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Privacy Implications of an Open Banking System in Canada

McMillan | Darcy Ammerman, Mitch Koczerginski, Robbie Grant, Anthony Pallotta | Oct 12, 2021

privacy implications of open banking in Canada - Privacy Implications of an Open Banking System in Canada

Privacy and Open Banking

Since open banking is predicated on the free flow of information, privacy is key to an open banking system. In its February 2019 Review into the Merits of Open Banking, the Committee said “[t]he trust needed to allow the digital economy to flourish, and the social license that organizations will need from Canadians to innovate with their personal data, hinges on having an appropriate legal framework in place that puts at the forefront key privacy issues.” In its January 2020 review of stakeholder submissions, the Committee observed that all stakeholders considered privacy to be a significant risk of open banking. In its own submission to the Committee, the Office of the Privacy Commissioner of Canada (“OPC”) called for several privacy reforms to support an open banking system.

Many of those reforms are already making progress. Before the election was called, the government had introduced a substantive overhaul to Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), in the form of Bill C-11, which would have enacted the Consumer Privacy Protection Act (“CPPA”) (we summarized the proposed changes in a previous bulletin). Bill C-11 died on the order paper when the election was called, but since the liberal government has now returned to office, a new privacy law bill is expected to be forthcoming. There is added international pressure for privacy reforms too, as the EU reviews Canada’s adequacy status under the General Data Protection Regulation (“GDPR”). Maintaining such status is crucial as it permits data processed in accordance with the GDPR to be subsequently transferred from the EU to Canada without requiring additional data protection safeguards or authorization to transfer the data.

See:  Canada’s Library of Parliament Report: A Comparison of Open Banking Recommendations

Meanwhile in Quebec, An Act to modernize legislative provisions as regards the protection of personal information (“Bill 64”) received Royal Assent on September 22, 2021. This Bill amends Quebec’s Act respecting the protection of personal information in the private sector (“Quebec’s Private Sector Act”) to include a data portability right, increased fines for non-compliance, and enhanced requirements for breach notification, consent, and data protection, among other changes.

Data Portability

In its June 2019 report on open banking, the Standing Senate Committee on Banking, Trade and Commerce recommended modernizing PIPEDA to align it with global privacy standards. It wrote that these changes “must include a consumer data portability right.”

In the context of open banking, data portability means a consumer’s right to direct that their personal financial information be shared with another organization. While this sounds simple in theory, it presents challenges for the organization sharing the data (typically the financial institution). First, personal information owned by the consumer is often grouped together with information owned by the sharing organization. For example, financial institutions may create “derived data” by processing consumer information together with proprietary algorithms and analysis. The Final Report takes the position that the financial institution should generally be able to exclude derived data from an open banking system. However, if such data is normally available to the consumer, the financial institution should have an obligation to justify an exclusion.

See: 

Betakit podcast with Senator Deacon on Open Banking and Competition

Reflections on Canada’s open banking report

The second and related challenge is that sharing organizations may store and process data in a variety of formats, but for data portability to be meaningful, the personal information must be shared in a usable technological form. The difference between a string of loose data, and a properly organized spreadsheet is significant to the utility of such information for a third party app developer. Financial institutions can look to Quebec’s Bill 64 as an example of how the concept of data portability could play out in practice. When it comes into force, Bill 64 will amend Quebec’s Private Sector Act to provide consumers with a right to request their computerized personal information in a “structured, commonly used technological format” unless doing so raises serious practical difficulties.

The introduction of a data portability right may require financial institutions to overhaul their data processing systems to ensure consumer data can be shared in a commonly used form, while separating out data that is unnecessary or proprietary to the financial institution. Depending on the sharing organization’s data processing systems, data portability may require significant lead time to implement. The challenges outlined above are likely why the technological format amendment to Quebec’s Private Sector Act does not come into force until September 22, 2024 (a full year after the majority of the amendments).

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NCFA Jan 2018 resize - Privacy Implications of an Open Banking System in Canada The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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The Relationship Between Millenials, Managers, and Leaders

Guest Post | Oct 19, 2021

informal outdoor meeting - The Relationship Between Millenials, Managers, and LeadersHave you been wondering about the differences between managers and leaders? What makes a great manager and a great leader? Do most managers have valuable leadership skills? How about teams and employees who are being managed? Even though expanding businesses need to hire managers, people don’t like to be managed. Especially Millennials who were born from the early 1980s until roughly the end of the 1990s. This doesn’t make managers’ work-life any easier.

These youngsters adapt to changes much faster than the members of their former generations. They have also been raised and socialized in an environment that approves of job-hopping. But before they change the workplace, chances are, a boss or a significant coworker thought they were self-centered, uninspired, entitled, stubborn, lazy, and disloyal. Even if they did their work a bit faster and more effectively than others. But if you think about it, generation Y is taking up half of the entire world’s workforce today. And they are raised to be fast-thinkers, independent, go-getters, and game-changers. This mix of characteristics often makes them move on.

See:  Bracing For Change In The Era Of The Augmented Workforce

If you are a Millennial, you could feel like being managed by a 9-5 factory, even though your resources differ from working in that way. Perhaps, you don’t need an office but can work anywhere with a good Wi-Fi connection.

You don’t only serve one employer, but instead, you have many clients. You don’t only specialize in one field but many. You don’t stay at one place all the time, you are on the move frequently. So why are so many of us still being managed like most of our former generations, who worked in plants?

The answer lies in our history.

Management History and Current Needs 

The idea of making organizations work effectively can be traced back to the time of the Industrial Revolution. Most of us are familiar with the theory of dividing our 24-hour day into three equal parts: 8-hour work, 8-hour recreation, and 8-hour relaxation. Up until the early 1900s management had gained momentum, by the 1950’s we polished management theories. Then, a major shift happened. We started recognizing the fact that focusing on the advancement of products and services isn’t enough anymore. We recognized that knowledge, information, and productivity is the key to our future success.

What does this mean? It means that the old model doesn’t work anymore, and we need to adjust. It’s enough to think in terms of the modern digital workspace, startups, think thanks, and any forms of new ventures today. Where does this path lead? It seems like the next generation will solely rely on knowledge-based entrepreneurial or creative work. So why do some of us still stick to our 9-5 office jobs? Because it is routine, and routine is comfortable. But does it inspire innovation, and getting out of our comfort zone? Not truly.

Changing Work Trends and Adjusted Management Style for our Future Generations

So how could you adjust your management style to our modern work environment? You should start leading by example. Trusting your employees 100 %, providing your team members adequate responsibilities, and resources to meet their targets and deadlines should be the foundation of your business. Inspiring them, and giving them a chance to deliver higher performance, even if you need additional help on your side of management. Give them enough space to breathe, do their best, time to rest, and work from home if they want to.

entrepreneurs with whiteboard - The Relationship Between Millenials, Managers, and Leaders

Photo by Austin Distel on Unsplash

Especially since the pandemic enabled working from home or in a hybrid set-up, we can see more clearly that employees can perform well even working from home if they so wish, as long as they perform quality work in due time. There’s no need to track them closely every hour or day, it would only show our distrust in them. Another crucial thing to consider is letting your employees work out very difficult situations alone. When they need support. It is time to think of ourselves as collaborative elements of business success. Therefore, you should always provide help in times of hardship, or with any issues. The more considerate you can be toward your employees, the better chances you have for growth.

See:  Getting tangible about intangibles: The future of growth and productivity?

People perhaps prefer to go into workplaces more frequently that don’t have a strict feeling, rather they feel like going to a community. Somewhere, their being is appreciated. So what could happen, if you provided your employees' these conditions to excel? They would probably make you more proud through their work. They should get more motivated, more creative, and be able to produce higher quality work with less effort. And change is only possible if we shift our focus from outputs to results.

How To Become A Successful Leader?

You should be focusing on individuals and their unique strengths before any other processes. People can reach big goals with their talents and ambitions if you provide them with the right platform to flourish. Try to learn about the dreams and goals of people in your team, to know who you are working with! This kind of investment can return tenfold. It is possible to get a management position without outstanding leadership skills. However, if you want to become a great leader, you need to develop certain skills. Sometimes the importance of emotional intelligence can be underestimated. This entails self-awareness and self-mastery, having consistency, discipline, thinking long-term, being outgoing, and thriving under pressure.

If you have all these characteristics, great, but it is equally essential to manage and inspire everyone’s emotions, empathy, motivation, and social skills after you manage all these in yourself! Finally, you must understand that you as a leader should make changes to serve your employees' needs to the best you can, and not vice versa! You can only become a true leader that others want to follow by adapting your ways to fit them and not on the contrary! Only by bringing out the best within, can you bring out the best from your team! Best of luck!!


NCFA Jan 2018 resize - The Relationship Between Millenials, Managers, and Leaders The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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As regulators circle above, how should the DeFi industry respond?

Forkast | Adi Ben-Ari | Oct 19, 2021

DeFi at crossroads - As regulators circle above, how should the DeFi industry respond?Recent intervention by regulators in the U.S. and China has made for difficult times for the decentralized finance DeFi sector, but it highlighted again the need to communicate the value that DeFi brings to business and finance, and to allay concerns about the risks.

DeFi is an exciting, rapidly growing corner of the cryptocurrency and blockchain world. It aims to remove human involvement from financial services by using smart contracts that democratize financial services, lower costs and improve access. Its popularity is growing sharply as organizations ranging from startups to traditional banking institutions recognize the value it brings.

Yet, as with all financial services, DeFi is accompanied by risk. The question is: how risky is DeFi and is that risk any greater than elsewhere in the financial services sector?

See:  Decentralized Finance—Risks, Regulation, and the Road Ahead

The regulators evidently see risk. Last month, the U.S. Securities and Exchange Commission (SEC) blocked a new digital asset product from Coinbase called Lend, having determined that it is a security and therefore under its regulatory authority. Later in the month, the People’s Bank of China cracked down on cryptocurrencies and crypto exchanges, declaring that all trading and other activities related to digital coins are illegal.

SEC Chair Gary Gensler commented that “a lot of people are likely to get hurt,” without investor protections of banking, insurance, securities laws and market oversight. His urging of Congress to allow regulators greater oversight of crypto exchanges suggests he wants a much tighter grip.

In China, meanwhile, the government clearly wants greater control as it paves the way for its own central bank digital currency (CBDC), the digital yuan.

Stablecoins support interconnection between DeFi and banking sectors

As Mr. Gensler considers the risks, particularly for small investors, it is incumbent on the DeFi industry to demonstrate that those risks are negligible — and certainly no greater than those elsewhere in the financial services sector.

If stablecoins eliminate the cryptocurrency risk, why all the fuss about them?  First of all, there’s no standardized way for stablecoins to disclose the assets that back them. Second, there are concerns about the providers of stablecoin solutions, private companies such as Tether and Circle, the two largest ones, both of which are under scrutiny over governance.

DeFi link to financial system crucial now, but set to loosen

We see a lot more money going into the tokens than coming out — this is evident in the prices. It looks as though a lot of investors and other organizations wish to stay in the crypto world as longer-term speculation, and to eventually conduct business through it.

See:  Kraken report: Crypto Yields – Deep Dive on DeFi

There are risks in the crossover between DeFi and traditional banking. If you want to cash out of crypto, you have to do so at an exchange — the same as when buying the crypto. The exchange can convert it into dollars or euros, for instance, but that ultimately will be through a traditional bank account. The risk is that the banks can decline their services to crypto exchanges — they have done so before. One reason would be if they don’t know where the money comes from, an important factor as they try to clamp down on money laundering and other nefarious activities.

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NCFA Jan 2018 resize - As regulators circle above, how should the DeFi industry respond? The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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IMF Seminar (On-demand): Digital Money Revolution

IMF Annual Meetings (2021 Washington DC)| Oct 18, 2021

IMF Seminar Digital Money Revolution - IMF Seminar (On-demand):  Digital Money Revolution

Overview of IMF Seminar 'Digital Money Revolution'

Digital finance innovations—central bank digital currencies, private eMoney, stable coins, or cryptoassets—may bring changes in the way we lead our lives. This seminar reviews the implications of this transformation for the international monetary system.

See:  The Impact of Fintech on Central Bank Governance

Moderator: 

  • Martin Wolf is chief economics commentator at the Financial Times, London.

Speakers:

  • Kristalina Georgieva is the Managing Director of the International Monetary Fund (IMF).
  • Benoît Cœuré was appointed Head of the BIS Innovation Hub in 2020.
  • Eswar Prasad is the Tolani Senior Professor of Trade Policy and Professor of Economics at Cornell University.

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NCFA Jan 2018 resize - IMF Seminar (On-demand):  Digital Money Revolution The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Canadian securities regulators seek comment on climate-related disclosure requirements

CSA | Release | Oct 18, 2021

climage change disclosures - Canadian securities regulators seek comment on climate-related disclosure requirementsCalgary and Toronto – The Canadian Securities Administrators (CSA) today published for comment proposed climate-related disclosure requirements. The proposed requirements address the need for more consistent and comparable information to help inform investment decisions. They also demonstrate the CSA’s commitment in favour of the growing international movement toward mandatory climate-related disclosure standards.

The requirements contemplate disclosure largely consistent with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations. They will improve the comparability of the information issuers disclose and help investors make more informed investment decisions by enhancing climate-related disclosure. The requirements are also intended to address costs associated with reporting across multiple disclosure frameworks, improve access to global markets and facilitate an equal playing field for issuers.

See:  The evolution of ESG: Corporate sustainability leaders in the financial services sector are taking on new responsibilities

“We recognize some issuers already share certain climate-related information,” said Louis Morisset, CSA Chair and President and CEO of the Autorité des marchés financiers. “Our proposed requirements will bring those disclosures into a harmonized framework benefitting investors and issuers alike and aligning Canadian capital markets with the global movement towards consistent and comparable standards.”

The proposed requirements contemplate disclosure by issuers related to the four core elements of the TCFD recommendations:

  • Governance – an issuer’s board’s oversight of and management’s role in assessing and managing climate-related risks and opportunities.
  • Strategy – the short-, medium- and long-term climate-related risks and opportunities the issuer has identified and the impact on its business, strategy and financial planning, where such information is material. As a modification from the TCFD recommendations, the proposed disclosure would not include the requirement to disclose “scenario analysis”, which is an issuer’s description of the resilience of its strategy within different climate-related scenarios, including a 2°C or lower scenario.
  • Risk management – how an issuer identifies, assesses and manages climate-related risks and how these processes are integrated into its overall risk management.
  • Metrics and targets – the metrics and targets used by an issuer to assess and manage climate-related risks and opportunities where the information is material.

See:  Regulators target “greenwashed” products susceptible to marketing hype

Issuers would be required to disclose their Scope 1, Scope 2 and Scope 3 greenhouse gas (GHG) emissions and the related risks, or their reasons for not doing so. The CSA is also consulting on an alternative approach that would require issuers to disclose Scope 1 GHG emissions. Under this alternative, disclosure of Scope 2 and Scope 3 GHG emissions would not be mandatory.

“With global momentum building on sustainability-related disclosures in both the public and private sectors, these proposals reflect our vision and expectations for reporting issuers as we move towards a global baseline for such disclosures,” said Morisset.

The disclosure requirements would be phased in, as outlined in the notice, to give companies sufficient time to plan for implementation.

The proposed disclosure requirements draw on extensive engagement with stakeholders, follow environmental and climate-related reporting guidance issued by the CSA in 2010 and build on CSA Staff Notice 51-358 Reporting of Climate Change-related Risks published in August 2019.

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NCFA Jan 2018 resize - Canadian securities regulators seek comment on climate-related disclosure requirements The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Foreign property tax implications associated with owning cryptocurrencies

Financial Post | Jamie Golombek | Oct 14, 2021

Crypto taxes - Foreign property tax implications associated with owning cryptocurrenciesWhere, exactly, is your cryptocurrency located? It's complicated

If you hold foreign property whose total cost exceeds $100,000 at any point in a tax year, you’re required to file Form T1135. The form covers the obvious things, such as your Swiss bank account or Cayman offshore investment portfolio, but it’s also required for foreign stocks, such as Apple Inc., Microsoft Corp. or Google owner Alphabet Inc., that are held in a Canadian, non-registered brokerage account.

The penalty for filing late is $25 per day to a maximum of $2,500, plus arrears interest. There have been at least 20 reported cases in which taxpayers have been assessed a late-filing penalty since the 1998 introduction of Form T1135.

Is cryptocurrency considered foreign property?

Those questions were discussed in a recent article by William Musani and Ashvin Singh of Felesky Flynn LLP, a boutique tax law firm with offices in Alberta and Saskatchewan. They analyzed whether cryptocurrency falls under the technical definition of “specified foreign property” in the Income Tax Act, which includes “intangible property situated, deposited, or held outside Canada that is not used or held exclusively in the course of carrying on an active business of the taxpayer.”

Back in 2015, the CRA stated that “digital currency would be funds or intangible property and would be specified foreign property of a person or partnership to the extent that it is situated, deposited or held outside of Canada.”

See:  Proposed Amendments to the GST/HST Treatment of Cryptocurrencies

But where, exactly, is your cryptocurrency located?

In practice, an entitlement to your cryptocurrency exists in the form of a digital ledger on the related blockchain. But because it’s stored on a blockchain, it can simultaneously exist in several geographic locations.

These digital ledgers are considered both “distributed” and “decentralized” databases. The database that records the entitlements of a cryptocurrency holder is stored and updated in many locations at once — that is, distributed — which makes it difficult, if not impossible, to manipulate its records. The ledgers are also decentralized, since no single distributed database is the sole source of the true ownership of the particular cryptocurrency.

The article’s authors argue that in relation to the location of your cryptocurrency holdings:

The geographic location of your private key is “arguably the most relevant factor in determining where such cryptocurrency is situated, deposited, or held for the purposes of the act.”

See:  Miami mayor says the city is moving toward paying public employees in bitcoin

But the answer to this may depend on whether you are using a “hot” or “cold” digital wallet. Hot wallets are digital wallets connected to the internet, which is how nearly all cryptocurrency exchanges or online providers store your cryptocurrency.

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NCFA Jan 2018 resize - Foreign property tax implications associated with owning cryptocurrencies The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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CFTC fines Tether US$41M for misleading claims about currency backing

Bloomberg | Jesse Westbrook | Oct 15, 2021

Tether fined 41M - CFTC fines Tether US$41M for misleading claims about currency backingTether will pay US$41 million to settle allegations it lied in claiming its digital tokens were fully backed by fiat currencies, putting a major compliance headache behind the world’s biggest issuer of stablecoins even as regulatory scrutiny intensifies.

For years, Tether told customers and the broader cryptocurrency market that it had US$1 in reserve to back every token, the Commodity Futures Trading Commission said in a Friday statement. That claim was wildly misleading, according to the agency. For instance, from June to September 2017, there was never more than US$61.5 million backing Tether, even as more 442 million coins were circulating at one point.

Read:  Tether banned on Canada’s first 2 licensed digital currency exchanges

“This case highlights the expectation of honesty and transparency in the rapidly growing and developing digital assets marketplace,” said acting CFTC Chairman Rostin Behnam.

Tether is widely used to trade Bitcoin and other tokens, making it pivotal to the crypto market. That’s because the coin allows quick transactions and because it’s designed to be largely immune to volatile price swings -- a function of its one-to-one peg to fiat currencies.

But many traders have long been skeptical that Tether genuinely had the money backing the coins that it claimed. More recently, the Treasury Department and other federal agencies have been alarmed by the stablecoin’s dramatic growth. There are now Tethers worth about US$69 billion in circulation, prompting concerns among that crypto-market disruptions could trigger chaotic investor fire sales that threaten the financial system.

In its enforcement action, the CFTC said Tether failed to disclose that it held unsecured receivables and non-fiat assets as part of its reserves, and falsely told investors it would undergo routine, professional audits to demonstrate that it maintained “100 per cent reserves at all times.”

See:  Is Tether a Black Swan?

In fact, Tether reserves weren’t audited, the agency said. Until at least 2018, Tether manually kept tabs on its reserve levels, a process that wasn’t updated in real time, the CFTC said. Tether didn’t admit or deny the CFTC’s allegations.

“Tether agreed to resolve this matter in order to move forward and focus on the future,” the company said in a statement posted on its website.

Continue to the full article --> here

 


NCFA Jan 2018 resize - CFTC fines Tether US$41M for misleading claims about currency backing The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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