It's been a very active week as many of us turn to WhyDRS with increasing fervor. From what I've seen, that means more time, effort, and thought put into our next steps. There's a long road ahead, as we've all discovered these past few years imo. Incredible to think how much we can all accomplish together.

I'm trying out this new format as a way to efficiently respond to interesting recent thoughts. Let me know what you think per attempts to streamline involvement. It seems I've been missing material discussions with my existing approach of some quick time each week to glance over main insights.

This kind of work is a(n unpaid) full time job. I dont expect anyone to stay up on all of it all the time unless they’re deeply entrenched in the day to day.

— wtfeweguys

Hopefully this new format will help organize otherwise disparate thoughts in a central place. All around, I appreciate community members who help organize new information by mentioning me when relevant. Your DMs, timely references, and public conversations mean a lot and help organize pending thoughts.

Background

Relevant to this new discussion medium is the evolving structure of Discord conversations. Half of the chat links above come from a private "internal team" server rather than the public Discord. Moreover, (future) community members frequently discuss important web3 governance topics across the web.

As some community members have voiced these last couple weeks, much of our work can feel like shouting into a black hole. As someone with twice as many YouTube videos than subscribers, I'm right there with you. Ideally, more sharable documentation like this will help spread our important messages at scale. While we've been diligently promoting our ideals, this next chapter of newfound organization might renew our passion, direction, and influence.

I won't pretend to know exactly where all this goes. That's for all of us to decide in concert. But we had a great start with our conversation last week on Taking Stock and in the biweekly internal dialogue thereafter. And hopefully these responses promote a permissionless, transparent, and direct governance system that's easy for anyone to reference, search, and chat around.

1. Regulation of Transfer Agent "Plan" Services

Firstly, we've been talking about important nuances in DSPP and other Plan custody schemes for months. I'd like to draw attention to the legal plan definition and SEC thoughts on their regulation:

Transfer Agents [with plans] all provide some level of transaction execution and order routing services.

Netting is a function commonly performed by clearing agencies and may also be performed by broker-dealers for customers holding in street name, but is not among the core functions enumerated in Exchange Act Section 3(a)(25) performed by registered transfer agents. Hence, netting and other execution services may not themselves implicate transfer agent requirements, but nonetheless may trigger broker-dealer regulatory requirements.

"Effecting securities transactions" includes, among other things, identifying potential purchasers of securities, soliciting securities transactions, routing or matching orders, handling customer funds or securities, and preparing and sending transaction confirmations (other than on behalf of a broker-dealer that executes the trades).

Receiving transaction-based compensation may also indicate that a person is effecting securities transactions for the account of other.

The Commission has brought enforcement actions against transfer agents operating as broker-dealers without registering as such with the Commission. For example, the Commission found that a transfer agent was acting as an unregistered broker-dealer in violation of Exchange Act Section 15(a) when it, among other things: opened accounts for individual retirement account ("IRA") customers

Furthermore, a transfer agent that effects securities transactions for investors in connection with administering certain types of Issuer Plans may be engaging in broker activity.

— SEC File No. S7-27-15

Relevantly, the most recent staff guidance on what transfer agents can and can't do in terms of direct trading involvement boil down to a handful of no-action letters issued largely before the turn of the century. It's been very difficult to revisit the topic given the advent of blockchain technology. This is why I think transfer agent regulations have sat on the SEC's docket for nearly a decade after the release referenced. ⌛

This is not an easy question as it requires a complete rethink of the origination and processing of transactions from the basis of shares in your own name. For instance, we've discussed historic services providing direct market access at length over over the past two months. Much of this conversation ultimately comes down to the crux of our problems: the DTCC as a monopoly marketplace. And this particularly starts to matter given their de-facto regulatory role—which may or may not be constitutional.

All this is part of why governance matters so much to TAD3. When you can directly trade without middlemen, the line starts to blur on exactly a transfer agent can and can't do. And I think the best people to define that boundary are investors themselves officially or directly.

2. Blockchain and Direct ETFs

DRS doesn't solve the ETF problems.

ETFs can still create and redeem without the asset being available. That's the problem.

Even if we DRS Book the whole float, ETFs will still trade with GME in them, legally too.

— Born Luckiest

I'm not entirely sure what you mean in terms of the legacy ETFs still trading with GME since if we DRS all the shares than in theory those holding companies should have to get their shares from a directly-registered source. So in that case it seems you would just be pushing institutional adoption of direct holding, which could of course lead to outflows from DRS. There's some nuance there, and I'd like to talk more about some other corner cases community members had about TAD3 on a Taking Stock AMA sometime. The implications may be hidden or third-order, but I think the details matter.

Stocks on chain fundamentally reimagine how we engage with ETFs, introducing a level of granularity in ownership that traditional methods simply can’t match. Picture an ETF not as a bundled package sold under a single ticker, but as a direct, real-time portfolio of individual assets on a blockchain. This vision allows investors to own and trade fractions of the actual assets within an ETF without intermediaries or the need for bundled products.

2.1 Elimination of Management Fees​

In traditional ETFs, management fees are charged to cover the costs of managing and operating the fund. However, with direct ETFs on the blockchain, each asset can be bought and sold individually without the need for a fund manager. This setup removes the management fees typically associated with ETFs, as investors manage their investments directly through their digital wallets, interacting with the market on a peer-to-peer basis.

2.2 No Premiums or Discounts​

Traditional ETFs can trade at values that deviate from the net asset value of their underlying assets, either at a premium or a discount, influenced by market dynamics and liquidity concerns. With blockchain-based direct ETFs, investors purchase tokens that represent actual ownership of the underlying assets. This direct linkage ensures that the trading price of these tokens is aligned with the real-time value of the assets, not affected by the speculative pricing often seen in traditional ETF markets.

2.3 Personalized Rebalancing​

Blockchain facilitates a high degree of control over investment portfolios. Investors can adjust their asset holdings in real-time to align with personal financial strategies and goals, without waiting for the ETF provider to make quarterly or annual adjustments. This control allows for dynamic portfolio management, enabling investors to respond quickly to market changes or shifts in their investment outlook.

3. Ongoing DAO Organization

[nonprofit advocacy organizations] don't exist yet, the structure only becomes legally possible on 7/1/2024, so I couldn't point you to an official one that is legally recognized.

— LastResortFriend

We've discussed the importance and material implications of building a distributed governance structure for the ape movement behind closed doors for a while now. I believe this is the materialization of a true market reform in the making. Namely, this community is one of the first groups I've heard of working with a pure intention to create a better public system for everyone to manage their assets. As a nonprofit should be:

there’s no distributed ownership/economics element to it. I’m pointing out there’s no ownership/economics to it at all.

— wtfeweguys

3.1 Documenting Journey​

Starting as a loosely organized advocacy group on Reddit, our community has grown into a more structured ensemble on Discord, allowing for deeper and more focused discussions. This transition was not just about changing platforms but about evolving our methods of engagement and decision-making to better suit our growing needs and objectives. The community has successfully organized with major innovations from finding good meeting times across time zones to facilitating bulk distributed work on a quality centralized database.

3.2 Open Source Development​

Recognizing the need for a collaborative and transparent development environment, we may consider turning to GitHub. This platform allows us to not only host and review code but also to manage specific TAD3 projects and documentation effectively. It's here that we can begun building the components of an open-source securities trading and settlement ecosystem, leveraging the collective expertise and enthusiasm of our community.

3.3 Universe Panel Sharing​

To further our understanding and refine our approach, might we consider hosting a panel discussions that brings together experts from our community. These discussions could prove invaluable for sharing knowledge, challenging our assumptions, and drawing lessons from our DAO successes and setbacks. It's essential to document our progress through detailed roadmaps and public events imo. These deliverables serve not just as planning tools but also as historical records of our journey. They help new members understand our evolution and ensure that our goals are aligned and clear.

4. Figurehead of Sorts

No one is comfortable being that central leader, so the roadmap and structure fill the role enough for a few people to pass it around.

— LastResortFriend

I believe there are some material risks in leading this movement given the vested interests, bad actors, and material disruption TAD3 or a similar system introduces. Ideally, Block Transfer itself can field most of any legal challenges that arise from disrupting Wall Street.

In terms of a speaking head in public, I'd be happy to throw myself in the ring. The GitHub event could be a good starting point. I'm more than happy to put more time into content like this if it's materially sustainable. It ultimately comes down to what the broader community wants in terms of speaking for yourself v. having a reliable representative ready to promote necessary ideological advancements.

What we're building is more than just software, recordkeeping, or business services. It's a fundamental rethink of capitalism that's that "nail in the coffin" of Wall Street complementing the "hammer" of effective advocacy. In my view, that also means a complete rethink of system governance to enable a longstanding replacement piece of public infrastructure.

5. Proxy Voting Email Manipulation

Per our official writeup:

Undetected suppression is difficult and probably reserved for higher ups. It seems too deliberate to be accident

— 6days1week

Firstly, exceptional efforts bringing this to light on X through detailed posts. Tremendous job getting primary sources collected and disseminated exposing potential ulterior motives driving profit interests above effective governance. While the regulations around traditional paper systems v. online communications are thorough, this kind of deceit is unfortunately not yet illegal per any mailing codifications.

Having designed our email notification system for proxy distribution, I agree that this is highly unusual. As shown with virtually all other companies, these emails are supposed to be standard variable changes and nothing more. It's almost always the exact same format with merged fields for every other stock. The only reason in my view for this kind of tomfoolery is that they are hiding something.

Per recent inquiries on other transfer agents, I'll reiterate that I don't like to speak poorly of legacy agents since the true enemy here is the DTCC per Taking Stock #16. Rather, might we all just collectively develop and standardized system and take first action as the inaugural Transfer Agent Depository?

6. Private v. Public Markets

Would be nice to find a continuously updated list of companies that aren't public anymore (due to going private, acquisition, merger, or bankruptcy) but I didn't see anything like this

— gorillionaire2

Hopefully the issuers.info API solves many of these challenges. But I'd like to call into question what exactly we mean with public v. private. The application legally here has to do with primary offerings and specifically what kinds of investors a company can sell stock to. But that's not the whole picture in an ongoing efficient market system like TAD3.

Namely, the system is built to enable anyone to trade after statutory limitations around holding periods. In English, that means anyone can sell their shares to anyone else after a year or less, in America at least. The trading itself as referenced earlier via the SDEX per open protocols thus enables widespread trading whether or not a company is "public."

6.1 Public - What Does it Mean?​

From the perview of the SEC, a public company means an EDGAR filer subject to Section 12 or 15(d) of the Securities Exchange Act of 1934. While that might sound technical, it is just the same set of reporting standards you're used to seeing around quarterly and annual reports. And the regulations themselves have statutory thresholds for when you must start filing documents, such as reaching over 2000 investors. Interestingly, our regulations themselves have little to say about any statutory requirement to have securities trading through intermediaries themselves.

6.2 Private - Can You Still Trade?​

For instance, consider that I have a private company, MonerAds. I sell you some shares, which become tradable in a year under Rule 144. Now you sign a contract with Joe Public transferring the stock in exchange for $X cash. This private transaction, valid under basic anti-fraud law, creates a small market for my private company's stock, even though I never met with or offered securities to Joe Public. And now that Joe has unrestricted shares, he can sell to whomever he wants, and so on.

6.3 TAD3 - Blurring the Lines​

All the assets Block Transfer acts as agent for can trade along these lines, on the basis of quality widespread transparent public information. The overall accounting system, built on Stellar, is the same fundamental technology for all underlying assets, peers, and jurisdictions. Our central role comes in just to manage the ongoing nuances of international compliance, primary placements, and protective regimes. So, when the difference between private and public is simply who the company can sell stock to, do widespread direct investor markets inherently place all companies on the same playing ground of direct capitalism?

7. Real World Demonstrations

[community member] wants more boots on the ground work, and honestly I'm fine with him being a team leader on stuff like that. It's not what I do, it's what some others are interested in, but don't have experience in where to start. I think part of the issue is most of us in this discord are researchers and makers... I've always seen this group as various departments with team leaders, but never one central leader... I think getting the 501c going will help bring in funding, which we need for the advocacy efforts. And the DAO is the most reflective way of how we operate.

— Bibic Jr

Not sure if demonstrations is the right word here, since it seems a lot of our work is slowly undoing very nuanced legal frameworks designed to put the money of the masses in the pockets of a few Wall Street insiders. But aside from that, if we want to do more live demonstrations, I'd also be happy to help and rally support using any means available. I love that the SEC does remote virtual meetings, allowing more diverse perspectives from community members that might have neither the time, resources, nor inclination to travel to D.C. like traditional lobbyists for instance.

8. Selling Our Ideas

I think everyone here understands the value of marketing.

— 6days1week

As I disused privately with Chives here, I've also been down the marketing hole with my first blockchain startup, various online courses, and stock investing book. It is a lot of work, and hopefully the new DAO structure will help us adequately attract and nurture top media talent. I'd be happy to dedicate more time on it if reasonably feasible.

9. Potential DWAC Integration

This all sounds fantastic to me. The only note I'd push back on is DRSing shares being a way to earn tokens. This could be something that bad actors abuse by DRSing their own companies, not to mention hard to prove without a trusted individual going to see the stockholder lists to verify.

— Bibic Jr

If Block Transfer is the transfer agent for issuers in question, then we could track incoming DRS transfers and issue corresponding governance tokens in real time. It's trivial to check if someone is an insider, put safeguards around that, and only reward someone's first direct registration. Even if we only observed TAD3 data as an impartial network peer, we can trustlessly achieve the same outcome depending on the insider identification scheme, which is an ongoing area of development per SEC Rule 15c2-11(b)(5)(i)(P) and this post.

10. Local Transfer Restrictions

I believe this is a list of the cities you can transfer certificates from one person to another. I hadn’t seen a list like this before.

— 6days1week

These geographical restrictions appear to be an outdated and unusual practice that does not align with modern regulatory frameworks or the global nature of today's securities markets. Under current SEC regulations, notably Rule 17Ad-15, there are no stipulations that should restrict the transfer of securities based on geographic location within the United States or internationally, unless specific sanctions or legal considerations apply.

These limitations may stem from legacy practices or misunderstandings of the regulations, which are increasingly incompatible with the principles of open and accessible markets. The goal of securities regulations is to ensure fair, efficient, and transparent markets, not to impose unnecessary barriers to ownership. Such restrictions are inhibitive, disenfranchising investors based on their location, which contradicts the global trend towards more inclusive financial participation.

Given the global desire to own American securities and the widespread use of digital and blockchain technologies that transcend physical borders, any practice that limits investor participation geographically should be rigorously questioned and reevaluated. A consortium of national securities regulators, alongside the investing public as a whole, need to clarify these issues and align practices with the principles of modern, inclusive, and efficient markets.

11. Issuer's Master Tabulator Nuances

Brokers as I understand it, just send voting forms to EVERYONE who has any holding of the stock on the record date. I believe there's two reasons for this; Firstly the voting data they pass to the share issuing company... is just an approximated aggregate of the voting opinion for their shareholders with weighting based upon each clients shareholding. Secondly, it aids to keep up the public facing illusion that a fractional actually 'exists' in the stock trading world and they are not just cashflow and lubricant for the order pipeline.

— Born Luckiest

This extends the broker implications from #1 and the SEC's historic leniency on Plans, as discussed. Relevantly, companies can choose their agent or another tabulation monopoly to manage and inspect the vote per discussion thereto. The implication from the EDGAR link there falls onto Delaware courts, where everyone operates from. When they rule the partial shares valid under the standard pretense of property rights, then the voting implications expand greatly depending on how honest your outsourced master and book tabulator decides to act, given no meaningful regulation over "black box" voting results. I don't see a way to fix this without completely digital votes.

Environmental impacts

12. Certain Broker's 3% Cash Back Card

Just so we're all on the same page, credit card fees are 2–3%. The card companies, interestingly, were originally nonprofits charging lower rates. But their "public utility status" ultimately gave way to rent-seeking profiteers that controlled the stock. When retailers tried to add this as a line item on bills in the early 2000s, these companies pushed back and convinced them to add cash prices as a "discount." Apparently calling the payment system what it is—an added cost baked into good prices—was too harmful to their money-printing business model.

All this to say that issuing banks like Coastal Community Bank in this case get ~2% of transaction volumes back in revenue split with the card companies. The extra money paid chiefly comes from the fees you pay each month for a "special account." Coinbase had a similar promotion like this briefly after their IPO where you got 5% back on all debit card purchases in Stellar Lumens. Unfortunately, take rates are about half as much on debit cards, making this program even more expensive to finance. In fact, my account's card was deactivated after extensive use, and they have much lower reward rates today.

All this to say that the program in question also leads to a fundamental conversation about our financial system. I personally love the consumer protections, cash back, and other perks credit cards offer. But are these benefits, when considered across society, worth the underlying costs of a transaction tax not recouped by uncreditworthy everyday purchasers, staggering amounts of enslaving debt, and ongoing oil-based plastic producing global pollutants?

13. Ken Griffin Interview Comments

Take a close look at JP Morgans recent annual report and 10K under legal actions, the OCC and FED's action against them and pending DOJ outcome. They have been facilatating quite a bit of offshore trading for over a decade. I would presume, most of the prime brokers have been involved in the same unsupervised trading. — bellweirboy

This comment was made in response to an interview where Ken seems to be using a teleprompter. I'd like to talk a little more about the routing implications per this prerequisite context.

My perspective comes from having actively traded based on dark pool and offshore volume, including building an AI model around it before GPT3. Hopefully, upcoming legislation will finally fix all these problems. Moreover, much of these challenges were detailed in Flash Boys, inter alia.

All this to say, I think there is a lot more going on here that gets swept under the bridge of public oversight because of the fragmented global securities trading regulatory regimes. Ideally, blockchain solves all this with a simple, transparent, immutable record of market transactions. We will prevail so long as we continually fight to decentralize securities trading and settlement, disintermediate global capital markets, and definitively open-source Wall Street.

Closing Thoughts

I am really excited for CAT - I do think we'll see if they are able to delay the 5/31 start. There are two lawsuits filed against the SEC that essentially claim the new market surveillance tool violates constitutional privacy rights.

— Chives

This isn't a lighthearted question in light of recent action against CZ (and that's after a $4bln fine). Most transfer agents today have wholly inadequate AML/KYC programs when compared to the excessive scrutiny expected from cryptocurrency exchanges. Since they were traditionally banks, I guess politicians just decided at some point that SEC-regulated transfer agents didn't need specific laws promoting America's policy agendas.

Given the material privacy concerns over web3, we should continually quander and ultimately outline a global approach to inclusive financial market access. Yet another material governance consideration that I believe should come from investors themselves by means of the democratically-elected officials we have the direct power to support in alignment with our views.

Looking Forward Together​

Take the idea of market literacy a step further. What do we as a group generally mean by that? What have we learned by becoming more market-literate? What problems/concerns have we surfaced? What do we feel can be done about those concerns?

— wtfeweguys

We have a lot to uncover together, and I'd love to have more community members on Main Street Markets to further document their investment background. I firmly believe we can make better decisions in consideration of all known factors by understanding the background of our community members themselves. In a perfect world, that means we can best define the full scope and longstanding implications a fundamental rethink of how capitalism works.

W/o any competitive pressure computershare will probably not change a thing

— beyond-mythos

Wholeheartedly agree on this point, which is why I believe we have so much potential to shake up the industry. Consider the worst case where our step function innovation and collaboration acts as a potential "competitor" to the legacy system. What's the worst that could happen aside from forcing more innovation, transparency, and automation? By addressing the larger narrative of ownership and control within financial systems, we can begin to forge pathways towards a more equitable and transparent market built for the 99%. This is not just about exposing Wall Street; it’s about establishing a new norm for financial interactions that prioritizes equality, accessibility, and accountability.

OCC Margin Comment Letter​

There are so many problems in our markets, and I can't think of any other community better suited to tack them. In the coming week, in as much time as I can find while packing up to move, I'll be working on a detailed comment letter per recent news.

Given the monopolization of securities trading and settlement, I believe we can convince regulators to extending FOIA access to non-governmental entities, just as they did with FTD data in the 2000s. These systemically important financial institutions have virtually no threat of competition given the impossibility of replacing their systems with anything outside of blockchain, which obviates the need for any such middlemen entirely.

Given that this is the main reason requests have historically been denied for financial SROs, the unbelievable lack of transparency in this rule might just be the straw that breaks the camel's back given the risk of options clearing amidst high volatility.

the opportunity is ripe isn't it

— Born Luckiest

Isolated Community Discussions​

I believe in information transparency, at least for movements like this, where we aren't working on something related to national security. I understand that the original private server exists so that top contributors can communicate in confidence and outside the risk of being misquoted out of context. Please let me know if responding to quotes in a more public and pseudonymous manner like this steps inside the boundaries intended by having two separate Discords. Ideally, we can get everything material into the hands of comprehensive public oversight, save for spam risk. Minds together stronger?

Whether we like it or not, the government knows a lot about us. They know when and where you fly. They theoretically know how much you earn, the stability of that income, and where it comes from. They know what kind of car you drive, how many traffic tickets you’ve racked up, and of course where you live (at least unless it’s in a separate entity). And that’s not even mentioning Snowden.

This isn’t a post about government oversight, but the topic seems particularly relevant. More specifically, by the end of this post, you’ll understand my nuanced view of how we (do and) should regulate newfound digital assets. The biggest question in my mind comes down to information distribution. Consider a currency like US dollars. There are only a handful of people that know anything material about USD value at any given time. They all work at high levels of the private profit-sharing Federal Reserve.

Considering almost the whole world uses dollars, we can safely say only ~0.0000001% of the population have insider knowledge about USD value. (Currencies trade against each other.) And of course all these people presumably have tight informational and trading restrictions imposed on them by the government. Almost like corporate insider investing or trading rules.

Now consider Bitcoin, the only digital asset presently classified by our government as a commodity. Almost from day one (compared to other blockchain networks), Bitcoin had no insiders. Certainly, Nakamoto was influential in committing original code, ideas, and limits. But, after ghosting the industry, the pseudonymous contributor disappeared from society.

Early Bitcoin Days​

In the beginning, I think there is a real argument that Nakamoto was an insider out of the few hundred early Bitcoin adopters. Namely, Nakamoto was a driving force in building out new network infrastructure themself. They were effectively releasing a new product and then letting others claim their own stake vis-a-vi mining.

A series of dot-com companies gave away free stock early on, in a similar spirit of fostering user adoption, increasing total investors, and gaining beneficial publicity. The SEC ultimately ruled these giveaway offerings as illegal securities law violations. And I think Bitcoin would have faced a similar outcome early on if meaningfully brought into courts before 2013.

Could the government have shut it down? Certainly not. But we might at least have better case law to reference today than the nuanced and intricate Ripple ruling with qualified purchasers. However, relevant to this discussion, very quickly after Nakamoto disappeared, Bitcoin effectively became a living thing.

While control of certain web2 functions was handed off to another active developer, the actual Bitcoin blockchain was off to the races with an independent, completely decentralized, and self-incentivizing system. A radical innovation that ultimately lead an self-organizing community of open-source developers to continually improve upon Nakamoto’s revelation.

Over a decade and a half later, regulators, investors, and users alike agree that nobody has any inside knowledge of Bitcoin’s next steps. Everything from code, mining software, and wallet implementations are open-source for everyone to see. Therefore there arguably exists no insider knowledge across digital assets (and therefore no need to regulate many cryptosystems for investor protections, like with commodities disclosures).

Corporate Securities​

Let’s talk more about digital assets in the comments. I think Ethereum’s number of insiders falls between that of Bitcoin and the Bank of England. Still extremely low, and not something any regulated broker would impose insider trading disclosures around, aside from PEP checks.

Insider trading laws have a relatively interesting history, which warrants a scholarly introduction:

Our Current Rules Evolved from State to Federal Law​

Warren Earl Burger was one of the longest-serving Chief Justices in the US Supreme Court, known for his extensive experience in securities cases. Around 1980, the Court debated a series of cases questioning Federal oversight of stock lending. In Santa Fe Industries, Inc. v. Green, the Court had to decide whether to invoke Rule 10b-5 to protect investors in a case about a public company going private. In question: whether anti-fraud provisions applied to an allegedly undervalued "coerced" valuation from a major investment bank? More thoughts.

The Court ruled that anti-fraud procedures in Delaware law applied over Rule 10b-5. This was a common theme throughout Bankers Trust v. Mallis, Rubin v. United States, and other cases. The Court explicitly tried to delegate investor protection power down to States. That was until United States v. Naftalin—a 1979 case about failures to deliver.

Big brokers were on the hook for this loss, so the Court exerted Rule 10b-5 to protect them. Based largely on Burger being absent in a surgery, it was arguably a scandalous, rushed ruling. The ruling has profound implications on our current securities regulation regime. And Congress hasn’t questioned it since...

Rubin v. United States called into question what a "sale of securities" included. The final decision was based on a minor difference in wording between the Securities Act of 1933 and the Securities Exchange Act of 1934. Its precedent was a clause in Naftalin arguing that securities laws were meant to be interpreted broadly to "include the entire selling process." By extension, the Court was defining the truly broad scope of power now entrusted to the SEC. Briefly, the ruling led to a broader interpretation of Rule 10b-5 to include almost all trading.

Globalization of Fraud Prevention​

As securities laws evolved in American courts, the main objective was always preventing fraud. The difficulty for judges was simply determining who needed to handle wrongdoings. As our regime elevated from State to Federal oversight, so too did our markets move from local brokers to national exchanges. This trend warrants further investigation given open web3.

When the Legislature incorporated the Bank of Illinois, it anticipated that its stock would be bought primarily by in-state investors. Instead, most shares were purchased by financiers in the East, who deviously use the names of Illinois farmers as owners of the stock.

— Michael Burlingame

Capital (mostly) flows intelligently to any market's best opportunities, no matter regulations, social norms, or your currency of denomination.

In the internet era, international companies can access international investors with the click of a button. Entering web3, how do we protect investors against widespread fraud, deceit, and inadequate disclosures in an increasingly worldwide capital market?

This roots of this question came up in last week’s Taking Stock. Namely, we were quibbling with how to prevent insider trading while protecting investor privacies.

Is Insider Trading Bad?​

Say 5–40% of public company employees have insider knowledge at any time. I think it makes sense to impose restrictions, public disclosures, and ongoing oversight to prevent insider trading. My view is further detailed in this comment letter. Briefly, I’ve seen market manipulation firsthand. I can almost feel when something doesn’t add up with the candlesticks. Would love to get on a trading podcast to elaborate.

The challenge with insider trading is investors don’t really see their losses. It’s a more nuanced, delayed extraction of value by corporate crooks. When they dump their shares after incredible earnings, for example, the stock still increases X%. But in reality, without insiders cashing in, you could argue that shares should’ve gone up Y%. It’s the same difficulty I face in explaining the international suppression of securities prices from FTDs.

Mixed opinions surfaced with Chives. I’d appreciate further discussion with everyone here. We can effectively police insider trading thoughtfully without completely revoking user privacy. It just comes down to designing open community reporting, analysis, and enforcement tools.

Replacing Trade Reporting Facility/Rule 613​

Clearly, we aren’t building these new systems to foster increased government oversight. A number of privacy advocates criticize the ineffectiveness of AML laws. I think we can build a unified global identity system based on the principles of Gitcoin Passport which lets us stop money laundering while preserving privacy with zero-knowledge proofs. It is technically possible. The only blocking factor is a true desire to do the right thing over making profits.

Every company starts as an idea in someone’s head. In other words, 100% of the first company employees have insider knowledge, largely because the actual product might not even be built yet. Accordingly, early pitches clearly represent an insider conveying their knowledge to an investor until they can convince them to pay money for a chance at a dream. For example:

Securities Anti-Fraud Laws Hold Issuers Accountable​

When one party to a securities offering knows more than another, regulation steps in to protect the public. Historically, that regulation has moved from State jurisdiction to Federal interpretation of securities laws. While this article linked extensively to FBI investigations, remember that the SEC prepares most cases. Transparency best keeps insiders honest, helping avoid the FBI in the first place.

These fallbacks are important because present private placement laws rightfully allow broad investor segments to invest in startups. By keeping the bar low for early fundraising, we effectively promote informed investment in the next innovators.

Private Company Disclosures​

We all know murder is wrong and bad. But we still write down laws and list out criminal criteria. Knowing the rules to play by is the definition of corporate accounting, the foundation of quality investor disclosures.

Early employees often wear all hats at a startup. Say over 80% of these employees have insider knowledge. Today, it is complicated, expensive, and slow to trade these private shares. With TAD3, it’s easy, instantaneous, and free. Accordingly, we think private market secondary trading rates will skyrocket in the coming years alongside the drastic increase in companies staying private to avoid legacy listing costs.

However, many private offering registrations or exemptions rely on unspecific compliance data. That makes it hard to ensure comprehensive reliance on current laws. Take for example a timeline of statements needed in some 506(b) placements with unaccredited investors:

Lack of Clarity​

This might seem like a simple checklist of documents to follow, but in reality, there is little to no Federal definition of what constitutes a balance sheet or statement of profit, loss, and retained earnings in connection with a JOBS Act Title IV offering. This leaves private issuers guessing at standards. Don’t even get me started on a lack of Federally-recommended reporting schemes for private securities transactions, financial performance, or corporate actions.

As more innovators found startups worldwide, we need to think deeply about our increasingly distributed online market for capital.

In Marine Bank v. Weaver, the Supreme Court ruled that an investment contract involving a Certificate of Deposit was not a security. Chief Justice Burger wrote that investors “are abundantly protected under the federal banking laws.” Accordingly, the alternate regulatory regime protected the CDs from SEC oversight. But the ruling left open a lack of predictability for secondary transactions that is more relevant now than ever given the rise of decentralized exchanges. Rather, the court deferred to a stance that "each transaction must be analyzed and evaluated on the basis of the content of the instruments in question, the purposes intended to be served, and the factual setting as a whole." Without truly answering the crucial question of horizontal commonality, we’re effectively left guessing at what a common enterprise entails under Howey.

In a world with millions of issuers, billions of investors, and trillions of transactions, it’s not reasonable to manually inspect each and every trade. It is reasonable to regulate issuer offerings, as our present securities regime does. But I believe we need to take a step back and call into question the intent of an offering itself in certain instances of digital assets so as to comprehend the nuance of an investment opportunity over the limited horizons of Rule 144. ⏰ We need a comprehensive overarching framework to pre-empt the legacy system.

International Blockchain Assets Standard Society​

• Digital assets are not legacy banking, securities fundraising, or commodities trading.
• They are a new global tool with widespread implications, namely for impoverished nations.
• We need to organize a global Blockchain Assets Standard Society with diverse representation.

Just last year, the SEC reported $2,869,000,000,000 raised through domestic private offerings. Including foreign investors, the sum raises to 40% of all the funds raised in America. You can capture a share of this massive capital influx by issuing a standard "SAFE," convertible note, or "KISS" agreement. Compared to just selling shares at market prices, these early placement agreements let you raise cash without a company value. Negotiation between founders and investors depends on your circumstances, the market, and business history.

SEC Fundraising Webinar

Closing a Placement​

In the early days of your business, closing a financing round like a private placement comes down to your ability to imagine, convey, and deliver on a promising venture vision. Once you master these core business skills, it just comes down to the right audience. An executive of our client said one surefire approach to convince investors: "Do something that you love, because you'll put in the work behind it." — Angel Laylor

We are currently streamlining the offering process through smart contracts that put these agreements on Soroban, so that you can raise from any verified users of Stellar. This is just one example of continuing to work steadfastly while racking up momentum, clientele, and experience. When you can just stick with your work, stuff will happen:

Relevant insights, albeit inspired by TVDH.

Pitching your startup can be one of the best ways to quickly understand your value proposition to investors and the market you'll serve. As Min-Liang Tan popularized, this can well start off with building something both "for and by" your community. Once you're off to the races building, it's a very short leap to selling inaugural users.

Direct investor trading is a symbol of financial liberation. It's about breaking down barriers and democratizing finance. And in this blossoming ecosystem, each of us has the potential to grow our investments on our own terms. It's a vibrant, bustling market where anyone with an internet connection and a government ID can participate. No longer confined by the walls of traditional exchanges, direct trading hands the reins of the market back to its rightful owners—the people.

The Basics of Direct Trading​

At its heart, TAD3 is about simplicity and connection. It's the financial equivalent of a farmers' market, where producers and consumers interact without a supermarket acting as a go-between. This translates to a system where individuals like you and me can trade securities directly with each other, without a traditional broker setting the terms or taking a slice of the pie.

Exempted Transactions​

Now, you might wonder, how is this all possible? Well, it's thanks to federal trading exemptions for anyone other than an "issuer, underwriter, or dealer." Imagine the process as if you're handing over a prized painting to a friend. You have a "painting certificate," a tangible representation of your investment. Instead of going through a centralized dealer gallery, you and I sit down to make a private deal. On our own behalves, I agree to wire you money directly, and you sign the Van Gogh over to me. There's a sense of satisfaction in handling the transaction ourselves, without intermediaries. That's TAD3,powered by distributed ledger technology.

Efficient Secondary Markets ↔​

Picture this: Miguel, an early investor in an innovative manufacturing startup, can sell his shares to Sarah, a retired scientist, without jumping through the hoops of traditional systems. They find common ground in TAD3, a beacon of efficiency with no trading fees nibbling away at their finances.

TAD3 Principles​

Just as artists trust galleries to distribute their paintings, companies use transfer agents to manage their stock. There's just a smidge more compliance work on the securities side. That's why only a few companies in the entire US market act as their own transfer agent,in fear of sub-par services. TAD3 is like a public, global digital archive rather than a physical gallery on Wall Street, only for a special few. Stellar holds detailed records of every transaction, maintaining a distributed ledger that's as clear and reliable as a museum's catalog (and don't forget programmatically accessible ).

TAD3's Non-Intermediary Model​

TAD3 acts as a silent witness rather than a vocal auctioneer. TAD3 don't stand between buyers and sellers, shouting out bids and offers. Instead, Stellar enables transactions directly between investors, much like a bulletin board in a community center where people can pin up offers and requests. (Don't worry, we have systems in place to enforce SEC trading halts.) This means that TAD3 does not profit from each transaction, but rather it allows us to facilitate the smooth transfer of ownership from one investor to another. You could think of the decentralized Stellar network as a librarian who organizes books for the depository, TAD3.

Advantages​

When TAD3 don't take a cut, the savings are passed directly to your savings and retirements. Imagine keeping every dollar you earn from selling tomatoes in your backyard garden instead of paying a vendor fee at the farmers' market. This is the financial equivalent. By not charging fees or acting as middlemen, TAD3 empowers investors to keep more of their profits, which can then be reinvested or spent as they see fit—the ultimate financial freedom. Moreover, this streamlined approach creates a more dynamic market, where securities change hands more freely and efficiently.

"Atomic Swaps" Make This Work​

Atomic swaps let you trade with no middlemen. They are a revolutionary piece of blockchain technology using math and the foundational principle behind the SDEX's global decentralized limit order book. Offers are "atomic" because either a trade happens in its entirety, or not at all. This eliminates counterparty risk, which removes the need for a centralized clearing system entirely.

Facilitating Trustless Trust​

Atomic swaps are a cornerstone of direct trading in TAD3. By using automated, decentralized protocols, the SDEX lets investors privately trade securely at scale in a way never before seen. This approach streamlines the trading process, reduces dependency on third parties, and (importantly) removes transaction fees that would otherwise go to intermediaries.

The Stellar Consensus Protocol underpins these transactions, ensuring they are fast, reliable, and tamper-proof. It's like a global farmers' market where companies can send crops to investors in exchange for payments, all through one email. The distributed network checks for fair trade conditions before finalizing all transaction. Seamless, secure, and nearly instant swaps—that's TAD3.

A Unique Network​

The SDEX is part of the actual Stellar core protocol. Most DEXes (if not all other than 0x ) rely on smart contracts, external service providers, or secondary layers for trading. Stellar's direct integration cuts out common security risks associated with those additional systems and provides a transparent, efficient trading experience.

Regulatory Compliance​

Based on extensive legal investigation, securities trading systems using those additional technologies would today be classified as Alternative Trading Systems, which must be registered with and regulated by the SEC (example ATS which presently charges 1% trading fees).

Because they're centralized, ATSs can and do discriminate based on traditional access methods. It’s essential to establish a fair and equitable system that provides equal opportunities for all investors, aligning with the ethos of decentralization and inclusivity that blockchain advocates. That doesn't happen when brokers require a US social security number because they can't bother with an international "low-value" user's government ID, or transfer agents require a medallion stamp.

Moreover, ATSs are "black boxes," which means you can't actually review how they operate. Investors have to rely on regular thorough broker investigations to ensure fairness, which gets quite expensive. Take a guess who those compliance costs get passed on to. Further, regulators can only act so quickly when it comes to the 49 ATSs in operation today. This oversight process can and does go wrong, at the expense of investors.

Despite illegality, stock exchanges and ATSs by ownership extension sell faster trading data to HFTs. That means that market makers can know the price of a stock up to three or four seconds before you. Remember, these exchanges are all for-profit corporations with shareholders to satisfy. Investor advocate Mark Faulk says:

" When the Exchange went from not-for-profit to for-profit...

the utility function of the marketplace of the exchanges disappeared.

Because once you... flipped the switch to make these exchanges, not utilities,

but for-profit vehicles, now you have shareholders to answer to... and obviously the largest customers are the HFTs. " We need to level the playing field for all investors, regardless of their trading frequency or volume.

Transparency is key in a new, trusting financial system. We shouldn't need to worry about when our broker is trading against us. Clear, auditable processes must allow users to understand how their trades execute—that's TAD3.

Lastly, for the finance geeks, all these different ATS trading venues split volume apart, segmenting the entire stock market. The implications and costs of this practice are very difficult to quantify, but they dramatically affect your investment returns over time. ⌚ This leads to higher spreads, a fragmented view of transaction history, and other problems detrimental to ' smarter markets.' A unified, or at least interoperable, recordkeeping system could eliminate this fragmentation. Not one controlled by a private for-profit monopoly.

The Takeaway​

There are a lot of very smart people working on the problems TAD3 solves. For instance, we spoke to a co-founder of the first widespread decentralized order book platform, launched in 2018. The system was built on extremely innovative P2P file-sharing technology, with transaction costs originally starting between 50 ¢ to a dollar. They got a knock on the door very early on since they'd processed millions of trades almost immediately after launching. For regulatory reporting, they told us you had to scan through dozens of Ethereum ledgers to find a certain kind of specific trading code signature to match a nuanced distributed data/ math scheme. That's impossible to conduct efficiently at scale or effectively oversee.

"Someone needs to build a unified system for trading," has been heralded for decades by market advocates,researchers, and investors alike. That's why we built TAD3.

Payroll Annualized: $0​

This is something from the origin story of DRS.

The Dr. Trimbath interview with No Safe Bets brings up:

In 1971, there was a group called the Banking And Securities Industry Committee...

These BASIC bankers got together and argued against creating something called

the transfer agent depository which would have given us direct registration back in 1971.

But instead, we were given the Depository Trust Company. — Bibic at WhyDRS.org ↗

Prerequisite Listening: Direct Registration System Provenance. TLDR: Wall Street gets all your money.

According to the U.S. Securities and Exchange Commission: The transfer agent depository ("TAD" ) would replace the certificate with computerized stockowner lists... which would serve as both the issuer's stock records and the shareowner's evidence of ownership.

SEC commenters supported the TAD. They thought the only investors should be registered investors (not interchangeable with book entry ). They wanted a world without a convoluted, oligopolic, and opaque trading system.

Beginnings​

Block Transfer started at an online Atlanta Web3 hackathon. I was trading international forex markets 22 hours a day at the time, using polyphasic uberman. I needed to do a "restart" because I decided to get a full night's sleep for finals. That meant staying up for 36 hours before starting my revolving 20-minute naps.

I think the exam was on a Wednesday, and the hackathon was the coming weekend. So I started the extended wake period 35 hours before the hackathon's closing ceremony. The hackathon was great, and it resulted in our first Block Transfer implementation

Soon after, we were graciously thrust into Georgia Tech's InVenture Prize. Ever since the campus guide told me about the event during a high-school visit, I'd wanted to present. The process also introduced us to a key early advisor.

Preparation for the competition included three rounds of pitch competitions, the latter two to a panel of judges. After qualifying for finals, we went through dozens of pitch practice session with those judges, each time narrowing my idea down.

Around the same time, I also applied to other college student business pitch competitions. I further refined my idea here, and even won $5,000 from Entrepreneurs' Organization and $2,000 from US Bank.

All this pitching made me very focused on money. Combined with bona fide prodding from mentor sessions during Tech's CREATE-X Startup Launch program, we tried to close our first client in the summer of 2021 with an improved Ethereum implementation.

Talks went well with that CFO, but cost savings alone weren't enough to drive a close with this level of implementation. I'm thankful for that, looking back. I think it would have been two months tops before we got an SEC non-compliance letter, if we took on the firm.

I realized that gas costs for a stock transfers on Ethereum would be at least $10 each, and significantly more for trades. To fix this problem, we planned to scale the Ethereum implementation with "level 2" daily transaction batches, using Arbitrum.

But any netting would facilitate counterparty risk (albeit less so with crypto) and, more importantly, slow down clearing to T+1:(## TAD2

So we set off looking for another blockchain. I settled on my three most important network considerations after considerable protocol analysis, comparisons, and brainstorming: (in order of importance)

1. Cost: Cost per transaction is and always will be a number one value metric for me. Per-trade costs directly impact investor returns. They are the one thing we can directly control to facilitate building real savings and retirements for masses of people.

2. Speed: I come from day trading. I regret sacrificing joyful instantaneous trading and limited market hours that squeeze most US volume from 9am to noon. But markets were originally given trading hours due to lack of buyer interest. That's not a problem in an increasingly global world with better online connection than ever.

3. Impact: We were unbelievably surprised to learn that Stellar cared so much about comprehensive global inclusion. I first learned about Stellar in 2017 when I bought its nature currency at $0.035. I've always felt excluded from the financial system. When I was a pre-teen, I built an RPG with a video game maker. When publishing onto Steam, they asked for my bank account and routing numbers. When I asked my parents, they wouldn't share the details because "people will steal your money." Talk about trusting the financial system. Without much leverage, I moved on and eventually got my first job at Subway. I have them to thank for the muscle memory to grab things behind me without looking. My manager wasn't the nicest guy. I was okay with that because they were letting me work illegally at 15. But a lot of pressure started mounting after about a year there, when so many of my coworkers left that I was working open to close completely alone. I decided that the only way to take control of my financial future was to take it into my own hands. For the next six months, I spent every waking hour outside of work or school researching the stock market. I even made my first few investments. I had losers, some decent investments in NVIDIA and AMD, and a few stocks in-between. When summer rolled around, I turned in my two-week notice. I quit my job to trade stocks full-time. Just one small problem: I didn't have a brokerage account. I did all my initial testing with my Dad's broker. But he didn't live with me, plus his broker didn't have a very good trading interface. Luckily, my Mom set me up with her Fidelity. Sadly, my home relations were not great at the time. Every morning I had a problem logging into Fidelity, which was surprisingly often, I had to either disrupt my Mom's conference calls or watch hopelessly as the market ripped away without me (I didn't know about UTMAs at the time). But at the end of that summer, I discovered Ethereum. A solution, I thought the same technical analysis patterns in crypto—no age verification required. Imagine that Web3 experience, but for any modern financial institution—and especially for US stock brokers. Think about what your world would be like without quality, accessible investment opportunities. Would you still save for retirement? It's a lot harder without the miracle of compounding. That's a daily reality for over 7 billion people, many of whose best investment option is a metal roof or deadly weapon. What if we gave them access to the most advanced, developed, and liquid capital market the world has ever seen?

Stellar also has some other pretty cool things, all built directly into the protocol level. That means you don't need to write a smart contract for any of our current features, which historically introduce significant security risks, even for the best teams.

That background was up to 2021. I spent the next two years learning to use Stellar. Personally, I never thought I'd code. I remember during my first blockchain startup thinking, "I'll never need to learn coding. I'll just hire developers with all the money I'll make trading stocks." I seriously doubt we'd be here today if I did outsource to a development team early on. Thankfully, good smart contract developers were too expensive for me at the time, so I learned how to code at Georgia Tech.

Launch​

We got our inaugural client in June, finished processing SEC registration papers for them in July, and started onboarding their investors upon receipt of a final cap table in September. We've onboarded 6 investors out of the 25 provided. There is currently a pending stock revocation for 12 investors the company claims do not actually own shares.

When this client first reached out to us, we thought they were a relatively large marketing company. But it turns out they are a small business—which is fine! Markets and stock ownership records 100% do need to exist for all businesses. If you plan to scale your business, it's very important to get your stock accounting right from day one. I've heard nightmare stories of VCs finding out three investment rounds later that they actually own another 250,000 shares per an early contract. Notwithstanding, they haven't yet paid us any communicated fees aside from an ~7% equity stake. They told us that this was due to lack of funds on a call dated 23 Oct 2023.

Next​

If you visited the last link, then you saw the actual transaction I was talking about when I mentioned our equity stake. It was a payment of 5 million shares from our Stellar "distributor account" to our treasury account. If you looked closely you can see the amount we paid for the shares in the memo and the "claimable" date we elected internally to not transfer our shares until, to both align our incentives with their long-term objectives and prevent us from dumping shares on their developing investor-base.

That's the power of Web3. Anyone can confirm information about a stock without worrying about expensive level 2 access fees, data platform access fees, or specialized market information consolidators. You can just reference the blockchain for all your needs in real time. And the transaction, which executed in about 5 seconds, cost only 0.0001 XLM, or $0.0012 today.

TAD3​

That's just the tip of the iceberg for what we're calling our "Web3 Transfer Agent Depository" or TAD3 for short. We've conducted extensive due diligence on the regulatory implications of TAD3. Despite presenting our system to even the most executive individuals at or formerly at the Securities and Exchange Commission, we've concluded that TAD3 falls outside of the current, relatively limited set of regulations on legacy transfer agents. We've always been registered as a transfer agent with the SEC, but we're happy to change filer types if the SEC thinks TAD3 should be explicitly classified as the transfer agent depository.

One particularly important aspect of TAD3 is the ability for registered investors to trade with each other through Stellar's native decentralized exchange, the SDEX. Block Transfer conducts KYC/AML checks for all accounts. The SDEX lets these investors trade TAD3 assets on a global, decentralized limit order book. Under the hood, investors use cryptography to sign bid and ask quotes which get stored on the blockchain and matched every ledger based first on price and then time.

We continually monitor all accounts for suspicious transfer or trading activities. With that said, it's worth explaining a little bit about what accounts look like in TAD3. All Stellar accounts get identified by a "public key" that looks like "GDRM3MK6KMHSYIT4E2AG2S2LWTDBJNYXE4H72C7YTTRWOWX5ZBECFWO7." Those public keys aren't very easy to share, so we give users a random permanent account ID that looks like BIYES3WTN. On the backend, this resolves to the full public key. If you visited the equity transaction link, then you might have noticed that the two accounts mentioned are identified on the ledger by their public keys. Those public keys, and thus their associated transactions, are the only user information stored on the blockchain.

It's worth pausing for a moment to talk a little more about Stellar.

Brief Stellar History​

Stellar went live one month after Ethereum in 2015. The SDEX has been there since day one.

The team behind Stellar split from Ripple in 2014 because they wanted to focus on empowering global citizens to access financial markets, not profiting from big banks (the article linked was originally titled "Jed McCaleb: XRP and XLM Visionary or Disaster Artist?" ). This decision shows in every aspect of Stellar.

In contract with other truly decentralized blockchains, Stellar does not distribute transaction fees or any other compensation to miners or validators, thanks to its unique consensus protocol. This keeps transaction costs down.

Stellar can currently process up to 1,000 transactions per ledger. That lets investors pack the blockchain with as many stock gifts, buy offers, or proxy votes as they can click away on their phones at once.

Lastly, Stellar is incredible dedicated to global financial inclusion. There are immense benefits to opening US investment markets to the world, direct foreign markets to Americans, and everything in-between (e.g. more eyeballs on stock tickers). TAD3 fundamentally connects a growing capitalistic world with a fair market for capital. We envision a future where, after proper SEC filings, a company can "go public" through an SDEX sell offer (most investors don't know that "being public" really just means that you report timely financial statements to the SEC). That why we connect investors and issuers with a standardized nonprofit global financial system.

We Will Comply​

The SEC is well within their rights to ask for programmatic access to our internal records to resolve a suspicious public key to its full internal PII record. We will grant them access to such a system, not unlike the present CIP. We built TAD3 to help investors for their entire investing career from start to peaceful bequeathment. Our general approach so far has been modeling the Syndicate based on the past 100+ years of broker regulations. TAD3 will either comply with all future transfer agent regulations, or we'll help build them ourselves.

Sources

SEC Report on Transfer Agent Depository

Read Next: Empowering Investors - Learn how TAD3 enables direct trading with zero banks, brokers, etc.

Two days ago, WalletConnect restricted its availability in Russia in response to new legal and OFAC guidelines. WalletConnect, for those who aren't familiar, is a linchpin in the Web3 ecosystem. It's a crucial bridge that allows for seamless interactions between decentralized applications and personal crypto wallets.

The update has broader implications than just affecting Russian users—it's sending ripples through the Web3 and financial spaces. T his situation is a perfect example of how Web3 innovations and regulatory preparedness intersect—and why it’s more crucial than ever to be informed and ready.

Financial Markets and Web3​

In the traditional financial world, regulations are stringent, and for a good reason. They protect investors, maintain trust, and ensure the stability of capital markets. Web3 projects, especially those related to decentralized finance, are challenging the status quo by democratizing access to financial instruments. But with great power comes great responsibility—and that includes adhering to regulations designed to promote global stability.

Non-compliance can result in hefty fines, legal disputes, and can even spell the end for your project. I've seen projects go from hot to not overnight (and vice versa ) because they ignored or underestimated compliance requirements. It's a reality check that comes in hard and fast.

Regulatory Compliance?​

In the early days of the internet, it was pretty much the Wild West. No one was quite sure what the rules were, and innovation took precedence over regulation. Fast forward to today, and you'll see that Web3, the decentralized internet built on blockchain technologies, is in a similar boat.

Regulatory compliance is not just a buzzword; it's an essential pillar for the sustainability of any Web3 project. It's the guardrail that keeps us from falling off the proverbial cliff of legal ramifications and provides a framework to operate ethically and responsibly.

What's at Stake?​

The ability for Web3 projects to interface and integrate with traditional markets largely depends on compliance. If DeFi projects, for example, are to ever become a recognized alternative to traditional financial systems, they need to play by some ground rules. If not, we're looking at isolated financial ecosystems that can't maximize their reach or impact.

A Personal Journey Through Securities Regulation​

At Block Transfer, we never considered regulations as an afterthought. Far from it! I actually began my journey into the transfer agent world through an old classic: The Transfer of Stock published in 1929 by Francis Christy. Yes, you heard that right—1929!

The New York Times hailed it as the “authoritative book on how corporate stock transfers are made.” This book was my gateway into the fascinating world of securities regulation. From there, over the course of years, I read every piece of federal US securities regulation, understanding that any innovation we drive must be compliant and reliable.

Closing Thoughts​

The WalletConnect situation showcases the complex relationship between Web3 technologies, regulatory compliance, and traditional financial markets. Web3 projects have the power to revolutionize not just how we interact online, but also how we deal with money, assets, and financial instruments. However, without proper regulatory compliance, we risk creating financial bubbles, harming investors, and missing out on creating something genuinely transformative.

Regulatory compliance may not be the most glamorous aspect of running a Web3 project, but it's definitely among the most important. Legal frameworks around investing are continually evolving. WalletConnect's recent update is a sign of how much external factors like government regulations can affect the Web3 landscape. We have to be prepared for these changes as they come. If you're a blockchain company with over 35 investors, we can make your shareholder compliance life easy.

Sources

WalletConnect Protocol Update Email

The traditional proxy voting system is a maze of paper ballots, phone calls, and centralized control numbers that can leave even the most diligent shareholder scratching their head.

Why does this matter? Because shareholder voting isn't just a formality; it's a pivotal aspect of corporate governance that directly impacts your investment. The voting process gives you the power to influence management decisions, potentially boosting stock performance by tapping into the collective wisdom of a diverse investor base. But what if this system, designed to give you a voice, is so flawed and cumbersome that it effectively silences you?

Deep challenges and inefficiencies plague the traditional proxy voting system. But what if there was a way to not only simplify this convoluted process but also make it more democratic?

The Quagmire of Proxy Plumbing​

"Proxy plumbing" may conjure images of a home improvement project, but it's actually a term that encapsulates the complex and often inefficient system of shareholder voting. It refers not only to the maze-like distribution of proxy materials—those vital documents that empower shareholders to vote on key corporate issues—but also to the entire vote collection process. This "plumbing" is intended to channel your voting power seamlessly into corporate decision-making, but it frequently experiences leaks and blockages along the way.

This system is rife with inefficiencies such as over-voting, empty voting, and a lack of vote confirmation, among others. These issues not only make the voting process cumbersome but also cast doubts on its integrity and inclusivity. The end result? A diluted shareholder voice and a missed opportunity to effectively influence corporate management.

Bank of America counted 130% of its shares voted...

they received 30% more votes than they had shares outstanding.

That‘s just the number of people who actually voted their shares!

Imagine how many shares were sold beyond what they actually authorized and issued. This violates the voting rights of shareholders and reduces effective corporate governance.

— Lucy Komisar

This system is rife with inefficiencies such as over-voting, empty voting, and a lack of vote confirmation, among others. These issues not only make the voting process cumbersome but also cast doubts on its integrity and inclusivity. The end result? A diluted shareholder voice and a missed opportunity to effectively influence corporate management.

The Phone Fiasco​

Imagine this: You've just received a notification that it's time to cast your vote on important corporate matters for a company you've invested in. Eager to exercise your shareholder rights, you decide to vote by phone, thinking it'll be quick and convenient. You dial the toll-free number provided and brace yourself for what should be a straightforward process.

But then, you're greeted by an automated voice system that seems to have been designed in the pre-internet era. The menu options are confusing, and you find yourself pressing the same numbers repeatedly, hoping to get to the right place. After several minutes of navigating this labyrinth, you're finally connected to a human operator.

You'd think this would make things easier, but no. The operator rushes through the voting items, barely giving you time to understand the issues at hand. You find yourself asking them to repeat the options, only to be met with audible sighs of impatience. The potential for errors is high, and you start to question the integrity of this voting method.

Finally, after what feels like an eternity, you cast your vote. But even then, there's no real confirmation that your vote has been accurately recorded. You hang up the phone, feeling more frustrated than empowered, wondering if your voice will even be heard.

The Paper Chase​

You're an investor who's just put money into a promising company, excited about the potential returns and the chance to have a say in corporate decisions. Then, one day, a hefty envelope lands in your mailbox. You open it to find a stack of papers, including the definitive proxy statement, which outlines the items up for a vote at the upcoming annual shareholder meeting. Alongside it, you find a comprehensive annual report from the issuer, filled with financial statements, executive summaries, and other disclosures.

You're not alone in receiving this "full set delivery" of materials. The company, often through a transfer agent, has sent out similar packages to all shareholders. The environmental impact of this paper-heavy process is staggering. Reams of paper are printed, and the carbon footprint of the mailing process is significant.

You spend the next couple of hours diligently filling out your ballot. After all, this is why you invested—to have a say in the company's future. You seal the return envelope and drop it back in the mailbox, but as you do, a nagging question remains: In an age where almost everything is digitized, why is the proxy voting system so stuck in the past? Why does it feel like your voice is being muffled by an outdated, inefficient process?

In all reality, t here's no guarantee that your vote will be accurately recorded or even received. Costly paper ballots can get lost in the mail, miscounted, or arrive past the deadline, effectively nullifying your vote.

Control Number Quandaries​

In the traditional proxy voting system, each shareholder is assigned a unique control number. This number is used to identify and authenticate the shareholder's vote. The centralized control number system, while designed to streamline the voting process, often ends up complicating it further. These inefficiencies not only burden companies but also disenfranchise shareholders, diluting their ability to influence corporate governance effectively. Consider these risks and past consequences, among others:

• Data Breaches: Centralized systems are a goldmine for hackers. A breach in the system could compromise the control numbers, leading to unauthorized voting or even vote manipulation.

• Tally Errors: The centralized nature of control numbers makes it easier for insiders or third parties to manipulate votes. Errors in the system can also lead to incorrect vote counts, as was the case in these examples:

• Yahoo's 2008 Director Election: Yahoo was forced to recount votes in its contested 2008 director election due to significant errors in reporting votes. The centralized control system failed to ensure an accurate count, leading to a recount that not only delayed the process but also raised questions about the integrity of the US equity shareholder voting system.

• Proxy Middlemen and Dell Buyout: In the buyout of Dell Inc., T. Rowe Price intended to vote "no" but, due to a complex chain of intermediaries and default settings, their vote was cast as "yes." This resulted in $TROW losing $194 million.

• 2017 Procter & Gamble Proxy Fight: Many proxies were invalidated due to systemic issues such as breaks in the chain of custody and improperly filled proxy cards. The centralized control system was unable to prevent these issues, leading to a recount and undermining the legitimacy of the entire process.

Three Top Threats to Democratic Elections​

Empty Votes​

Imagine you're a long-term investor in a company you believe in. You've done your research, you understand the business model, and you're invested not just financially, but emotionally. You care about the company's future and want to have a say in its direction. Now, picture this: someone votes on crucial decisions about the company you love, but they have no skin in the game.

When you buy shares through a brokerage account, those shares are held in "street name," meaning they're registered in the name of the brokerage rather than in your name. This common practice gives brokers the legal right to lend out your shares to short-sellers. The broker earns interest income from lending out these shares, and most of the time, you, the actual owner, are none the wiser.

This practice is usually buried deep in the fine print of your brokerage agreement, and let's be honest, how many of us read that cover to cover? So, while you think you're holding shares of a company you believe in, those shares could be lent out to someone betting against the very same company you're supporting. The kicker? The person borrowing your shares also inherits the voting rights attached to them.

Long story short, they've borrowed shares or used derivatives to acquire voting rights without actually owning the stock. This is the unsettling reality of empty voting. They can vote on mergers, leadership changes, and other pivotal matters without worrying about the consequences—you will.

They can, in fact, throw out your vote and just not count it.

They can randomly assign your vote to some real proxy that wasn‘t voted.

They can vote what shares they actually do have proportionally

based on how many phantom votes come in. It‘s all done in secrecy.

They don‘t have to tell you, they don‘t have to tell the NYSE, they don‘t have to tell anyone. They don‘t have to tell the company whose shares they voted. — Dr. Susanne Trimbath This disconnect between voting power and economic interest is more than just unfair; it's a threat to the very essence of shareholder democracy. It's a loophole in the system that allows for the manipulation of outcomes, diluting the voice of shareholders who are genuinely invested in the company's future. The emotional toll of this can be significant. Imagine watching powerless as decisions are made that you know are not in the best interest of the company you care deeply about.

Overvoting​

Picture this: You're at a town hall meeting, and everyone is given a single token to cast their vote on community issues. You drop your token into the voting box, confident that your voice will be heard. But then you notice something odd—some people have multiple tokens, and they're gleefully dropping them into the box. Your heart sinks as you realize that your single vote has been diluted, overshadowed by the unfair advantage of others. This is the essence of overvoting in the corporate world, a system where the "one share, one vote" principle is often compromised.

In the traditional proxy voting system,overvoting is a rampant issue. It occurs when more votes are cast than there are shares available, often due to the lending of shares by brokers. This dilutes the voting power of individual shareholders and creates a chaotic, unreliable voting landscape. It's like a game where the rules are constantly changing, and not in your favor.

Veil of Anonymity​

Now, let's add another layer of complexity: the OBO/NOBO rule. Brokers have the option to classify your account as either an "objecting beneficial owner" or "non-objecting beneficial owner." OBO is the default setting, which means you're anonymous to the companies you're investing in. Learn more in this full blog post.

The OBO/NOBO conundrum doesn't just create a barrier to effective corporate governance; it also has a financial impact that many investors are unaware of. When you're a beneficial owner, brokers essentially charge companies whatever they want to distribute your proxy materials under SEC Rule 14a-13(a)(5). This creates a perverse incentive system where brokers are motivated to request as much material as possible, just so they can bill the issuer more.

This practice has even led to a bizarre bidding war among physical material distributors. These distributors will bid up the price they're willing to pay a broker for the "privilege" of sending out proxy materials. Why? Because they know they can pass those costs onto the companies. It's a major source of revenue for brokers, but it's a cost that public companies have to bear, often without fully understanding the extent of these charges.

This system is not just inefficient; it's fundamentally broken. It distorts the true cost of shareholder engagement and puts a financial strain on companies, which ultimately affects their performance and, by extension, shareholder value. Further, these middlemen don't just make money from distributing proxy materials; they also charge companies exorbitant fees for a list of OBO holders with basic information. It's a double whammy that not only keeps the companies in the dark but also drains their resources.

Our Solution​

Enter blockchain technology. Our solution leverages the transparency and security of blockchain to ensure that each share corresponds to a single vote. When you cast your vote through our wallet app, it's recorded on a public ledger that is immutable and transparent. No more secret backroom dealings, no more vote manipulation.

With direct registered ownership, your vote truly counts. You're not just a face in the crowd but a recognized, valued participant in corporate governance. It's time to take back control, to ensure that your voice is heard loud and clear. With blockchain-based voting, we're not just fixing a broken system; we're building a new one, rooted in fairness, transparency, and trust.

Our systems make every vote traceable and transparent. Once voting opens, we send investors standard proxy notices. But instead of dialing a call center or mailing back a postcard, investors use a wallet app to cryptographically vote with math. They go through an interface with the voting items specific to each meeting, selecting "for," "nay," "abstain," or "withhold" for each item. These choices get encoded in a transaction memo, which is then sent to a public blockchain voting address. At the meeting, vote results from these public distributed ledger are reconciled with shareholder record-date balances as recorded on the blockchain. Anyone can tally up public transaction memos to verify final counts, and all votes have the same security backing our stock transfers.

Sources

Block Transfer Yellowpaper

Komisa r's P hantom Shares

Trimbath's Post #1,#2, &#3

You're about to transfer some shares online, a process that should be as simple as a few clicks, right? Not so fast! You get hit with a curveball called a "medallion signature guarantee." It sounds like something out of a medieval knighthood ceremony, but it's actually a stamp—yes, a physical stamp—required by legacy transfer agents to authenticate your identity for electronic registered stock transfers.

If you're scratching your head thinking, "Isn't this the digital age?", you're not alone. It's a system that feels not just outdated, but downright unreasonable in today's world of digital transactions. In this post, we'll explore why medallion signature guarantees have overstayed their welcome and how blockchain technology is ready to take the stage as a far more reasonable, secure, and efficient alternative.

What is a Medallion Signature Guarantee?​

Despite its grandiose name, medallions are essentially a specialized stamp to authenticate financial transactions. Traditionally, you needed this seal as a measure of fraud protection when you wanted to transfer stock on the books of an issuer (think direct share purchase plans or employee stock options). The stamp is not just any ordinary stamp, it's backed by a monetary guarantee from the issuing bank that you are, in fact, you.

Basically, a banker reviews your documents and government IDs (yes, you need two at most banks). First, they must approve your documents as financial statements and legal representations related specifically to you. Some banks won't stamp if you're withdrawing from an affiliate (think brokerage to DRS ). If all is good, they watch you sign the physical document, and they rubber stamp it.

The idea is to provide an extra layer of security in financial transactions. But in a world that's rapidly digitizing, the question arises: Is this old-school method of security still effective, or even reasonable? Forcing this antiquated system onto modern financial transactions is like trying to fit a square peg in a round hole. Sure, it might fit with enough force, but there's a better shape out there that makes the whole process easier.

The Drawbacks of Medallion Signature Guarantees​

Now that we've got a handle on what medallions are and why they've been a staple in financial transactions for so long, let's talk about why they're no longer the golden standard. If you've ever gone through the process of getting a medallion, you know it's anything but convenient. From the need to physically visit a financial institution to the pile of documentation you have to carry, the process is, simply put, a hassle. But the inconvenience is just the tip of the iceberg. Let's dig into the deeper issues that make medallions a not-so-great fit for our fast-paced, digital world.

Time and Inconvenience ⌛​

We live in a world where you can transfer money to someone halfway across the globe in a matter of seconds, thanks to digital platforms. So why does transferring shares still require a detour to a financial institution and a potential wait of several days just for a stamp?

First off, you'll likely need to make an appointment with your financial institution, adding another to-do on your already busy schedule. Once you get there, you'll have to present multiple forms of identification, financial statements, and possibly account statements for both the sending and receiving parties involved in the transaction. This additional paperwork adds another layer of complexity to an already cumbersome process.

After all the documents have been presented and reviewed, which can take anywhere from an hour to a week, only then will your paperwork be stamped with a medallion.

And don't forget: this is for each transaction. Planning on making multiple stock transfers? Brace yourself for the tedious process each and every time.

The reality is that medallions are a roadblock in the fast lane of digital transactions. They slow down processes that could otherwise be quick and seamless, adding unnecessary layers of complexity and time delays. In today's fast-paced world, where efficiency is everything, the cumbersome process of acquiring a medallion is a glaring bottleneck.

Limited Accessibility​

The inconvenience of getting a medallion doesn't stop at the time-consuming process and piles of paperwork. There's also the matter of accessibility. Not every financial institution offers medallion services, and even among those that do, some only offer it to their existing customers. This creates a barrier to entry for those who are either not near a participating institution or are not existing account holders.

Lack of Global Access​

We've talked about how inconvenient it is to get a medallion, but what if you're not even in the United States? Then, you're really in for a wild ride. Medallions are predominantly a U.S. practice, meaning there are extremely few institutions that offer them outside the country. So if you're an international investor or just find yourself overseas, your options are pretty limited.

"But what about online alternatives?" you might ask. Sure, there are some digital platforms that offer medallion guarantees, but brace yourself for a shocker: these services often charge exorbitant fees, sometimes running into hundreds of dollars per transaction. That's not just an inconvenience; it's a financial burden.

The lack of accessibility further exacerbates the issue, making medallions not just a hassle, but often an impossibility for people who aren't conveniently located near a guaranteeing institution. In an increasingly globalized world where financial transactions should be borderless, the limitations of medallions present a significant drawback.

Investor Demographics​

Additionally, let's not forget about the groups that are often overlooked: the elderly, the disabled, and those without easy access to transportation. For these individuals, the need to physically go to a financial institution presents an added challenge that makes the entire process even more inaccessible.

Importantly, a considerable number of investors fall into the elderly category. These aren't just random people struggling with the system; they're stakeholders in the investment world who are being inconvenienced by an outdated process.

So, while medallions might offer a layer of security, they also inadvertently act as a gatekeeper, limiting who can easily engage in stock transfers. This flies in the face of the inclusivity and ease of access that the digital age should be offering to everyone, regardless of location or circumstance.

Human Error​

When it comes to financial transactions, especially something as important as transferring shares, the margin for error should be as minimal as possible. However, the process of acquiring a medallion introduces multiple opportunities for human error, which can result in costly mistakes or delays. ⏳

For instance, the financial institution reviewing your application could misinterpret a document, incorrectly record information, or simply stamp the wrong section of a form. Each of these errors, while seemingly minor, can have significant repercussions, such as transaction delays or even the invalidation of the entire transfer.

Furthermore, with the numerous identification and financial documents required, the possibility of submitting incorrect or outdated paperwork is also heightened. Given the time-sensitive nature of many stock transfers, these delays can be more than just a nuisance; they can be financially detrimental.

Lastly, let's not forget that medallions are physical stamps. They can smudge, fade, or otherwise become illegible, adding yet another layer of potential error that can compromise the integrity of the transaction.

Our Own Experience​

In the (very) early days of Block Transfer, we joined the major medallion stamp programs, thinking that this would be an essential step in becoming a trusted player in the financial sector. What we found was enlightening—and not in a good way.

One significant issue that quickly came to light was the startling frequency with which medallion stamps are lost or stolen. Yes, these stamps—supposed symbols of security and authenticity—are routinely pilfered or misplaced. And when that happens, every financial institution verifying medallions has to cross-reference each and every stamp against a constantly-updated registry of stolen stamps.

You'd be surprised how common these incidents are. It's like constantly checking a "Most Wanted" list before making any transaction. This cumbersome process not only introduced another layer of complexity but also made us question the effectiveness of the very system we were supposed to trust.

It was an eye-opener for us, and it played a part in shaping our current direction: seeking a more secure, streamlined, and modern solution to replace the dated and problematic medallion system. And we found that blockchain offers exactly what the traditional medallion system lacks.

The Web3 Revolution​

So we've talked at length about the archaic and problematic nature of medallions in the world of financial transactions. But it's not all doom and gloom; in fact, far from it. Enter the Blockchain Revolution —a paradigm shift that promises to change the landscape of financial transactions and security measures, making many of the problems we've discussed virtually obsolete.

What if we told you that there's a way to conduct share transfers that is secure, transparent, and doesn't require you to step foot in a financial institution? What if you could eliminate the multiple checks against stolen stamps, the endless documentation, and, most importantly, the incessant waiting?

Blockchain technology offers all this and more. It's not just a digital ledger; it's a disruptive force that promises to reshape how we think about and conduct financial transactions. And the best part? It aligns perfectly with the fast-paced, digital world we live in today.

Speed​

In a world where everything from messaging to grocery delivery is instant, the snail's pace of traditional share transfers feels like a relic of a bygone era. The inefficiencies we've explored earlier—document collection, appointment scheduling, correspondence mailings—all contribute to unnecessary delays that can cost both time and money.

The remarkable speed of blockchain transactions doesn't happen in a vacuum; it's empowered by advancements in cryptographic techniques, most notably digital signatures. When you electronically authorize a transaction, these tamper-proof cryptographic methods quickly and securely go to work.

In traditional systems like the medallion stamp, security relies on centralized verification—essentially, one entity giving the nod. But blockchain flips this on its head. It relies on distributed networks and sophisticated cryptographic algorithms to confirm transactions. This negates the need for centralized authorities and time-consuming verification steps, such as checking stamps against a list of stolen or misplaced ones.

Here's the real magic: thanks to blockchain technology, your digital signature can be verified in just a matter of seconds. You can visit this class to get into the nitty-gritty of how it all works. Just know that blockchain makes the process both quick and secure, allowing you to make transactions at any time, without the hassle.

The result? Transactions that can happen 24/7, without the delays imposed by "business hours" or manual verification steps. It's as though the technology has torn down the tollbooths on the freeway, allowing for a free flow of secure, immediate transactions. ⏱

Transparency​

Transparency isn't just a buzzword; it's a crucial feature that many traditional financial systems lack. With medallions, once the stamp is applied, the transaction largely disappears into the bureaucratic labyrinth, leaving you to simply trust the process.

In contrast, blockchain offers unparalleled transparency. Each transaction is recorded on a public ledger, accessible to anyone who wants to see it. You can actually track the journey of your transaction from start to finish, witnessing in real time as it gets verified and added to the blockchain.

This level of transparency doesn't just offer peace of mind; it also reduces the risk of fraud and errors. If something doesn't look right, you'll know immediately, not days or weeks later when you finally decipher your account statement.

Transparency is more than just a feature; in the blockchain world, it's a standard. It eliminates the 'black box' nature of traditional financial transactions and replaces it with a clear, traceable path that anyone can follow.

Error Trails​

In traditional systems, the risks associated with reconciliation and verifying share counts are considerable. Centralized databases and physical document storage can make it difficult to track down the paper trail during an audit, increasing the risk of legal repercussions from share count discrepancies.

Blockchain minimizes this risk substantially. A transparent, publicly accessible ledger ensures all transactions and share counts are open for inspection. Auditors can more easily validate records, thereby reducing the risk of audit errors and subsequent legal complications.

Security​

In the realm of financial transactions, security is often the first line of defense against various types of risks, and this is an area where blockchain technology shines. Unlike traditional financial systems that are prone to hacking, data manipulation, and identity theft, blockchain offers a fortified wall of protection.

Firstly, the decentralized nature of blockchain eliminates a central point of failure, inherently reducing the risk of cyber attacks. Each transaction is verified by multiple nodes on the network before it's added to the blockchain, making it extremely difficult for unauthorized alterations. This makes blockchain one of the most secure financial environments out there.

Beyond cyber threats, blockchain also mitigates the risk of identity theft through its multi-layered authentication protocols. This is a significant upgrade over traditional systems that often rely just on usernames and passwords.

One of our early advisors was the CISO of Intercontinental Exchange for two decades, building the organization's whole cyber program from scratch, based on experience founding an ISP in the '90s. He mentioned that people usually have a relatively weak password, but a relatively strong second-factor method (think Google Authenticator). Naturally, authenticating users based solely on that second-factor would be equally secure, and much more efficient.

Without going into the weeds, you secure your Block Transfer account using a completely random string of words written down during onboarding. This "backup phrase," "account certificate," "seed phrase" —whatever you want to call it, we think it's the most secure way to authenticate yourself based on mathematical secrets. Your words never change, which means you can store the credentials in a safe for a lifetime. (Don't worry, we have fallback systems in case of robberies.)

Last but not least, blockchain also addresses the very real risk of data manipulation. Once a transaction is verified and added to the public ledger, it becomes immutable. This feature drastically reduces the chance of data tampering, adding another layer of security and peace of mind to each transaction.

The Takeaway​

As we've journeyed through the limitations of traditional financial systems and the medallion signature guarantees, it's evident that there's plenty of room for improvement. The cumbersome processes, the exorbitant wait times, and the potential for human error are not just inconvenient but also riddled with various risks.

Enter blockchain: the revolution we didn't know we needed but can no longer ignore. With its unparalleled speed, transparency, and most importantly, its robust security features, blockchain is setting new benchmarks for how financial transactions should be conducted. It's not just making things faster; it's making them safer, more transparent, and more equitable for everyone involved.

And that's where we come in. Block Transfer isn’t just another company intrigued by blockchain technology; we are a transfer agent specializing in implementing these blockchain solutions. If you're a CFO of a public American company, understanding and leveraging the potential of blockchain technology should be at the top of your to-do list. And at Block Transfer, we're making it easier than ever to bring this transformative technology into your financial operations. And if you're interested in making your financial operations more secure, efficient, and transparent, it's time to learn more about what we have to offer.

Sources US Patent Application 17/396,742