 pages for the first mention of a scam.
Question is, why Cyprus?

This is where we live, also to spark mass changes you need a "big bang event" the theft of peoples life savings was this event. Cyprus is also not too big to gain widespread adoption, but not too small for it to go unnoticed on a global scale.

when will  be ipo on BF??  i am in !!

The dates will be announced shortly.

Hmmm, the risks section seems dangerously sparse. I am specifically concerned with the "Regulatory Risks" section. As you dutifully mention on the third page of the prospectus the following restriction has been placed on Cypriots:
Quote
● Overseas transactions may not exceed €5,000 per month per person, and only if the transaction is sending money to a student or completing payment of an invoice related to a business.
Bitcoin subverts this unequivocally. How will you explain to regulators that once the user has withdrawn their Bitcoins there is no way to manage where they are sent? You can't. This disproves one of your points in the regulatory risk section:

Quote
By holding assets in Bitcoin outside of the legacy banking system, there is no current legal framework or technical means for the Central Bank of Cyprus or the European Central Bank to seize Neo’s customer deposits.

The law that would allow them to freeze (or maybe even seize) would [in this case] be that they couldn't be sure where funds are actually being sent once the coins are in the wild.

From that perspective it would not be a far to leap to think that Cyprus wouldn't necessarily make Bitcoins illegal, but they could put a temporary ban on any Cyprus-based Bitcoin business. On the flip side you say

Quote
Neo will work closely with regulators and the government to ensure the impact of our operations shall be a benefit to the economy of Cyprus, thus preventing the need to declare the use of Bitcoin as illegal.

So do you have any actual relationships with these regulators? Wouldn't it be sensible, given the enormity of your business and the source of funding, to be absolutely sure that one day xyz agency doesn't coming knocking on your doors and shut you down without notice? At least have some measure of govoernment sentiment before you dive head first into such an ambitious operation.



Initially the possibility of people withdrawing Bitcoin to the wild is slim because that would entail them understanding how to use Bitcoin in its raw format, we expect that until we open up the possibility for opening accounts from within the wider European Union direct Bitcoin withdrawals will be almost non existent.

The capital controls are under review in the September meeting of the Troika however this is of no concern because we are signing off on a partnership shortly that will enable the physical notes to remain in Cyprus whilst providing us with those funds electronically outside of the traditional Cypriot banking infrastructure.  This ensures that we have zero exposure with our "competitors", ensuring they cannot try and complicate matters with frozen accounts, temporary holds etc.

We have spent the last 12 months making the necessary contacts with both regulators, government officials and key influential groups such as those now challenging the EU over the bail-ins. The initial lobbying efforts have been very promising, the president himself has spoken about the need for a "Plan B". One of the joys of Cyprus being small is the 2 degrees of separation, in larger countries this would have been a much drawn out process after speaking with personal assistants for months just to ensure a letter is passed onto the relevant person. Here we don't have that problem.

We currently do not require a Banking License
You'll be taking deposits off people, you absolutely will need a banking licence unless your retirement plans include 'free room and board in jail' Wink

We are still determining the AML/KYC solution that we shall proceed with.
Will drop you a PM

We are taking deposits from people in exchange for Bitcoin, current regulations entails this is no different from buying a loaf of bread from the bakery and the bakery providing storage of the bread. In Cyprus Bitcoin isn't "money" yet, however we are the ones lobbying to change this. All of our policies, procedures and systems are planned to be compliant with existing regulations. We want that legal framework to adhere too because from a PR perspective we will not be operating within grey areas of the law.

I will answer your PM once I have caught up on the questions here in this thread.

1. How exactly do you intend to cover losses (and make profits) in case of dramatically falling of BTC--EUR exchange rate? Please explain it in a simple way like I'm 10 years old.

2. Why do you choose to relate on third-party company (TAT Investments) for managing your IPO? Is it too difficult for you to cope with such a simple task for yourselves?

3. Exactly what services will you provide for you customers?

1. We will implement a hedging strategy utilizing our own reserves, this strategy will be constantly changing, we will also be setting the price locally to ensure that sudden falls in price are not realized on the front line immediately. This gives us an opportunity to increase trading activities to strengthen our positions. A good trader(s) will make gains under volatile conditions, irrespective of the direction of the movement. Sorry I cannot provide the exact strategies for different scenarios but doing so would be like playing poker with see through cards.

2. It is not a case of difficulty, it is based on time demands. As I am certain any potential investor wants me and the team to concentrate on the business and not handling asset transfers all day. My time is extremely limited as it is, I had to move 5 meetings today (Sunday) to ensure I could have some time to answer questions.

3. We provide the opportunity for our customers to buy Bitcoin and store them in a user friendly and secure wallet, some of our products remove the risk of volatility away from the customer and onto ourselves, we will also be providing a method for merchants to accept Bitcoin payments. In the near future we plan to offer insurance products, lending services and other financial related products.



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chkgk
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September 08, 2013, 08:55:43 AM
 #91

Apart from the IP(V)O terms, I have some questions that are quite important to potential investors I presume:

1) In your prospectus you state that you will accept Cash, SPEA and Wire transfer methods for deposits and withdrawals of Euros.
How does that not require a full banking license under current Cyprus / European Banking Regulations?

2) In your initial post here you state that customers will receive an 8-digit account number.
Why would a customer want that account number? For SEPA he will already be provided with the IBAN / bic combination.
For pure bitcoin transactions he only needs a bitcoin private / public key pair.

3) Your prospectus says that Bitcoin wallets are generated, printed, loaded and sealed in the customer's presence to ensure security. They will be subject to a 0.5% deposit fee and an optional additional 0.5% fee to retain the wallet in the branch's vault.
How do you plan to charge the deposit and storage fee?
Will you keep the private keys of the generated wallets to be able to "deduct" the fees?
How is that secure for the customer?

4) You project BTC/EUR price increases for the first two quarters, not any further. Why?

5) Your prospectus ends with a future outlook which only talks about the next 2 years. This is VERY short-term for a financial institution. If customers trust you with their money, they expect you to have a plan for more than two years.
Please provide the classic 5 year and 10 year outlooks.

6) You tell us that the BEE software and network infrastructure is currently being developed. Are you sure you can meet your roll-out projection of early 2014?

7) Your flagship branch is currently being designed and constructed. What is it?
Is it being designed or being constructed?
How far along are you? Will it be ready for your early 2014 launch?
Also, you provide two pictures, one where it says NEO on a banderole around the whole building, and one where only the leftmost "shopwindow" ins marked as the branch location. Which is it?

8 ) Seeing that you are developing your own payment network, how do you plan to break the dominance of the current monopolist?
Will your cards work at each and every terminal of your competitor (i.e. will it use the same protocol)?
Will your cards work at all ATMs in use throughout cyprus?
If not compatible, how many merchants willing to implement your POS Terminals do you currently have signed for the launch in early 2014?
How many for the months after that?


cryptocyprus (OP)
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September 08, 2013, 09:53:27 AM
 #92

1) In your prospectus you state that you will accept Cash, SPEA and Wire transfer methods for deposits and withdrawals of Euros.
How does that not require a full banking license under current Cyprus / European Banking Regulations?

We are selling Bitcoin, something that is not considered "Money" here in Cyprus, although we are proactively lobbying to change this.

2) In your initial post here you state that customers will receive an 8-digit account number.
Why would a customer want that account number? For SEPA he will already be provided with the IBAN / bic combination.
For pure bitcoin transactions he only needs a bitcoin private / public key pair.

Our target demographic is not the existing Bitcoin community, we are providing a way for the average non-technically minded man/woman in the street to use the Bitcoin protocol, feel free to go and ask 5,000 people in your local town or city as to which they prefer using: 31uEbMgunupShBVTewXjtqbBv5MndwfXhb or 12121212 The response will be overwhelmingly in favor of the 8 digit number.

The acceptance of SEPA and Wire transfers are enabled through a strategic partnership with a fiduciary financial service provider, we are currently under NDA's with three potential partners, however we are hoping to be in a position to announce the partnership at the Amsterdam conference.


3) Your prospectus says that Bitcoin wallets are generated, printed, loaded and sealed in the customer's presence to ensure security. They will be subject to a 0.5% deposit fee and an optional additional 0.5% fee to retain the wallet in the branch's vault.
How do you plan to charge the deposit and storage fee?
Will you keep the private keys of the generated wallets to be able to "deduct" the fees?
How is that secure for the customer?

This is only for those that want to purchase Bitcoins and walk out with them in a sealed paper wallet. The fees would be deducted at the time of exchange, not after the wallet has been funded.

4) You project BTC/EUR price increases for the first two quarters, not any further. Why?

Following this period our future income will not be dependent upon this factor due to the products we shall be adding to our offerings, following the first two quarters of trading will dictate our strategy towards the growth and expansion of our business, which in turn will provide a better indication at the rate we shall be adding liquidity to the market.

5) Your prospectus ends with a future outlook which only talks about the next 2 years. This is VERY short-term for a financial institution. If customers trust you with their money, they expect you to have a plan for more than two years.
Please provide the classic 5 year and 10 year outlooks.

We are writing the handbook on this, as we are the ones providing the solutions for the mass adoption of Bitcoin first. After the first two quarters it will provide a better insight into our 5 and 10 year plans. We have guidelines as to where we want to be within 5, 10, 15 and 20 years. One could argue that the sign-up rate in January, February and March 2014 will be a strong indication as to the rate at which people will adopt to what we are offering.

6) You tell us that the BEE software and network infrastructure is currently being developed. Are you sure you can meet your roll-out projection of early 2014?

100% yes.

7) Your flagship branch is currently being designed and constructed. What is it?
Is it being designed or being constructed?
How far along are you? Will it be ready for your early 2014 launch?
Also, you provide two pictures, one where it says NEO on a banderole around the whole building, and one where only the leftmost "shopwindow" ins marked as the branch location. Which is it?

The interior designers are now incorporating the branding into the designs for the decor of the branch. The builders are creating the secure partitions ready to commence the internal renovations as per the interior designers final plans. This branch will be delivered complete at the end of December, ready for the soft opening in January to commence the account sign-up process.
Both, our offices are on the first floor of the building, the offices have a veranda with a glass wall along the outer edge that we can utilize to brand the full length and width of the building as per the first image.


8 ) Seeing that you are developing your own payment network, how do you plan to break the dominance of the current monopolist?
Will your cards work at each and every terminal of your competitor (i.e. will it use the same protocol)?
Will your cards work at all ATMs in use throughout cyprus?
If not compatible, how many merchants willing to implement your POS Terminals do you currently have signed for the launch in early 2014?
How many for the months after that?

Our network is independent from the existing VISA/MasterCard network, no they will not be useable at the ATM's however we do have the ability to offer "cashback" at the merchant terminals, in effect turning every merchant into an ATM machine (Further details will be provided on this). Many merchants do not accept card payments from the existing monopolist because of the high fees and poor settlement terms (I have recently seen a quote of 60 day settlement terms!). By removing all barriers to entry such as zero fees to set-up the merchant account, vastly lower transaction fees, and almost instant settlement terms, we are providing ourselves with a solid platform to ensure a high adoption rate.

We are already ahead of schedule towards our target of indicated acceptance, it would be unprofessional for me to quote figures until contracts are signed and sealed. Our legal team have the Bee contracts on their list of tasks however the lobbying efforts are taking precedence because the content of the contracts will be dependent upon the outcome of that process.


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WALLET




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September 08, 2013, 10:22:13 AM
 #93

A route for non-bitcoin customers, maybe........ http://www.bitcointrezor.com/

Also, stumbled on this, and see parallels possibly (although im still trying to understand the legitimacy of these, if any?)....... https://www.bitmit.net/en/shop/c/23-money/8-credit-cards

Will you have a recognizable presence/sponsership at the Amsterdam Conference?
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September 08, 2013, 10:30:05 AM
 #94


A route for non-bitcoin customers, maybe........ http://www.bitcointrezor.com/

The trezor hardware wallet is great until you lose it, we want to ensure that as little of a conscious effort as possible has to be made by our customers towards security above and beyond what they are already subjected too.

Also, stumbled on this, and see parallels possibly (although im still trying to understand the legitimacy of these, if any?)....... https://www.bitmit.net/en/shop/c/23-money/8-credit-cards

We will not be offering anonymous anything, one of the biggest concerns from the regulators was the misrepresentation that Bitcoin is completely anonymous. Once we explained this in detail, they are much more receptive to the idea.

Will you have a recognizable presence/sponsership at the Amsterdam Conference?

I am speaking at the conference.




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black2burn
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September 08, 2013, 11:04:32 AM
 #95

Your prospectus mentions an aggressive trading platform to hedge FX fluctuations - Can you elaborate on this a bit more?  Will you using internal manpower/bots or sourcing 3rd party platforms? 

Best of luck!
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September 08, 2013, 11:11:29 AM
 #96


A route for non-bitcoin customers, maybe........ http://www.bitcointrezor.com/

The trezor hardware wallet is great until you lose it, we want to ensure that as little of a conscious effort as possible has to be made by our customers towards security above and beyond what they are already subjected too.

Also, stumbled on this, and see parallels possibly (although im still trying to understand the legitimacy of these, if any?)....... https://www.bitmit.net/en/shop/c/23-money/8-credit-cards

We will not be offering anonymous anything, one of the biggest concerns from the regulators was the misrepresentation that Bitcoin is completely anonymous. Once we explained this in detail, they are much more receptive to the idea.

Will you have a recognizable presence/sponsership at the Amsterdam Conference?

I am speaking at the conference.





Look forward to hearing you.

Can you just explain the context of ......"We have spent the last 12 months making the necessary contacts with both regulators, government officials and key influential groups such as those now challenging the EU over the bail-ins".......... Were there really Bitcoin-Cyprus discussions, this time last year?

 
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September 08, 2013, 11:22:35 AM
 #97

Thanks a lot for your clarifications, cryptocyprus!  Smiley
cryptocyprus (OP)
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September 08, 2013, 12:10:05 PM
 #98

Your prospectus mentions an aggressive trading platform to hedge FX fluctuations - Can you elaborate on this a bit more?  Will you using internal manpower/bots or sourcing 3rd party platforms? 

Best of luck!

We are not restricting ourselves to certain platforms and or methods of trading, it will be a mixture of all mentioned in your post on and away from the public markets. Our team will be managing and constantly developing a complex portfolio of futures and strategic partnerships.



Look forward to hearing you.

Can you just explain the context of ......"We have spent the last 12 months making the necessary contacts with both regulators, government officials and key influential groups such as those now challenging the EU over the bail-ins".......... Were there really Bitcoin-Cyprus discussions, this time last year?


This has been in the planning for 12 months, irregardless of the bail-ins and I personally knew we had to have certain individuals, the media, decision makers on board to launch any type of Bitcoin related business here on the ground for the mass adoption. So yes there was Bitcoin-Cyprus discussions happening this time last year, it wasn't mainstream it was more in passing during that time to gauge reactions and to make those connections, whilst I personally developed the ideas and solving the noted issues surrounding the mass adoption.

Thanks a lot for your clarifications, cryptocyprus!  Smiley

No problem, any more questions that you have will be addressed as quickly as possible.


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ThickAsThieves
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September 08, 2013, 01:09:44 PM
 #99

What are the real reasons behind the 'virtual entity' nonsense when you could be selling the real shares in the real legal entity ?
The virtual entity is to ensure current American SEC regulations are not being broken by investors from America.
Why are you sure that calling it virtual will definitely exempt you from all SEC regulations?
This IP"V"O absolutely is under the purview of the SEC if this caters to US citizens. Any claim to the contrary is misinformed or a lie.
I'd be particularly interested to hear TAT's opinion on this, after his many condemnations of Burnside for doing something very similar.

Edit: added quote below from the BTC-TC thread:

Your perspective is short-sighted, in my opinion.

Yes, it is easier to think and behave how you recommend, but that does not make it healthy or right or smart or necessary.

This is not a question of shoddy legalese, it is calling a duck a spade for the preservation of the duck trade.

He can afford KYC hoops, and there are services that can help with that. Why assume he has made any effort at all in that regard?

No one expects a bitcoin financial service effort to be totally SEC-proof at this point, but the SEC does indeed value good faith efforts to operate within the law. They do not, however, respect deception and the contrary.

Yes, I can acknowledge that legal developments take time, I know this first hand. But I do not see how asserting a false position is wise, nor how a legal team could recommend such.


If you read the provided description of the term IPVO, it makes clear that this is not attempt to do what Burnside is doing. His use of "virtual" is in a context of a "game" in his text. This is not a game, it is virtual-currency-fueled finance. The difference here is that, from a legal standpoint, the IPVO, while similar in ways to an IPO, is quite different.

To date, the bitcoin securities market has attempted to use the term IPO creatively by redefining it to suit its needs, but the term IPO, is meant to imply more than simply selling your company publicly. "IPO" is an accepted term that implies an offering that will be made public on traditional stock exchanges at Wall St and the like, which is obviously not the case here.

Being that most bitcoin IP(V)Os are things like fundraising, crowdfunding, profit-shares, informal entities, and partially unregulated, a unique term must be adopted to differentiate so as not to confuse those familiar with traditional IPOs.

As Danny mentions, there is trailblazing happening here. Both of our legal teams are hard at work establishing ourselves as best as possible within the current framework of guidance. As I have mentioned before, there will be more news on these developments soon, and there will be even more changes to come.
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September 08, 2013, 01:49:48 PM
 #100

If you read the provided description of the term IPVO, it makes clear that this is not attempt to do what Burnside is doing. His use of "virtual" is in a context of a "game" in his text. This is not a game, it is virtual-currency-fueled finance. The difference here is that, from a legal standpoint, the IPVO, while similar in ways to an IPO, is quite different.

To date, the bitcoin securities market has attempted to use the term IPO creatively by redefining it to suit its needs, but the term IPO, is meant to imply more than simply selling your company publicly. "IPO" is an accepted term that implies an offering that will be made public on traditional stock exchanges at Wall St and the like, which is obviously not the case here.

Being that most bitcoin IP(V)Os are things like fundraising, crowdfunding, profit-shares, informal entities, and partially unregulated, a unique term must be adopted to differentiate so as not to confuse those familiar with traditional IPOs.

As Danny mentions, there is trailblazing happening here. Both of our legal teams are hard at work establishing ourselves as best as possible within the current framework of guidance. As I have mentioned before, there will be more news on these developments soon, and there will be even more changes to come.

I do hope it works out, it will be great for bitcoin if this venture can succeed. Thanks for your response, but it addresses why I was curious to hear your opinion on the question, it doesn't answer the actual question...

The virtual entity is to ensure current American SEC regulations are not being broken by investors from America.
Why are you sure that calling it virtual will definitely exempt you from all SEC regulations?

...which as other have commented, appears to not be the case. Cryptocyprus has also avoided the question, even though several people have now raised it.

If it this IPVO wasn't for a financial service I wouldn't be pushing this, but they want to start a bitcoin bank! What other important legal or regulatory things do they believe are ensured that aren't? It's something of a red flag, especially when it's probably only a matter of time before the wrong civil servants in some place or another start looking for excuses to close them down.

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