MS Gaming Commission

Best of the best Q&A Stephens and Shingos. BQX Bible Regulations

Shingo about regulation, [19.08.17 02:40] Regulation is meant to protect consumers. Everyone hates regulation until an unregulated market bites them in the ass. Complying with regulations will also force us to build a robust consumer protection framework which will be beneficial long-term When we enter the U.S. market we want to be extremely prepared and have the technical considerations already built into the platform for the U.S. regulatory landscape. It has always been our plan to get to U.S. as soon as possible from day 1. That was part of the reason we were excited to bring Stephen Corliss on board. US is gold standard of regulation. Being compliant in the US would also necessitate having a solid product.
stephen corliss, [08.09.17 18:47] Don't be afraid of regulations! Yes, some will be written and implemented poorly as legislators never get these things right BUT the most important thing is how much value this industry already generates (income, capex, etc) and the massive potential it delivers to create the next economic wave or revolution. Everything else is just noise!
stephen corliss, [23.08.17 02:14] The SEC isn't the issue really as their position shouldn't have come as a surprise to anyone. I know it did but it really shouldn't have. Regardless, we can help exchanges understand how to manage through this as we know this space inside and out. Now don't shoot me for saying this but the SEC actually is on our side, as long as we show that we are protecting consumers. That is their original mandate but unfortunately they get the bad wrap because the financial industry keeps forcing them to write regulations in response to fraud and bad behavior by financial firms that consistently hurts consumers.
stephen corliss, [16.11.17 01:43] [In reply to EstimatedProphet: What has been your experience when speaking with regulators so far? Many individuals I speak with tend to be very concerned about the SEC and the impending regulation/ restrictions on how we can utilize and or liquify our assets. In your experience, is there much room for concern?] Thank you. I believe the main concern of regulators are those tokens that clearly are violating securities laws. Unfortunately, many of the tokens issued in earlier cycles clearly are or may be securities and will face some headwinds if they don’t self-correct and adjust their models. I believe regulators will allow “utility” tokens to continue with a slight potential for a move in the future involving some sort of a “regulation-lite” solution. From our perspective, we chose to develop our model and platform in a way that embraces regulations by accommodating for them in all of processes, which allows us to operate with minimal disruptions and business risks. More importantly, this approach allows us to service consumer and business customers interested in BOTH crypto and traditional assets thus enabling us to engage newbies on the traditional asset side while slowly introducing them to crypto. I believe this optimizes our customer growth plans as it removes many of the onramp issues we would have in meeting our objective to deliver mass adoption in crypto. Personally, I’m not concerned about regulators in the least as worst case is our industry is pulled into the fold, which has already occurred at some level anyway because of money transmitter regulations.
stephen corliss, [02.10.17 16:13] Now the toxic question, would this get caught up in jurisdictional definitions of a security? My answer, no but only with the right model. Let me expand on this.. First, I'm not going to do all the work for our existing or future competitors so give me some leeway as this is one of many competitive advantages. Yeah, maybe they will figure it out after we launch but by then it won't matter...! First, a security is something that is defined prior to issuance as it sets the legal structure and parameters of the token itself. As most of you know, almost all POS coins define upfront a dividend paying model that in effect sets the legal rights of all coin holders. Without revealing all the reasons why, this is the first big mistake as to sell coins like this to the public, one must first go to their local regulator (company origin) and submit documents to authorize a public sale. Additionally, a firm like this will also have to understand the foreign issuer rules for every jurisdiction their holders reside. Not an easy task let me tell you. Now, small business exemptions exist in most developed economies for capital raised below a certain amount but these almost never involve holders/investors who are not "accredited investors". Out dated rules but nevertheless they exist on the books almost everywhere. Is there a better model? Yes sir ee! What is this model? Ah, why mess around, the functional token with a very specific overlay business model. That's where I will stop but I promise I will reveal more details as we move forward as we do want to ensure new entrants get this right so that all of you don't have to worry about all this legal mumbo jumbo One last point, for those firms like us residing within the financial side of the blockchain industry, the complexity level increases 10x minimum as everything must be assessed versus global rules involving many different types of financial business types, products or services. It is a painstaking process but if this is where you choose to hang your hat, you best know all of the ins and outs and, no offense to all my lawyer friends, you best not depend entirely on your law firm as they can only advise you on the facts you present to them. If you present them wrong, which many do even large financial firms, you will find yourself on the end of a major fine and maybe even banned entirely. This last point is huge as what I see when I look out across the competitive landscape are firms who have made very big mistakes in their business models. This will mean they will face severe legal headwinds going forward that when combined with strategic pivots that will have to come, they will be left behind by those of us who got this right.
stephen corliss, [23.08.17 02:24] Hello there! I will stay away from tax authorities opinions but with regards to the SEC it will depend on the behavior of our peers and industry. If the fraud and theft continues, they will have no choice. This is unfortunate as I've worked with many financial products over the years that were "self-regulated" and it works well. Unfortunately, the financial industry messed that up too so now there are basically no self-regulated products. If we don't fix this from within, regulation "around the world" is inevitable.
stephen corliss, [23.08.17 22:22] It is actually quite positive really as this means we are growing up. Sometimes that seems like a bad thing but it truly isn't especially if we want this eco-system to thrive. I love this stuff!! Easy as pie! Everything I've done for the last 25+ years has been regulated whether it was in Europe, Asia or United States so I embrace things like this, just a part of life. This is actually our advantage!
stephen corliss, [23.08.17 22:26] [In reply to Benjamin: stephen nice to hear that! take the time you need to build a good ground for bqx!]
We absolutely will! The most prudent thing we can do for all of you, besides building you a badass platform, is mitigate all the risks so BQX can absolutely flourish. That is what we will do, bank on that!
stephen corliss, [23.08.17 22:33] [In reply to Rawls: This guy knows how the things are supposed to be done. Nice.] Thanks Raul! The more we do up front the more we remove all the unknowns to ensure the platform maintains its superiority. If you mitigate for all risks now then that removes chances of unwanted outside disruptions. We have 100% clarity and a detailed plan to do just that.. Fun stuff!!
stephen corliss, [27.08.17 03:49] I wholeheartedly believe that regulations are inevitable and that regulations are the thing that allows this space to explode. Initially, the immediate reaction would be a very short term negative price reaction (could be a period of hours or several days) before the market realizes that this is just what happens to any product as it matures. Its the maturity of the eco-system that requires it to be regulated, which allows it to move to mass adoption and price explosion driven by massive demand. This is why everything we do here at Bitquence assumes we operate in a regulated environment and thus is embedded in our "immediate" and longterm strategic plans". By doing so, we remove most, if not all, potential future business disruption, unlike most others who will get caught off-guard. Consider the most recent disruption to Exchanges and Exchangers, where most of the industry were negatively effected by the opinions put out by the SEC (US) and MAS (Singapore) regulatory bodies regarding ICO's. What happened in a lot of cases here was that firms operating in these spaces had to hit the pause button while they sought legal advice on how to adapt their business operations and procedures. By planning ahead, one can remove much of these known and unknown variables by building a model that can flourish in such an environment. This is our approach.
stephen corliss, [27.08.17 04:23] Almost all global regulators follow a process that entails first publishing "proposed rules" to the public for comments, 2nd An internal assessment of all commentary received and finally, the issuance of final rules. The entire process averages about 9-15 months. Now, lets assume the first to enter is the SEC in the United States. Not a bad assumption because one of its key National Legal Bodies, NATIONAL CONFERENCE OF COMMISSIONERS ON UNIFORM STATE LAWS, has just approved something called "UNIFORM REGULATION OF VIRTUAL CURRENCY BUSINESSES ACT". This is important as this provides a National Law Framework for each of the States to approve and add to State Laws. With this key piece of law defined, we could assume that others will begin to build off of this. Thus, my best guesstimate for you would be we could see some regulations in early 2019. There are a lot of moving parts here all around the globe so we need to monitor a lot of things across a lot of countries! But, the first mover historically tends to be regulators from the US.
stephen corliss, [03.09.17 05:13] [In reply to catmando: Now the impacts of more regulations. im not sure. Will it slow growth but help promote better products? will regulations dampen much at all? Idk, but im sure by the end of next year the prices of a good handful of these coins will be significantly higher.] Regulations may, if not will, be a major disruption for most of our industry. However, we are building Bitquence to sustain this liquid rule environment by embracing rules and structures that are commonplace with traditional investments. This is one of many differentiators for bitquence over the long term.
stephen corliss, [03.09.17 14:09] [In reply to Bodhisattwa: Does bqx has clarify on it not being a security ?] Hello, BQX is a Functional Token that enables users to access services on the Platform. It is not a Tokenized Security because of the above reason along with the facts that it does NOT carry with it any rights other than "access", like voting, profits, dividends or any other feature common with traditional "shares".
stephen corliss, [03.09.17 15:51] All, We hear you 100%. Let me make one point reference competition. Competition will be and is a healthy thing for any industry as it provides options for consumers while also allowing consumers to choose the better service provider and technology. However, when building a model in an industry such as this one that has to align with a complex financial industry centuries old, most will either fail or miss the mark significantly. What we have right now is a classic "square peg round hole" situation where ONLY those with the necessary technical, business AND industry expertise will win. What I can share here is this, we've done all of the necessary work designing a comprehensive solution that can flourish in a highly fluid business environment, where most others will be confused and distracted. I've set up many financial firms in my life worldwide so this is not unchartered territory and we will do whatever is necessary to ensure BItquence can flourish. FOCUS, BE BOLD, BE FAST, BUILD AND DELIVER, it is as simple as that.
stephen corliss, [03.09.17 22:35] A little more color: "Our list of younger members in our forums is growing because of the mission for mass adoption is resonating with them and a lot of these younger folks need help understanding this complex space." Thus, lets be sure to operate accordingly.
stephen corliss, [04.09.17 23:23] Ben, There are some overlapping parts but many do not. At the end of the day we could simply conclude that a critical differentiating factor is they are more "active" focused and we are focused more on the "passive" end. However, these two investor types and related features do overlap in similar respects but our Universal Wallet feature is unparalleled and is not something they offer. Now, I have a much stronger opinion with detailed specifics of the numerous functionality that separates us but lets keep that to ourselves so we can maintain the advantage over the competition.
stephen corliss, [06.09.17 14:34] Brian, we are a Functional Token and should not be thought of as any type of Tokenised Security as our Tokens represent access to services on the Bitquence Platform. Our Customer Acquisition Strategy is broad in scope and is aligned with our product roadmap to ensure we reach all desirable markets and grow our user base. Exchanges are a critical component of extending our customer reach so anything we do here would be part of our business development efforts, which is a continuous process. Let me remind the community that coins and tokens involve significant volatility and risks and, more importantly, according to our Terms, Token Sale Participants were not submitting Contribution Tokens to obtain BQX for the purpose of speculative investment. Furthermore, market liquidity was not guaranteed and the value of any token could depreciate in full, be highly volatile and inherently risky. With regards to development progress, our Alpha version has been released to the Product Council for review and testing, which will most likely run for a few weeks. Beta will immediately follow for a period and we expect to release the Bitquence Prediction functionality in Q4.
stephen corliss, [14.09.17 04:48] [In reply to John Weston about news: Upcoming changes regarding Canadian users] John, I know of them well. I want to be respectful here so I'm just going to speak big picture rather than speak of any other firm.
First, one must first understand if a token is a Functional Token or Tokenized Security. A Tokenized Security is evident if tokens represent ownership in the company and token owners have rights to vote and participate in company profits/dividends. Tokens facing fact patterns like this are going to be very problematic in a lot of OECD member jurisdictions, including US, Canada, EU, EN, Asia, etc. (Basically all developed and emerging economies). The big issue here would involve the legal hurdles anyone must overcome and adhere to when raising money from the public. If a firm runs a global ICO and it involved a tokenized security, and the firm didn't meet the legal requirements across all regions before issuing, this could be a big problem to overcome.
Secondarily, the business model operated by any Token company must also be assessed to understand if it is involved in securities activities. Again, in most OECD jurisdictions when somebody accepts any type of funds from investors in-kind for a share of something being offered by the Token company, it is quite typical for regulators and courts to find a security because investors are investing capital, in a common enterprise (the tokens firms structure which represents a value to the investor, like a fund for instance) with the expectation of profit (literature claiming returns) from the efforts of others (whether the Token firm itself or a 3rd party who manages the fund). This would be the same for a mutual fund for instance. This situation could be made even more problematic for several reasons, beginning with 1) a companies own Token being classified as a "security", 2) a token firms structure for accepting investors money as part of its business (post ICO) will most likely also be classified as securities, and 3) if neither the token firm or its outside 3rd party service providers were licensed as authorized investment advisors or asset managers, they could face some severe regulatory difficulties. Furthermore, because any transactions involving any of the above would be considered securities, a token firm could also have a fourth issue stemming from the trades they accepted from users, as these could be securities and thus require a broker dealer or brokerage license. I hope this helps but ping me back here or directly if you have any other questions. Sorry, there's a potential 5th issue, if a company such as the above were handling transactions that ultimately were determined to be securities AND that firm executed customer trades (rather than send them to an external exchange), that firm could be found to be a securities Exchange and require those authorities in every region.
stephen corliss, [22.09.17 16:23] [In reply to Ron Mata: good morning . So Jamie Dimon is at it again. He just had another interview where he says government will shut down bitcoin and throw people in jail like china. But from your end it sounds different. You are bullish on this and was approached by china to help transition china. Do you know something Jamie Dimon doesn't know? Do you respect the man?] Remember, not everything is as it appears. To answer you last question first, I would say he is a smart man who is aligning his public comments with current conventional thinking. Meaning, we all know there is a lot of dark money flowing around our industry along with some firms who are committing fraud. With that as the backdrop, he cannot publicly support this industry as he cannot be at odds with the rules that are in place to safeguard the global system. Until we start embracing KYC/AML, nobody in the financial industry or those who regulate it will support it, at least publicly. However, what he is not saying is that because of rules and conventional thinking, he cannot participate in Token-Sales or this broader economy and this is a problem as at some level it impacts his businesses. For instance, it is expected that at least $3billion will pile into Blockchain startups in 2017 and ONLY 25% of this total will come from traditional Venture Capital firms and 75% will come from Token-Sales. The financial industry already struggles with their capacity to put Institutional Investors capital to work in alternative investments strategies. If we are drawing away larger pools of potential venture investment, this leaves them in a bit of a bind as their customers need higher performing assets in their total portfolios. Additionally, if this model continues to flourish, this will have a knock on effect across Private Equity as they will have much less firms to provide later stage funding or acquire, which also means they will have less capacity to put capital to work. This also means that the financial industry loses a bit of control they currently have over typical fintech firms where it is a major source of innovation for them that they typically acquire through acquisitions, which also increases competitive threats to their business that they cannot mitigate. So, what do you do? You speak negatively about this industry for all of the above reasons. I haven't even touched on the larger issues about how an industry left unmanaged or unchecked could lead to systemic failures. This is the bigger issue that I think none of us are really talking about as we cannot simply change the way capital markets work without carefully and respectfully thinking about its impact on the system as a whole. This is what regulators and central banks must, and are, thinking very carefully about, which is why I believe every national economy will begin to shift towards our model and force us all to play by the rules. (which is exactly what China is doing). In essence, a lot of this noise at some level is intended to scare the dark money out of this space, which I actually believe is working. Not a bad thing for those of us who are legitimate, both consumers and businesses. Respect? Not sure as I prefer transparency and this is very rarely what you get from leaders.
stephen corliss, [24.09.17 17:27] [In reply to CB: hi mate, are you guys concerned about Change Bank??] All, let me give a bit more thought on my Change Bank comments. Although we think about competitors, my biggest concerns are almost always driven by a single question, which is "Can a token be part of the population of tokens available to our customers in their baskets?". This is important as a token can only be included in the Basket Service if it passes a few tests. 1) Is it legitimate and 2) Would adding it expose Bitquence to serious legal, financial and reputational risk? This 2nd question is absolutely critical as we only need to look to the DAO and to discover how 1 firm's mistake can expose the entire industry. Why does this matter to Platform users? Because the business risks associated with any Token you hold are correlated 1:1 with the firm sponsoring the token so if they face serious legal/regulatory headwinds, and fines, this could drive the value of their token to zero leaving token holders with a worthless token and no service to use it with. Since our mission is to provide tech and services to our users that helps them build wealth and make prudent decisions, Bitquence will need to do whatever it takes to provide them with critical information through our Token Rating System to help you mitigate or manage risks.
stephen corliss, [25.09.17 12:33] [In reply to Dean Jaman: stephen with all the news coming out of China, I read an article that speculates China is working on placing a proportion of their currency on the blockchain, to be able to offer liquidity to its people and moreover the world. It would essentially function as Tether USDT. Can you shed some light on this theory?] Hi Dean, Moving some of a countries monetary system on to a DLT based structure makes sense but it has its challenges as understanding the impact on existing lending, credit and other macroeconomic factors will be quite difficult. However, we know China believes and invests in the technology. Purely from an economic perspective, being first in this space has tremendous potential advantages on future economic activities. If governments believe in the technology, why would they not invest in the innovation to secure a leading position in the field, generate employment and investment , etc. Personally, I know China is investing in the technology and I know the US is doing the same but to a lesser extent. However, indirectly, the US through its Venture Capital Sector is investing a growing amount of capital in DLT. I also know through some initiatives I've been involved with that the US is intently focused on how to use DLT to tackle the unbanked and underbanked, internationally. So, with all that said, I know governments see the potential benefits of this innovation and that this will have a positive impact on our efforts to move towards mass adoption. Is China actually looking to move a small share of the monetary base on chain? No idea but the fact pattern does seem to support such a move but only if they can truly understand the implications of doing so (macroeconomic factors). Plausible for sure. However, we all do need to understand how very complicated such a shift would/will be and how dangerous it could be if a central bank got it wrong. Baby steps is the only possible approach, which will require us to be very patient as this will be extremely complex and take decades to occur, if it ever does.
stephen corliss, [25.09.17 21:45] [In reply to Greg: Thanks for video and explenation of TCF. So coins from all categories will be on the platform? Will you be able to add "tokenized security" coins to portfolio without colision with the law?] Tokenized Securities can be either those that are "registered" by Issuers with National Regulatory Bodies or those that are not, whether knowingly or not. The latter example, cannot be traded on any platform whatsoever whether the platform itself is regulated or not because the Issuer has not registered their tokens. If it is, then all of the firms involved in a transaction like this could be in violation of certain rules and subject to fines.
The former, Or registered Tokenized Securities, can be transacted on a Platform but only if the platform itself is structured appropriately. What I mean by this is that unless a Platform is structured correctly, registered Tokenized Securities can only involve other regulated entities such as a licensed Broker, Exchange or Advisor depending on ones role in the process.
stephen corliss, [02.10.17 12:53] [In reply to Greg: If team figure out how to deal with asian regulators it will be a big step ahead.] Been working with Asian regulators for years so this is covered!
stephen corliss, [14.10.17 23:57] [In reply to EstimatedProphet: I think these individuals deal with government regulation all the time. They have a much more realistic perspective on how the government might come down on it. I think Stephen disagrees but I may be wrong.] Most leaders don’t really understand regulations and investment law and this is typically a conscious decision. Many of the leaders I know or have met over the years actually have very little knowledge about the rules involving global finance and almost none of them understand market structures and there inner mechanics. Knowledge is something you desire for yourself, or if you don’t have this desire you mostly rely on others. Unfortunately most opt for the latter and this is how most companies operate nowadays. Its a personal choice, simple as that. What leaders unfortunately do have is the ability to apply leverage over policy. This is what I worry about and develop strategies to protect against.
Shingo, [23.10.17 01:53] [In reply to Harshad Thakar: Do you think that the way you guys are developing the "upper layer" that might involve such crypto stuff, it will be subject to incremental scrutiny by these countries?] This is more of a @BQXStephen question, but I think that this is an area that the law hasn't fully caught up to the technology. When you send funds to an address, it is just that. The address doesn't "reside" anywhere. You could look at who owns the private key and where they reside, but it can often be unclear and unenforceable. I think the best solution that any crypto company can do is operate ethically and under the auspices of reputable regulators. For services that can clearly be tied to a jurisdiction (fiat transfers etc.) then you restrict based on location of origin.
Stephen: Thanks Harshad. Shingo is absolutely right. I want to tread carefully here but without exposing our strategic model too much, the problem our industry faces is that our default strategy is to run “from” regulation rather than to it. By taking such an approach, our industry sends signals to those whose mandate is to protect consumers that we don’t care or respect rules or that we have something to hide. That position, stance or strategic approach, is fundamentally flawed in our view and we believe there is a better approach that allows a firm to minimize obstacles rather than create new and additional ones.
Shingo, [04.11.17 17:33]* I think blockchain has the ability for us to rethink the global financial system from the ground up. Financial firms tend to do a lot of abstraction: securities, funds, etc. in order to make the system more efficient. The entire system we have now can be made more transparent, ethical and accessible through blockchain. That is really the holy grail of blockchain technology
stephen corliss, [06.11.17 03:36] Questions From User (Oscar) In Response To The Securities Question From Earlier 1.) Does BQX consider people holding BQX currently as investors or gamblers betting on a "utility token"? This is important... From a fundamental standpoint, why should we hold bqx if it does not consider us investors, offer returns, offer voting, etc? Why hold a measely utility token if its only use is for powering an app? Doesnt bode well for the long term.
2.) Are you considering selling/converting bqx for stock/stoken at some point? Perhaps some % share in fees etc? I think if bqx could incorportlate a way to incentivise $$ people to hold and buy more, they could use this opportunity to gain more popularity and lead the way. Telling people who very much consider this an investment that they are "thinking wrong" makes it sound like bqx has very little value.
3.) What happens if the sec labels BQX a security?
This is key... Lots of people are backing a project and you are right they are not being promised ownership or voting rights - and you say the problem is how people think of utility tokens - yeah we handed you 40 million to "just" play on your app... that does not make me want to hold BQX.
You guys may want to find a better incentive than "using the platform," to encourage long term holding and building value or further investment. Im sure all coins will have to deal with this Indeed, but we all know how to use a VPN, and a coin offering a return or stake in the comoany is a lot more valuable than one that does not. This could really help or hurt BQX.”
My Response:
  1. Your Question: Does BQX consider people holding BQX currently as investors or gamblers betting on a "utility token"? My Answer: Neither. We see token holders as members, supporters and customers who have purchased tokens necessary to access and use products and services they desire and deem essential and critical with regards to financial services. I liken this to a cooperative where those with shared interests came together to solve shared problems to improve outcomes for all members.
  2. Your Question: Why should we hold bqx if it does not consider us investors, offer returns, offer voting, etc? My Answer: Customers should hold BQX because they believe it has value to them personally AND that others will also believe it has value, and thus purchasing the token and holding it could serve 2 benefits, 1) It allows holders to lock in their cost to access the system at a lower cost while 2) potentially selling some of their lower cost tokens to others in the future at a higher price because of increased demand by new customers / users
  3. Your Question; Why hold a measely utility token if its only use is for powering an app? My Answer: In conjunction with the potential benefits in #2, the utility provided to customers can also replace services available today at a lower cost, allowing customers to pocket cost savings. Additionally, depending on the product or service, benefits can come in the form of better outcomes that could take the form of increased returns and decreased risks. There are numerous others but lets leave it there for now.
  4. Your Question: Are you considering selling/converting bqx for stock/stoken at some point? My Answer: We have not furthered our thoughts on this with an actual strategic plan, as of yet, but if customers would benefit we wouldn’t hesitate. However, this may be the end result anyway when regulators mature their thinking, which is also why we would consider making such a transition anyway in order to remove any unknowns or uncertainties and allow us to operate with minimal distractions.
  5. Your Question: Perhaps some % share in fees etc? I think if bqx could incorportlate a way to incentivise $$ people to hold and buy more, they could use this opportunity to gain more popularity and lead the way. My Answer: Absolutely.
  6. Your Comment - Telling people who very much consider this an investment that they are "thinking wrong" makes it sound like bqx has very little value. My Response: I didn’t say people were thinking wrong, what I said was even though some firms are not issuing tokenized securities, the mentality of holders is identical, which may create a regulatory “problem” with regards to the legal structure of functional / utility tokens. This is important from the perspective of regulators because of their consumer protection mandates. As such, whether something is a utility token or not may not matter at the end of the day as regulators will protect the public when they see the need. Personally, I believe this review will be necessary as we all know predators and fraudsters are out there.
  7. Your Question: What happens if the sec labels BQX a security? My Answer: First, we didn’t offer tokens during our Token Sale to US residents and Secondary offerings made subsequent to our token sale are not made between the company and customer but rather customer:customer. However, as mentioned, we think and plan for all variables so any such determination would have limited impact as we’ve done a ton of work to mitigate risks such as these.
  8. Your Comment: This is key... Lots of people are backing a project and you are right they are not being promised ownership or voting rights - and you say the problem is how people think of utility tokens - yeah we handed you 40 million to "just" play on your app... that does not make me want to hold BQX. My Response: First of all, the 40m number doesn’t apply to BQX so lets make sure that is clear. Please read everything I post and comment on very carefully as I believe you are using my comments out of context. This disconnect is not a pro blem for me but rather a problem with respect to current laws and opinions, which presents a gap that courts will need to close so everyone has the clarity they need.
  9. Your Comment: You guys may want to find a better incentive than "using the platform," to encourage long term holding and building value or further investment. Im sure all coins will have to deal with this Indeed, but we all know how to use a VPN, and a coin offering a return or stake in the comoany is a lot more valuable than one that does not. This could really help or hurt BQX. My Response: I’m feeling like you misunderstand how we think of our customers. We don’t believe the only incentive we offer customers is “using the platform”. The token provides access to countless benefits both from products and services AND the benefits listed above under #2 and #3 Bitquence will be the currency that enables new projects, products and services to launch within a new global financial eco-system. So, yes there are differences but a lot of similarities as well.
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These are wagered using betting pools where 75% of the prize pool is returned to gamblers using a totalisator (tote-board) system. Age Limit and Taxes on Public Sport Unlike lottery which is exempt, income tax can also be owed on returns from racing tote. (4) Pools betting, lotteries, gaming and casino taxes; (5) Road taxes; (6) Business premises registration and renewal levy; - urban areas (as defined by each state): maximum of N 10,000 for registration and N5 ,000 for the renewal per annum - rural areas - registration N2,000 per annum - renewal N 1,000 per annum (9) “Exotic pools” means wagering pools, other than the traditional win, place, or show (1st, 2nd, or 3rd place) pools, into which a contributor can place a wager on more than one entry or on more than one race or game in the same bet and which includes, but is not limited to, daily doubles, perfectas, quinielas, quiniela daily doubles, exactas, trifectas, and Big Q pools. taxes such as value added tax (VAT) and withholding tax (WHT) (charged by the Federal and State authorities) on winnings, payments made to foreign partners, etc. Global trends has shown that sports betting if clearly regulated, is a major sector for the generation of tax revenue by the government. This has however not been the case in The Lagos State Lotteries Board (LSLB) is the pioneer gaming regulatory body in the Nigeria. It is responsible for regulating lotteries, sports betting, scratch card & interactive games, casino, gaming machines operations, pools betting, promotional competitions and other gaming activities within Lagos State.

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