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Summary: Everyone knows that when you give your assets to someone else, they always keep them safe. If this is true for individuals, it is certainly true for businesses.
Custodians always tell the truth and manage funds properly. They won't have any interest in taking the assets as an exchange operator would. Auditors tell the truth and can't be misled. That's because organizations that are regulated are incapable of lying and don't make mistakes.
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First, some background. Here is a summary of how custodians make us more secure:
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Previously, we might give Alice our crypto assets to hold. There were risks:

• Alice might take the assets and disappear.
• Alice might spend the assets and pretend that she still has them (fractional model).
• Alice might store the assets insecurely and they'll get stolen.
• Alice might give the assets to someone else by mistake or by force.
• Alice might lose access to the assets.

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But "no worries", Alice has a custodian named Bob. Bob is dressed in a nice suit. He knows some politicians. And he drives a Porsche. "So you have nothing to worry about!". And look at all the benefits we get:

• Alice can't take the assets and disappear (unless she asks Bob or never gives them to Bob).
• Alice can't spend the assets and pretend that she still has them. (Unless she didn't give them to Bob or asks him for them.)
• Alice can't store the assets insecurely so they get stolen. (After all - she doesn't have any control over the withdrawal process from any of Bob's systems, right?)
• Alice can't give the assets to someone else by mistake or by force. (Bob will stop her, right Bob?)
• Alice can't lose access to the funds. (She'll always be present, sane, and remember all secrets, right?)

See - all problems are solved! All we have to worry about now is:

• Bob might take the assets and disappear.
• Bob might spend the assets and pretend that he still has them (fractional model).
• Bob might store the assets insecurely and they'll get stolen.
• Bob might give the assets to someone else by mistake or by force.
• Bob might lose access to the assets.

It's pretty simple. Before we had to trust Alice. Now we only have to trust Alice, Bob, and all the ways in which they communicate. Just think of how much more secure we are!
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"On top of that", Bob assures us, "we're using a special wallet structure". Bob shows Alice a diagram. "We've broken the balance up and store it in lots of smaller wallets. That way", he assures her, "a thief can't take it all at once". And he points to a historic case where a large sum was taken "because it was stored in a single wallet... how stupid".
"Very early on, we used to have all the crypto in one wallet", he said, "and then one Christmas a hacker came and took it all. We call him the Grinch. Now we individually wrap each crypto and stick it under a binary search tree. The Grinch has never been back since."
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"As well", Bob continues, "even if someone were to get in, we've got insurance. It covers all thefts and even coercion, collusion, and misplaced keys - only subject to the policy terms and conditions." And with that, he pulls out a phone-book sized contract and slams it on the desk with a thud. "Yep", he continues, "we're paying top dollar for one of the best policies in the country!"
"Can I read it?' Alice asks. "Sure," Bob says, "just as soon as our legal team is done with it. They're almost through the first chapter." He pauses, then continues. "And can you believe that sales guy Mike? He has the same year Porsche as me. I mean, what are the odds?"
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"Do you use multi-sig?", Alice asks. "Absolutely!" Bob replies. "All our engineers are fully trained in multi-sig. Whenever we want to set up a new wallet, we generate 2 separate keys in an air-gapped process and store them in this proprietary system here. Look, it even requires the biometric signature from one of our team members to initiate any withdrawal." He demonstrates by pressing his thumb into the display. "We use a third-party cloud validation API to match the thumbprint and authorize each withdrawal. The keys are also backed up daily to an off-site third-party."
"Wow that's really impressive," Alice says, "but what if we need access for a withdrawal outside of office hours?" "Well that's no issue", Bob says, "just send us an email, call, or text message and we always have someone on staff to help out. Just another part of our strong commitment to all our customers!"
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"What about Proof of Reserve?", Alice asks. "Of course", Bob replies, "though rather than publish any blockchain addresses or signed transaction, for privacy we just do a SHA256 refactoring of the inverse hash modulus for each UTXO nonce and combine the smart contract coefficient consensus in our hyperledger lightning node. But it's really simple to use." He pushes a button and a large green checkmark appears on a screen. "See - the algorithm ran through and reserves are proven."
"Wow", Alice says, "you really know your stuff! And that is easy to use! What about fiat balances?" "Yeah, we have an auditor too", Bob replies, "Been using him for a long time so we have quite a strong relationship going! We have special books we give him every year and he's very efficient! Checks the fiat, crypto, and everything all at once!"
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"We used to have a nice offline multi-sig setup we've been using without issue for the past 5 years, but I think we'll move all our funds over to your facility," Alice says. "Awesome", Bob replies, "Thanks so much! This is perfect timing too - my Porsche got a dent on it this morning. We have the paperwork right over here." "Great!", Alice replies.
And with that, Alice gets out her pen and Bob gets the contract. "Don't worry", he says, "you can take your crypto-assets back anytime you like - just subject to our cancellation policy. Our annual management fees are also super low and we don't adjust them often".
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How many holes have to exist for your funds to get stolen?
Just one.
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Why are we taking a powerful offline multi-sig setup, widely used globally in hundreds of different/lacking regulatory environments with 0 breaches to date, and circumventing it by a demonstrably weak third party layer? And paying a great expense to do so?
If you go through the list of breaches in the past 2 years to highly credible organizations, you go through the list of major corporate frauds (only the ones we know about), you go through the list of all the times platforms have lost funds, you go through the list of times and ways that people have lost their crypto from identity theft, hot wallet exploits, extortion, etc... and then you go through this custodian with a fine-tooth comb and truly believe they have value to add far beyond what you could, sticking your funds in a wallet (or set of wallets) they control exclusively is the absolute worst possible way to take advantage of that security.
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The best way to add security for crypto-assets is to make a stronger multi-sig. With one custodian, what you are doing is giving them your cryptocurrency and hoping they're honest, competent, and flawlessly secure. It's no different than storing it on a really secure exchange. Maybe the insurance will cover you. Didn't work for Bitpay in 2015. Didn't work for Yapizon in 2017. Insurance has never paid a claim in the entire history of cryptocurrency. But maybe you'll get lucky. Maybe your exact scenario will buck the trend and be what they're willing to cover. After the large deductible and hopefully without a long and expensive court battle.
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And you want to advertise this increase in risk, the lapse of judgement, an accident waiting to happen, as though it's some kind of benefit to customers ("Free institutional-grade storage for your digital assets.")? And then some people are writing to the OSC that custodians should be mandatory for all funds on every exchange platform? That this somehow will make Canadians as a whole more secure or better protected compared with standard air-gapped multi-sig? On what planet?
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Most of the problems in Canada stemmed from one thing - a lack of transparency. If Canadians had known what a joke Quadriga was - it wouldn't have grown to lose $400m from hard-working Canadians from coast to coast to coast. And Gerald Cotten would be in jail, not wherever he is now (at best, rotting peacefully). EZ-BTC and mister Dave Smilie would have been a tiny little scam to his friends, not a multi-million dollar fraud. Einstein would have got their act together or been shut down BEFORE losing millions and millions more in people's funds generously donated to criminals. MapleChange wouldn't have even been a thing. And maybe we'd know a little more about CoinTradeNewNote - like how much was lost in there. Almost all of the major losses with cryptocurrency exchanges involve deception with unbacked funds.
So it's great to see transparency reports from BitBuy and ShakePay where someone independently verified the backing. The only thing we don't have is:

• ANY CERTAINTY BALANCES WEREN'T EXCLUDED. Quadriga's largest account was $70m. 80% of funds are in 20% of accounts (Pareto principle). All it takes is excluding a few really large accounts - and nobody's the wiser. A fractional platform can easily pass any audit this way.
• ANY VISIBILITY WHATSOEVER INTO THE CUSTODIANS. BitBuy put out their report before moving all the funds to their custodian and ShakePay apparently can't even tell us who the custodian is. That's pretty important considering that basically all of the funds are now stored there.
• ANY IDEA ABOUT THE OTHER EXCHANGES. In order for this to be effective, it has to be the norm. It needs to be "unusual" not to know. If obscurity is the norm, then it's super easy for people like Gerald Cotten and Dave Smilie to blend right in.

It's not complicated to validate cryptocurrency assets. They need to exist, they need to be spendable, and they need to cover the total balances. There are plenty of credible people and firms across the country that have the capacity to reasonably perform this validation. Having more frequent checks by different, independent, parties who publish transparent reports is far more valuable than an annual check by a single "more credible/official" party who does the exact same basic checks and may or may not publish anything. Here's an example set of requirements that could be mandated:

• First report within 1 month of launching, another within 3 months, and further reports at minimum every 6 months thereafter.
• No auditor can be repeated within a 12 month period.
• All reports must be public, identifying the auditor and the full methodology used.
• All auditors must be independent of the firm being audited with no conflict of interest.
• Reports must include the percentage of each asset backed, and how it's backed.
• The auditor publishes a hash list, which lists a hash of each customer's information and balances that were included. Hash is one-way encryption so privacy is fully preserved. Every customer can use this to have 100% confidence they were included.
• If we want more extensive requirements on audits, these should scale upward based on the total assets at risk on the platform, and whether the platform has loaned their assets out.

There are ways to structure audits such that neither crypto assets nor customer information are ever put at risk, and both can still be properly validated and publicly verifiable. There are also ways to structure audits such that they are completely reasonable for small platforms and don't inhibit innovation in any way. By making the process as reasonable as possible, we can completely eliminate any reason/excuse that an honest platform would have for not being audited. That is arguable far more important than any incremental improvement we might get from mandating "the best of the best" accountants. Right now we have nothing mandated and tons of Canadians using offshore exchanges with no oversight whatsoever.
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Transparency does not prove crypto assets are safe. CoinTradeNewNote, Flexcoin ($600k), and Canadian Bitcoins ($100k) are examples where crypto-assets were breached from platforms in Canada. All of them were online wallets and used no multi-sig as far as any records show. This is consistent with what we see globally - air-gapped multi-sig wallets have an impeccable record, while other schemes tend to suffer breach after breach. We don't actually know how much CoinTrader lost because there was no visibility. Rather than publishing details of what happened, the co-founder of CoinTrader silently moved on to found another platform - the "most trusted way to buy and sell crypto" - a site that has no information whatsoever (that I could find) on the storage practices and a FAQ advising that “[t]rading cryptocurrency is completely safe” and that having your own wallet is “entirely up to you! You can certainly keep cryptocurrency, or fiat, or both, on the app.” Doesn't sound like much was learned here, which is really sad to see.
It's not that complicated or unreasonable to set up a proper hardware wallet. Multi-sig can be learned in a single course. Something the equivalent complexity of a driver's license test could prevent all the cold storage exploits we've seen to date - even globally. Platform operators have a key advantage in detecting and preventing fraud - they know their customers far better than any custodian ever would. The best job that custodians can do is to find high integrity individuals and train them to form even better wallet signatories. Rather than mandating that all platforms expose themselves to arbitrary third party risks, regulations should center around ensuring that all signatories are background-checked, properly trained, and using proper procedures. We also need to make sure that signatories are empowered with rights and responsibilities to reject and report fraud. They need to know that they can safely challenge and delay a transaction - even if it turns out they made a mistake. We need to have an environment where mistakes are brought to the surface and dealt with. Not one where firms and people feel the need to hide what happened. In addition to a knowledge-based test, an auditor can privately interview each signatory to make sure they're not in coercive situations, and we should make sure they can freely and anonymously report any issues without threat of retaliation.
A proper multi-sig has each signature held by a separate person and is governed by policies and mutual decisions instead of a hierarchy. It includes at least one redundant signature. For best results, 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7.
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History has demonstrated over and over again the risk of hot wallets even to highly credible organizations. Nonetheless, many platforms have hot wallets for convenience. While such losses are generally compensated by platforms without issue (for example Poloniex, Bitstamp, Bitfinex, Gatecoin, Coincheck, Bithumb, Zaif, CoinBene, Binance, Bitrue, Bitpoint, Upbit, VinDAX, and now KuCoin), the public tends to focus more on cases that didn't end well. Regardless of what systems are employed, there is always some level of risk. For that reason, most members of the public would prefer to see third party insurance.
Rather than trying to convince third party profit-seekers to provide comprehensive insurance and then relying on an expensive and slow legal system to enforce against whatever legal loopholes they manage to find each and every time something goes wrong, insurance could be run through multiple exchange operators and regulators, with the shared interest of having a reputable industry, keeping costs down, and taking care of Canadians. For example, a 4 of 7 multi-sig insurance fund held between 5 independent exchange operators and 2 regulatory bodies. All Canadian exchanges could pay premiums at a set rate based on their needed coverage, with a higher price paid for hot wallet coverage (anything not an air-gapped multi-sig cold wallet). Such a model would be much cheaper to manage, offer better coverage, and be much more reliable to payout when needed. The kind of coverage you could have under this model is unheard of. You could even create something like the CDIC to protect Canadians who get their trading accounts hacked if they can sufficiently prove the loss is legitimate. In cases of fraud, gross negligence, or insolvency, the fund can be used to pay affected users directly (utilizing the last transparent balance report in the worst case), something which private insurance would never touch. While it's recommended to have official policies for coverage, a model where members vote would fully cover edge cases. (Could be similar to the Supreme Court where justices vote based on case law.)
Such a model could fully protect all Canadians across all platforms. You can have a fiat coverage governed by legal agreements, and crypto-asset coverage governed by both multi-sig and legal agreements. It could be practical, affordable, and inclusive.
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Now, we are at a crossroads. We can happily give up our freedom, our innovation, and our money. We can pay hefty expenses to auditors, lawyers, and regulators year after year (and make no mistake - this cost will grow to many millions or even billions as the industry grows - and it will be borne by all Canadians on every platform because platforms are not going to eat up these costs at a loss). We can make it nearly impossible for any new platform to enter the marketplace, forcing Canadians to use the same stagnant platforms year after year. We can centralize and consolidate the entire industry into 2 or 3 big players and have everyone else fail (possibly to heavy losses of users of those platforms). And when a flawed security model doesn't work and gets breached, we can make it even more complicated with even more people in suits making big money doing the job that blockchain was supposed to do in the first place. We can build a system which is so intertwined and dependent on big government, traditional finance, and central bankers that it's future depends entirely on that of the fiat system, of fractional banking, and of government bail-outs. If we choose this path, as history has shown us over and over again, we can not go back, save for revolution. Our children and grandchildren will still be paying the consequences of what we decided today.
Or, we can find solutions that work. We can maintain an open and innovative environment while making the adjustments we need to make to fully protect Canadian investors and cryptocurrency users, giving easy and affordable access to cryptocurrency for all Canadians on the platform of their choice, and creating an environment in which entrepreneurs and problem solvers can bring those solutions forward easily. None of the above precludes innovation in any way, or adds any unreasonable cost - and these three policies would demonstrably eliminate or resolve all 109 historic cases as studied here - that's every single case researched so far going back to 2011. It includes every loss that was studied so far not just in Canada but globally as well.
Unfortunately, finding answers is the least challenging part. Far more challenging is to get platform operators and regulators to agree on anything. My last post got no response whatsoever, and while the OSC has told me they're happy for industry feedback, I believe my opinion alone is fairly meaningless. This takes the whole community working together to solve. So please let me know your thoughts. Please take the time to upvote and share this with people. Please - let's get this solved and not leave it up to other people to do.
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Facts/background/sources (skip if you like):

• The inspiration for the paragraph about splitting wallets was an actual quote from a Canadian company providing custodial services in response to the OSC consultation paper: "We believe that it will be in the in best interests of investors to prohibit pooled crypto assets or ‘floats’. Most Platforms pool assets, citing reasons of practicality and expense. The recent hack of the world’s largest Platform – Binance – demonstrates the vulnerability of participants’ assets when such concessions are made. In this instance, the Platform’s entire hot wallet of Bitcoins, worth over $40 million, was stolen, facilitated in part by the pooling of client crypto assets." "the maintenance of participants (and Platform) crypto assets across multiple wallets distributes the related risk and responsibility of security - reducing the amount of insurance coverage required and making insurance coverage more readily obtainable". For the record, their reply also said nothing whatsoever about multi-sig or offline storage.
• In addition to the fact that the $40m hack represented only one "hot wallet" of Binance, and they actually had the vast majority of assets in other wallets (including mostly cold wallets), multiple real cases have clearly demonstrated that risk is still present with multiple wallets. Bitfinex, VinDAX, Bithumb, Altsbit, BitPoint, Cryptopia, and just recently KuCoin all had multiple wallets breached all at the same time, and may represent a significantly larger impact on customers than the Binance breach which was fully covered by Binance. To represent that simply having multiple separate wallets under the same security scheme is a comprehensive way to reduce risk is just not true.
• Private insurance has historically never covered a single loss in the cryptocurrency space (at least, not one that I was able to find), and there are notable cases where massive losses were not covered by insurance. Bitpay in 2015 and Yapizon in 2017 both had insurance policies that didn't pay out during the breach, even after a lengthly court process. The same insurance that ShakePay is presently using (and announced to much fanfare) was describe by their CEO himself as covering “physical theft of the media where the private keys are held,” which is something that has never historically happened. As was said with regard to the same policy in 2018 - “I don’t find it surprising that Lloyd’s is in this space,” said Johnson, adding that to his mind the challenge for everybody is figuring out how to structure these policies so that they are actually protective. “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
• The most profitable policy for a private insurance company is one with the most expensive premiums that they never have to pay a claim on. They have no inherent incentive to take care of people who lost funds. It's "cheaper" to take the reputational hit and fight the claim in court. The more money at stake, the more the insurance provider is incentivized to avoid payout. They're not going to insure the assets unless they have reasonable certainty to make a profit by doing so, and they're not going to pay out a massive sum unless it's legally forced. Private insurance is always structured to be maximally profitable to the insurance provider.
• The circumvention of multi-sig was a key factor in the massive Bitfinex hack of over $60m of bitcoin, which today still sits being slowly used and is worth over $3b. While Bitfinex used a qualified custodian Bitgo, which was and still is active and one of the industry leaders of custodians, and they set up 2 of 3 multi-sig wallets, the entire system was routed through Bitfinex, such that Bitfinex customers could initiate the withdrawals in a "hot" fashion. This feature was also a hit with the hacker. The multi-sig was fully circumvented.
• Bitpay in 2015 was another example of a breach that stole 5,000 bitcoins. This happened not through the exploit of any system in Bitpay, but because the CEO of a company they worked with got their computer hacked and the hackers were able to request multiple bitcoin purchases, which Bitpay honoured because they came from the customer's computer legitimately. Impersonation is a very common tactic used by fraudsters, and methods get more extreme all the time.
• A notable case in Canada was the Canadian Bitcoins exploit. Funds were stored on a server in a Rogers Data Center, and the attendee was successfully convinced to reboot the server "in safe mode" with a simple phone call, thus bypassing the extensive security and enabling the theft.
• Over $200m has been stolen impersonating users of cryptocurrency platforms by one group alone. Here's a list of 10 social engineering attacks against corporate companies. Here's an even larger case. While verification methods are improving, so are methods of identity theft and social engineering. We now have sim swapping and deep fake videos to contend with. Hackers have massive database sets of personal information they can utilize. As the sums at stake increase, so to will the level of effort criminals are willing to undertake. Obscurity for an insecure system will only postpone an attack until the "jackpot" is large enough.
• The very nature of custodians circumvents multi-sig. This is because custodians are not just having to secure the assets against some sort of physical breach but against any form of social engineering, modification of orders, fraudulent withdrawal attempts, etc... If the security practices of signatories in a multi-sig arrangement are such that the breach risk of one signatory is 1 in 100, the requirement of 3 independent signatures makes the risk of theft 1 in 1,000,000. Since hackers tend to exploit the weakest link, a comparable custodian has to make the entry and exit points of their platform 10,000 times more secure than one of those signatories to provide equivalent protection. And if the signatories beef up their security by only 10x, the risk is now 1 in 1,000,000,000. The custodian has to be 1,000,000 times more secure. The larger and more complex a system is, the more potential vulnerabilities exist in it, and the fewer people can understand how the system works when performing upgrades. Even if a system is completely secure today, one has to also consider how that system might evolve over time or work with different members.
• By contrast, offline multi-signature solutions have an extremely solid record, and in the entire history of cryptocurrency exchange incidents which I've studied (listed here), there has only been one incident (796 exchange in 2015) involving an offline multi-signature wallet. It happened because the customer's bitcoin address was modified by hackers, and the amount that was stolen ($230k) was immediately covered by the exchange operators. Basically, the platform operators were tricked into sending a legitimate withdrawal request to the wrong address because hackers exploited their platform to change that address. Such an issue would not be prevented in any way by the use of a custodian, as that custodian has no oversight whatsoever to the exchange platform. It's practical for all exchange operators to test large withdrawal transactions as a general policy, regardless of what model is used, and general best practice is to diagnose and fix such an exploit as soon as it occurs.
• False promises on the backing of funds played a huge role in the downfall of Quadriga, and it's been exposed over and over again (MyCoin, PlusToken, Bitsane, Bitmarket, EZBTC, IDAX). Even today, customers have extremely limited certainty on whether their funds in exchanges are actually being backed or how they're being backed. While this issue is not unique to cryptocurrency exchanges, the complexity of the technology and the lack of any regulation or standards makes problems more widespread, and there is no "central bank" to come to the rescue as in the 2008 financial crisis or during the great depression when "9,000 banks failed".
• In addition to fraudulent operations, the industry is full of cases where operators have suffered breaches and not reported them. Most recently, Einstein was the largest case in Canada, where ongoing breaches and fraud were perpetrated against the platform for multiple years and nobody found out until the platform collapsed completely. While fraud and breaches suck to deal with, they suck even more when not dealt with. Lack of visibility played a role in the largest downfalls of Mt. Gox, Cryptsy, and Bitgrail. In some cases, platforms are alleged to have suffered a hack and keep operating without admitting it at all, such as CoinBene.
• It surprises some to learn that a cryptographic solution has already existed since 2013, and gained widespread support in 2014 after Mt. Gox. Proof of Reserves is a full cryptographic proof that allows any customer using an exchange to have complete certainty that their crypto-assets are fully backed by the platform in real-time. This is accomplished by proving that assets exist on the blockchain, are spendable, and fully cover customer deposits. It does not prove safety of assets or backing of fiat assets.
  • If we didn't care about privacy at all, a platform could publish their wallet addresses, sign a partial transaction, and put the full list of customer information and balances out publicly. Customers can each check that they are on the list, that the balances are accurate, that the total adds up, and that it's backed and spendable on the blockchain. Platforms who exclude any customer take a risk because that customer can easily check and see they were excluded. So together with all customers checking, this forms a full proof of backing of all crypto assets.
  • However, obviously customers care about their private information being published. Therefore, a hash of the information can be provided instead. Hash is one-way encryption. The hash allows the customer to validate inclusion (by hashing their own known information), while anyone looking at the list of hashes cannot determine the private information of any other user. All other parts of the scheme remain fully intact. A model like this is in use on the exchange CoinFloor in the UK.
  • A Merkle tree can provide even greater privacy. Instead of a list of balances, the balances are arranged into a binary tree. A customer starts from their node, and works their way to the top of the tree. For example, they know they have 5 BTC, they plus 1 other customer hold 7 BTC, they plus 2-3 other customers hold 17 BTC, etc... until they reach the root where all the BTC are represented. Thus, there is no way to find the balances of other individual customers aside from one unidentified customer in this case.
• Proposals such as this had the backing of leaders in the community including Nic Carter, Greg Maxwell, and Zak Wilcox. Substantial and significant effort started back in 2013, with massive popularity in 2014. But what became of that effort? Very little. Exchange operators continue to refuse to give visibility. Despite the fact this information can often be obtained through trivial blockchain analysis, no Canadian platform has ever provided any wallet addresses publicly. As described by the CEO of Newton "For us to implement some kind of realtime Proof of Reserves solution, which I'm not opposed to, it would have to ... Preserve our users' privacy, as well as our own. Some kind of zero-knowledge proof". Kraken describes here in more detail why they haven't implemented such a scheme. According to professor Eli Ben-Sasson, when he spoke with exchanges, none were interested in implementing Proof of Reserves.
• And yet, Kraken's places their reasoning on a page called "Proof of Reserves". More recently, both BitBuy and ShakePay have released reports titled "Proof of Reserves and Security Audit". Both reports contain disclaimers against being audits. Both reports trust the customer list provided by the platform, leaving the open possibility that multiple large accounts could have been excluded from the process. Proof of Reserves is a blockchain validation where customers see the wallets on the blockchain. The report from Kraken is 5 years old, but they leave it described as though it was just done a few weeks ago. And look at what they expect customers to do for validation. When firms represent something being "Proof of Reserve" when it's not, this is like a farmer growing fruit with pesticides and selling it in a farmers market as organic produce - except that these are people's hard-earned life savings at risk here. Platforms are misrepresenting the level of visibility in place and deceiving the public by their misuse of this term. They haven't proven anything.
• Fraud isn't a problem that is unique to cryptocurrency. Fraud happens all the time. Enron, WorldCom, Nortel, Bear Stearns, Wells Fargo, Moser Baer, Wirecard, Bre-X, and Nicola are just some of the cases where frauds became large enough to become a big deal (and there are so many countless others). These all happened on 100% reversible assets despite regulations being in place. In many of these cases, the problems happened due to the over-complexity of the financial instruments. For example, Enron had "complex financial statements [which] were confusing to shareholders and analysts", creating "off-balance-sheet vehicles, complex financing structures, and deals so bewildering that few people could understand them". In cryptocurrency, we are often combining complex financial products with complex technologies and verification processes. We are naïve if we think problems like this won't happen. It is awkward and uncomfortable for many people to admit that they don't know how something works. If we want "money of the people" to work, the solutions have to be simple enough that "the people" can understand them, not so confusing that financial professionals and technology experts struggle to use or understand them.
• For those who question the extent to which an organization can fool their way into a security consultancy role, HB Gary should be a great example to look at. Prior to trying to out anonymous, HB Gary was being actively hired by multiple US government agencies and others in the private sector (with glowing testimonials). The published articles and hosted professional security conferences. One should also look at this list of data breaches from the past 2 years. Many of them are large corporations, government entities, and technology companies. These are the ones we know about. Undoubtedly, there are many more that we do not know about. If HB Gary hadn't been "outted" by anonymous, would we have known they were insecure? If the same breach had happened outside of the public spotlight, would it even have been reported? Or would HB Gary have just deleted the Twitter posts, brought their site back up, done a couple patches, and kept on operating as though nothing had happened?
• In the case of Quadriga, the facts are clear. Despite past experience with platforms such as MapleChange in Canada and others around the world, no guidance or even the most basic of a framework was put in place by regulators. By not clarifying any sort of legal framework, regulators enabled a situation where a platform could be run by former criminal Mike Dhanini/Omar Patryn, and where funds could be held fully unchecked by one person. At the same time, the lack of regulation deterred legitimate entities from running competing platforms and Quadriga was granted a money services business license for multiple years of operation, which gave the firm the appearance of legitimacy. Regulators did little to protect Canadians despite Quadriga failing to file taxes from 2016 onward. The entire administrative team had resigned and this was public knowledge. Many people had suspicions of what was going on, including Ryan Mueller, who forwarded complaints to the authorities. These were ignored, giving Gerald Cotten the opportunity to escape without justice.
• There are multiple issues with the SOC II model including the prohibitive cost (you have to find a third party accounting firm and the prices are not even listed publicly on any sites), the requirement of operating for a year (impossible for new platforms), and lack of any public visibility (SOC II are private reports that aren't shared outside the people in suits).
• Securities frameworks are expensive. Sarbanes-Oxley is estimated to cost $5.1 million USD/yr for the average Fortune 500 company in the United States. Since "Fortune 500" represents the top 500 companies, that means well over $2.55 billion USD (~$3.4 billion CAD) is going to people in suits. Isn't the problem of trust and verification the exact problem that the blockchain is supposed to solve?
• To use Quadriga as justification for why custodians or SOC II or other advanced schemes are needed for platforms is rather silly, when any framework or visibility at all, or even the most basic of storage policies, would have prevented the whole thing. It's just an embarrassment.
• We are now seeing regulators take strong action. CoinSquare in Canada with multi-million dollar fines. BitMex from the US, criminal charges and arrests. OkEx, with full disregard of withdrawals and no communication. Who's next?
• We have a unique window today where we can solve these problems, and not permanently destroy innovation with unreasonable expectations, but we need to act quickly. This is a unique historic time that will never come again.

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Thoughts?

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In case you haven't noticed the consultation paper, staff notice, and report on Quadriga, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
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• This framework was developed through a study of 96 past exchange hack/scam/fraud events. It prevents all historic cases where funds were lost in cryptocurrency exchanges.
• Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
• Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.

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Many of you have limited time to read the full proposal, so here are the highlights:

Offline Multi-Signature

Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.

Regular Transparent Audits

Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.

Insurance Requirements

Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
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Background and Justifications

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Cold Storage Custody/Management
After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems:
• Funds stored online or in a smart contract,
• Access controlled by one person or one system,
• 51% attacks (rare),
• Funds sent to the wrong address (also rare), or
• Some combination of the above.
For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program.
The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms.
• 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective.
• The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated.
The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II.
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On The Subject of Third Party Custodians
Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems.
However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies.
There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both.
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On The Subject Of Insurance
ShakePay has taken the first steps into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC.
However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example, the insurance agent refused because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange in South Korea, their insurance claim was denied, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
ShakePay's insurance was only reported to cover their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline[] to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance.
In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework.
A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians.
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On The Subject of Fractional Reserve
There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds.
There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past.
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Proof of Reserves/Transparency/Accountability
Canadians need to have visibility into the backing on an ongoing basis.
The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users.
Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit.
The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided.
Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense.
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Hot Wallet Management
The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets.
However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process.
A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage.
Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
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Current Draft Proposal

(1) Proper multi-signature cold wallet storage.
(a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet.
(b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time).
(c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7.
(d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds.
(e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers.
(2) Regular and transparent solvency audits.
(a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row.
(b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored.
(c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process.
(d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify.
(e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible.
(3) Protections for hot wallets and transactions.
(a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets.
(b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy.
(c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage.
(d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange.
(e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.

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Steps Forward

Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized.
The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges.
The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.

I want to thank everyone who replied to our survey! Your feedback is extremely valuable!
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Here are the results and how they're helping shape our direction.
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What goals would you like to see us accomplish? What's most important to you in how this Quadriga situation ends?

This was an open-ended question and the answers varied widely (and there was definitely a lot of responses which mentioned multiple goals). Here's a summary:

• 65% mentioned recovering losses for affected users.
• 45% described a desire to get better standards on Canadian exchanges.
• 30% included justice for victims.
• 25% desired education on crypto-asset protection.
• 20% had the creation of the new exchange.

The justice theme has been entirely overlooked by what we're doing. Discussing the idea on the Quadriga Uncovered Telegram group, it was determined that there was definite interest in a potential letter-writing initiative. One possibility would be sending letters to the RCMP to request the exhumation.
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Is there any part of our initiative which confuses you?

Almost universally, there was no mention of any confusion.
The feedback we did receive:

• "The website landing page could provide an executive summary of the key aspects of the initiative".
  • The front page was last updated March 30th. We are constantly experimenting and improving the front of the website and our presentation of ideas and welcome any insight.
• "I was worried with the proposal to have a token for affected users. The intention may be ok, but tokens and ICOs have a bad reputation for being scams. I confess that I didn't read the website of the Initiative, but from communications, I didn't see the association between the Initiative and the official committee."
  • We should make clear we are fully separate from the bankruptcy process. There is no tie to the official committee, although we have gotten their feedback throughout. This is an opportunity for the business community to provide additional help for victims.
  • We are contemplating the need for having blockchain-backing, however it does provide the ability to have greater transparency in the distribution/supply, more control in the form of a multi-sig smart contract, and easier liquidity options.
  • What we are doing is fundamentally different from any ICO. Tokens are distributed 100% free against verified losses. Redemption happens over time for utility (products/services) or goodwill (best-effort redemption) and it's always a fixed value of $1.
• "Generally i understand. Confused about progress and value offer to crypto enthusiasts."
  • The initial (very first) value proposition for the tokens will be the ability to offset trading fees on the partner exchange, where we expect that traders may adopt having a small stash to cover their trading expenses as they trade. From there, we have other businesses interested in accepting partial payment in tokens. Basically, tokens are spent in place of dollars to get a discount at participating businesses which wish to support affected users.
  • In terms of progress, we are still waiting for three things:
    • Partner exchange full launch.
    • First bankruptcy payout to complete.
    • Reaching 1,000 signups (as necessary for our deal).

Please feel free to reach out on Telegram and Reddit if there are any further questions!
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Is it more important to you that we focus on (a) helping victims of Quadriga recover, (b) educating more people about Quadriga and other exchange fraud, or (c) preventing future exchange fraud events like Quadriga?

Of the first or only choice picked, 70% chose (a) helping victims of Quadriga recover, while 30% chose (c) preventing future exchange fraud events like Quadriga.
(a) was mentioned in 80% of cases, and top choice in 70%.
(b) was a second choice in 30% of cases and mentioned in 35%.
(c) was mentioned in 65% of responses and top choice in 30%.
The educational portion of our initiative was seen as the lowest value. We are floating the idea of replacing the Education goal with a separate Justice goal, which is composed of letter-writing and other advocacy to help speed up any potential criminal investigations.
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What bothers you most about Canadian cryptocurrency exchanges?

The responses varied widely. Here's a selection:

• "The lack of unbiased information on how trustworthy exchanges are."
• "The lack of transparency."
• "that they are unregulated"
• "I only use a non-custodial exchange now (Bull Bitcoin). The inertia and apathy of the government bothers me a lot. After Quadriga there should have been an inquiry. Even my emails to MPs Marie-France Lalonde and Bill Blair got no response. It's not realistic to wait for exchanges to 'self-regulate'."
• "Terrible for trading and unreliable"
• "Where is the regulation and oversight?"
• "It's difficult to know which one is safe and w[h]ich one is not. It's easier to go to a bigger exchange (eg. Binance, Kraken, ... ) who has a solid reputation than Canadian one (at least for now)"
• "Small"
• "Slow volume, difficulty to access for some, security"
• "Security, trust, support, education"

There is clearly a lack of satisfaction.
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Should preventing events like Quadriga focus more on regulatory reform (working with regulators) or trying to create change through setting the example on one exchange and go from there (similar to how "Tesla" has electrified vehicles)?

Overall summary:

• 40% of respondents desired an approach which included both aspects.
• 40% of respondents desired an approach of setting an example in one exchange.
• 20% preferred a regulatory approach.
• "(c), creating an independent classification/review system that would allow users to know which exchanges are most trustworthy, and to force less trustworthy ones to shape up."
  • There are a few such services out there. Key issues are that these opinions can be influenced by referral bonuses, the exchange reputations change over time (as was the case in Quadriga), and there is limited information on which to base the evaluation. Many reputable third parties have recommended shady services that subsequently failed.

Pressing forward on both fronts appears to make the most sense.
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Would you rather have the recovery run inside of a for-profit exchange (sort of a marketing/promotion idea to push people onto a safer exchange) or as an independent group of affected users pushing for our own interests (working with the safer exchange and other businesses potentially similar to a labour union or political advocacy)?

The end result:

• The majority (55%) prefer to have the independent group advocating for affected users.
• A minority (35%) prefer to have it run in a for-profit/promotional way inside the exchange.
• There were 10% of responses indicating both would be acceptable, or no clear preference.

We will be working to run this independently, however working closely with our partner exchange as a joint project (and it is definitely a promotional tool for them).
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If given the choice, would you prefer (a) $20 cash each year for 10 years (slower recovery with full choice), or (b) your choice of $200 worth of discounts on products/services that are donated by small businesses which you could use this year (faster recovery with less choices)?

60% indicated a preference for (b), and 40% had the preference for (a). There is clear interest in focusing on both, which will push the fastest and most flexible recovery.
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Affected users have a liquidation option which allows non-victims to purchase their tokens on the exchange. How do you feel about charging non-victims a small fee (5 cents per token) that is split between funding the project and a pool for affected user payout?

50% expressed outright support for the idea. Below are more detailed responses and comments:

• "indifferent, although I think any fee will end up factoring in to the exchange rate on the value of the token. If people are willing to pay $10 for a $15 coupon, then a 5% fee might mean they'll only pay $9.50"
  • This is undoubtedly true. In your example, 25 cents would go to the project, 25 cents to affected users, and $9.50 to the seller. As opposed to $10 going to the seller.
• "I am not yet clear on the cost structure of the proposed solution. Has the cost of managing the recovery effort been accounted for?"
  • It hasn't been properly accounted for, and this is one possible solution.
• "I think that it is more important to have broad communication, reaching out to public at large and crypto communities in other countries. Then there should be multiple ways for different communities to contribute financially to affected users. I don't like the idea of fees and tokens because it seems to distract from the larger tasks of communication, rallying, documenting and advocating."
  • You bring up great points. Outreach is important, as is flexibility in approach. If you have more concrete ideas we would love to consider them!
• "Good idea, but it restricts the on boarding of new users"
  • This is a fair point. The hope is that those participating want to help.
• "I would prefer to avoid this option, Unless we can show that there are many added benefits from using this platform over others, thus justifying the fees and making it more acceptable to users."
  • Absolutely. Hopefully there will be many added benefits.
• "I think it a good idea, fees will go anyway to affected users, I totally agree"
  • Awesome. That's definitely the intent.
• "better not tax when tokens are transferred to the blockchain - tax the transaction (something small, in order not to affect the volume/liquidity too much) like what they are doing with the flight tickets in Quebec"
  • Absolutely! This would be a transaction cost only.

At the moment this has not yet been agreed upon by the partner exchange.
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Have you discussed the project with anyone else who lost funds in Quadriga? What kind of feedback are you hearing?

40% said they've discussed it. 40% have not. 20% didn't answer (or it was hard to understand). Some of the responses:

• "only online, and there there seems to be some confusion about the projects goals, some concerns about the connection to a for-profit exchange, and a general 'one bitten twice shy' mentality."
• "Yes, Matt and my spouse. The problem was foreseeable. We just all ignored the risk because we were sold on the simplicity. The first red flag I saw was that accounts could be reloaded through an entity in China, which did not make sense, but I ignored it because of my perceived impression of protection given that the operator was in Canada."
• "Yes - most have given up hope of recovering funds"
• " I can't follow the chats on Telegram. I gained no knowledge the times I tried to read the discussions there. In fact the discussions there seemed to be not very polite. I wasn't able to connect with any other affected user. I wish there were some more structured gathering. Maybe a webinar would be nice."
  • Note: This sounds like it may be talking about the separate and more popular Quadriga Uncovered Telegram group. We would be very interested for any examples of impolite discussions on our Telegram group.
• "This recovery process started out fine, but has turned into a circus show as is usual with lawyers who naturally want to stretch cases out to steal more money from victims."
• "Not for now, I don't know any other victim (except members of Quadriga initiative)"
• "Its your fault for keeping it on an exchange, what did you think was going to happen. There will be no money left after the 'bankruptcy'.. Lightning will solve all these problems other than recovery of funds."

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Many affected users have strong privacy concerns and shame regarding what happened to them, such that they are even hesitant to share basic details. What do you feel is the best way to build trust and openness among the affected user community?

Here are some of the replies:

• "I really don't know. Keeping things as anonymous as possible might help, but then the project would also need accountability to show that most of the tokens weren't sent to your own account. It's a tricky problem."
  • Absolutely. We also need to consider the various ways the project could be defrauded.
• "What you are doing now. I am just not clear on the sustainab[i]lility of this effort without appropriate financial support."
• "We all lost. We got burned. No shame in getting burned. It happens."
• "There must be a way for affected users to connect to each other. Communication is the foundation, and it can be done preserving privacy. Some ideas include a webinar, chat tools that preserve privacy, etc. I heard of the documentary but I don't know what will be there. I think it is important also for the public at large to know how Quadriga affected users. That is, it's important for some personal stories to be published, ideally in the mainstream press."
  • We have Telegram, Reddit, and Twitter. A webinar would be great! There have been a number of mainstream news articles on Quadriga, although it's not well known outside of the crypto community. We welcome any further ideas for platforms.
• "I would use the angle that crypto will continue to gain traction as time goes on, and that although the affected users were victims of a terrible fraud, we have an opportunity to prevent this from happening to others. I would also use the fact that this initiative has gained a considerable following and that affected users are all in this together, whether we want it or not."
  • Absolutely!
• "Maybe a guarantee that nobody will be further persecuted would help."
  • Hopefully no affected users are persecuted. Who's being persecuted?
• "I don't know what else could be done for now."
• "Just let us go forward."
• "Once you demonstrate positive effects (and communicating about them), and set up ways to contact you securely, the users who have privacy concerns will contact you. You should have anonymous way to communicate with you (maybe using memo.cash?)"
  • Feel free to use an anonymous handle for any communication with us via Reddit, Twitter, Telegram, or email.
• "Simple questions, good job :). Wonder about the stages of loss/gr[ie]f. Maybe the stinging pain needs to subside before people will trust."

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Notes: Percentages rounded to the nearest 5%.
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Thank you very much for everyone who took the time to respond! We will continue to study your answers as we move forward!

Note: you can read this on GitHub (link), Medium (link) or old Reddit (link) to see all the links.

Development

dcrd: Version 1.3.0 RC1 (Release Candidate 1) is out! The main features of this release are significant performance improvements, including some that benefit SPV clients. Full release notes and downloads are on GitHub.
The default minimum transaction fee rate was reduced from 0.001 to 0.0001 DCkB. Do not try to send such small fee transactions just yet, until the majority of the network upgrades.
Release process was changed to use release branches and bump version on the master branch at the beginning of a release cycle. Discussed in this chat.
The codebase is ready for the new Go 1.11 version. Migration to vgo module system is complete and the 1.4.0 release will be built using modules. The list of versioned modules and a hierarchy diagram are available here.
The testnet was reset and bumped to version 3.
Comments are welcome for the proposal to implement smart fee estimation, which is important for Lightning Network.
@matheusd recorded a code review video for new Decred developers that explains how tickets are selected for voting.
dcrwallet: Version 1.3.0 RC1 features new SPV sync mode, new ticket buyer, new APIs for Decrediton and a host of bug fixes. On the dev side, dcrwallet also migrated to the new module system.
Decrediton: Version 1.3.0 RC1 adds the new SPV sync mode that syncs roughly 5x faster. The feature is off by default while it receives more testing from experienced users. Other notable changes include a design polish and experimental Politeia integration.
Politeia: Proposal editing is being developed and has a short demo. This will allow proposal owners to edit their proposal in response to community feedback before voting begins. The challenges associated with this feature relate to updating censorship tokens and maintaining a clear history of which version comments were made on. @fernandoabolafio produced this architecture diagram which may be of interest to developers.
@degeri joined to perform security testing of Politeia and found several issues.
dcrdata: mainnet explorer upgraded to v2.1 with several new features. For users: credit/debit tx filter on address page, showing miner fees on coinbase transaction page, estimate yearly ticket rewards on main page, cool new hamburger menu and keyboard navigation. For developers: new chain parameters page, experimental Insight API support, endpoints for coin supply and block rewards, testnet3 support. Lots of minor API changes and frontend tweaks, many bug fixes and robustness improvements.
The upcoming v3.0 entered beta and is deployed on beta.dcrdata.org. Check out the new charts page. Feedback and bug reports are appreciated. Finally, the development version v3.1.0-pre is on alpha.dcrdata.org.
Android: updated to be compatible with the latest SPV code and is syncing, several performance issues are worked on. Details were posted in chat. Alpha testing has started, to participate please join #dev and ask for the APK.
iOS: backend is mostly complete, as well as the front end. Support for devices with smaller screens was improved. What works now: creating and recovering wallets, listing of transactions, receiving DCR, displaying and scanning QR codes, browsing account information, SPV connection to peers, downloading headers. Some bugs need fixing before making testable builds.
Ticket splitting: v0.6.0 beta released with improved fee calculation and multiple bug fixes.
docs: introduced new Governance section that grouped some old articles as well as the new Politeia page.
@Richard-Red created a concept repository sandbox with policy documents, to illustrate the kind of policies that could be approved and amended by Politeia proposals.
decred.org: 8 contributors added and 4 removed, including 2 advisors (discussion here).
decredmarketcap.com is a brand new website that shows the most accurate DCR market data. Clean design, mobile friendly, no javascript required.
Dev activity stats for August: 239 active PRs, 219 commits, 25k added and 11k deleted lines spread across 8 repositories. Contributions came from 2-10 developers per repository. (chart)

Network

Hashrate: went from 54 to 76 PH/s, the low was 50 and the new all-time high is 100 PH/s. BeePool share rose to ~50% while F2Pool shrank to 30%, followed by coinmine.pl at 5% and Luxor at 3%.
Staking: 30-day average ticket price is 95.6 DCR (+3.0) as of Sep 3. During the month, ticket price fluctuated between a low of 92.2 and high of 100.5 DCR. Locked DCR represented between 3.8 and 3.9 million or 46.3-46.9% of the supply.
Nodes: there are 217 public listening and 281 normal nodes per dcred.eu. Version distribution: 2% at v1.4.0(pre) (dev builds), 5% on v1.3.0 (RC1), 62% on v1.2.0 (-5%), 22% on v1.1.2 (-2%), 6% on v1.1.0 (-1%). Almost 69% of nodes are v.1.2.0 and higher and support client filters. Data snapshot of Aug 31.

ASICs

Obelisk posted 3 email updates in August. DCR1 units are reportedly shipping with 1 TH/s hashrate and will be upgraded with firmware to 1.5 TH/s. Batch 1 customers will receive compensation for missed shipment dates, but only after Batch 5 ships. Batch 2-5 customers will be receiving the updated slim design.
Innosilicon announced the new D9+ DecredMaster: 2.8 TH/s at 1,230 W priced $1,499. Specified shipping date was Aug 10-15.
FFMiner DS19 claims 3.1 TH/s for Blake256R14 at 680 W and simultaneously 1.55 TH/s for Blake2B at 410 W, the price is $1,299. Shipping Aug 20-25.
Another newly noticed miner offer is this unit that does 46 TH/s at 2,150 W at the price of $4,720. It is shipping Nov 2018 and the stats look very close to Pangolin Whatsminer DCR (which has now a page on asicminervalue).

Integrations

www.d1pool.com joined the list of stakepools for a total of 16.
Australian CoinTree added DCR trading. The platform supports fiat, there are some limitations during the upgrade to a new system but also no fees in the "Early access mode". On a related note, CoinTree is working on a feature to pay household bills with cryptocurrencies it supports.
Three new OTC desks were added to exchanges page at decred.org.
Two mobile wallets integrated Decred:

• Coinomi added Decred to their Android and iOS wallets. In addition to the Apple App Store and Google Play you can download the APK directly. Coinomi features an integrated cryptocurrency exchange and is the first company to offer a mobile Decred wallet.
• BitBill Android and iOS wallet also added Decred.

Reminder: do your best to understand the security and privacy model before using any wallet software. Points to consider: who controls the seed, does the wallet talk to the nodes directly or via middlemen, is it open source or not?

Adoption

Merchants:

• Bit Dials announced DCR support via GloBee at their bitdials.eu luxury boutique. Their separate supercar and classic car shop bitcars.eu also accepts DCR, either via GloBee or with manual invoicing in case of privacy concerns.
• Sheldon Store re-enabled DCR payments. The shop sells gift cards for Amazon, iTunes, Netflix and many more.

Marketing

Targeted advertising report for August was posted by @timhebel. Facebook appeal is pending, some Google and Twitter campaigns were paused and some updated. Read more here.
Contribution to the @decredproject Twitter account has evolved over the past few months. A #twitter_ops channel is being used on Matrix to collaboratively draft and execute project account tweets (including retweets). Anyone with an interest in contributing to the Twitter account can ask for an invitation to the channel and can start contributing content and ideas there for evaluation by the Twitter group. As a result, no minority or unilateral veto over tweets is possible. (from GitHub)

Events

Attended:

• Meetup in Puebla City, Mexico, organized by @elian. (photo, slides, missed in July issue)
• @joshuam discussed Decred and decentralized organizations with Craig Laundy, Federal Minister for Small Business, the Workplace, and Deregulation with the Australian Government, at @YBFVentures. (photos)
• Meetup at @TheBlockCafe in Lisbon, Portugal. @mm presented "Decred 101 - Governance with Skin in the Game" and @moo31337 talked about Decred's 2018 roadmap. (photos: 1 2 3)
• Meetup in Taipei, Taiwan. @morphymore made a short intro of Decred and noted: "After the talk, many have approached to tell me that they literally don’t hear of Decred until today, and are interested in finding out more about the merit of a hybrid consensus system.". Longer report here, some photos and a video are here.
• @eSizeDave introduced Decred to the SILC Undergraduate Program students at @YBFVentures. (photo)
• OKEx Global Meetup Tour in Ho Chi Minh City, Vietnam. @joshuam gave a brief presentation covering the history of Decred, how the project functions, and the importance of governance. Afterwards he joined a panel discussion and spoke about Decred's incentives for long term viability. (video, video, photo)
• Blockchain & Decentralised Governance Panel at @YBFVentures in Melbourne, Australia. @eSizeDave presented Decred, mini-report here. (photos: 1 2)
• Blockchain Futurist Conference in Toronto, Canada. @zubairzia0 noted: "Devs and the community were held in high regard for the people who knew about decred ... one positive thing I remember was someone defending us saying 'Decred does not need a booth', I believe that comment was reflective of the quality of projects being showcased at the conference.". (photo)
• Meetup at @YBFVentures in Melbourne, Australia. @joshuam discussed Decred with Graham Stuart, U.K. Minister for International Trade. (news, photos)
• Small meetup with Jackson Palmer in Melbourne, Australia. (photo)
• Voice of Blockchain in Chicago, USA. @moo31337 talked on Protocol Governance panel, Solving Scalability panel (video) and gave an interview, while @ay-p spoke on Decentralized Exchanges panel. Stakey made an appearance on the slides. (photos: 1 2 3 4 5)
• Hawthorne Street Fair in Portland, USA. Raedah Group was out answering questions about crypto and Decred. (photos)
• Blockchain APAC in Melbourne, Australia. @joshuam joined a panel discussion with reps from banking, university and ISO/TC 307. @eSizeDave reports: "This enterprise conference was indeed a whole lot better than I expected. The presentations were actually full of very worthwhile information from credible people, articulated aptly to a very government, academic, and corporate crowd, who genuinely took on board valuable insights. Good to know some of these key people are Decred holders and stakers as well. I got to use the entire day to speak directly with some of the most pivotal personalities in this particular populace. Ongoing relationships have been built and strengthened.". (photos: 1 2 3)

For those willing to help with the events:

BAB: Hey all, we are gearing up for conference season. I have a list of places we hope to attend but need to know who besides @joshuam and @Haon are willing to do public speaking, willing to work booths, or help out at them? You will need to be well versed on not just what is Decred, but the history of Decred etc... DM me if you are interested. (#event_planning)
The Decred project is looking for ambassadors. If you are looking for a fun cryptocurrency to get involved in send me a DM or come talk to me on Decred slack. (@marco_peereboom, longer version here)

Media

Decred Assembly episode 21 is available. @jy-p and lead dcrwallet developer @jrick discussed SPV from Satoshi's whitepaper, how it can be improved upon and what's coming in Decred.
Decred Assembly episodes 1-21 are available in audio only format here.
New instructional articles on stakey.club: Decrediton setup, Deleting the wallet, Installing Go, Installing dcrd, dcrd as a Linux service. Available in both English and Portuguese.
Decred scored #32 in the August issue of Chinese CCID ratings. The evaluation model was explained in this interview.
Satis Group rated Decred highly in their cryptoasset valuation research report (PDF). This was featured by several large media outlets, but some did not link to or omitted Decred entirely, citing low market cap.
Featured articles:

• Decred Investor Interviews: Ciarán O’Leary, General Partner, BlueYard Capital (medium)
• Decred Update Research Report by Node Blockchain (medium), and the corresponding full 11-page report (Google Drive)
• Is Decred worth my time and money? by Fabien Pelissier (medium), and the full 13-page Decred Analysis (PDF)
• Decred for Custody Providers by @bee (medium)

Articles:

• The 3 Best-Performing Cryptocurrencies in 2018 (nulltx.com, missed in July issue)
• Decred Review (vivecrypto.com, missed in July issue)
• What is Decred? Everything about Decred, the wallet and the hybrid consensus (Dutch, currentcrypto.nl)
• Decred overview (Japanese, cryptocoinportal.jp, note: Decred's Coco is Amazing, according to Google Translate)
• What is Dark Red (Decred)? (Japanese, billion-coin.jp)
• Decred is the neglected gem among altcoins (captainaltcoin.com)
• What are the characteristics of Decred and where to buy? (Japanese, motto-money.com)
• What is hybrid virtual currency Decred? Explanation of features and future potential (Japanese, investor-a.com)
• What is DCR? Introduction to Decred (cryptobriefing.com)
• Cryptocurrencies in the Top 100 With Working Products That Are In-Use (investinblockchain)

Videos:

• Top 3 Coins Crushing it in 2018 so Far! - Decred, VeChain, Binance Coin! by Decentralized TV (youtube)
• Decred review by Ultimate Money (youtube, missed in July issue)
• Interview with Marco Peereboom by BitBoy Crypto (youtube)

Community Discussions

Community stats:

• Twitter followers 39,592 (+174)
• Reddit subscribers 8,631 (+119)
• Matrix users 163
• Slack users 6,067 (+103)
• YouTube subscribers 3,667
• Facebook 3,048 followers and 2,814 likes
• GitHub 417 (+14) stars and 1,021 (+44) forks of dcrd repository

Comm systems news:

• Interruptions in the chat bridge led to some Slack messages not reaching other platforms, and consequently not being archived in Matrix.
• Several impersonators were detected and banned.
• Inactive Slack channels were archived. If you miss them, let it be known.
• Mastodon was mentioned by several people as a possible alternative for Twitter.
• Two new Reddit rules were added to prevent CAPS flood and duplicate submissions.

After another debate about chat systems more people began testing and using Matrix, leading to some gardening on that platform:

• Decred Matrix community was created: +decred:decred.org, it helps to see all Decred-related rooms and people.
• #privacy and #design are now bridged.
• One private work channel was successfully migrated to Matrix.
• Stylish room avatars were set.
• @Haon has prepared a short guide to help new Matrix users get started and join the Decred rooms.

Highlights:

• A thread was started to discuss changes to Decred jargon with the intent to make it more consistent and accessible to newcomers. The question whether changing "official" terminology requires stakeholder approval was touched in this thread and in #documentation.
• Project fund transparency and constitution were extensively discussed on Reddit and in #general.
• Pre-proposal to use Politeia to approve Politeia as a legitimate decision-making tool for Decred.

Reddit: substantive discussion about Decred cons; ecosystem fund; a thread about voter engagement, Politeia UX and trolling; idea of a social media system for Decred by @michae2xl; how profitable is the Obelisk DCR1.
Chats: cross-chain trading via LN; plans for contractor management system, lower-level decision making and contractor privacy vs transparency for stakeholders; measuring dev activity; what if the network stalls, multiple implementations of Decred for more resilience, long term vision behind those extensive tests and accurate comments in the codebase; ideas for process for policy documents, hosting them in Pi and approving with ticket voting; about SPV wallet disk size, how compact filters work; odds of a wallet fetching a wrong block in SPV; new module system in Go; security of allowing Android app backups; why PoW algo change proposal must be specified in great detail; thoughts about NIPoPoWs and SPV; prerequisites for shipping SPV by default (continued); Decred vs Dash treasury and marketing expenses, spending other people's money; why Decred should not invade a country, DAO and nation states, entangling with nation state is poor resource allocation; how winning tickets are determined and attack vectors; Politeia proposal moderation, contractor clearance, the scale of proposals and decision delegation, initial Politeia vote to approve Politeia itself; chat systems, Matrix/Slack/Discord/RocketChat/Keybase (continued); overview of Korean exchanges; no breaking changes in vgo; why project fund burn rate must keep low; asymptotic behavior of Decred and other ccs, tail emission; count of full nodes and incentives to run them; Politeia proposal translations and multilingual environment.
An unusual event was the chat about double negatives and other oddities in languages in #trading.

Markets

DCR started the month at USD 56 / BTC 0.0073 and had a two week decline. On Aug 14 the whole market took a huge drop and briefly went below USD 200 billion. Bitcoin went below USD 6,000 and top 100 cryptos lost 5-30%. The lowest point coincided with Bitcoin dominance peak at 54.5%. On that day Decred dived -17% and reached the bottom of USD 32 / BTC 0.00537. Since then it went sideways in the USD 35-45 / BTC 0.0054-0.0064 range. Around Aug 24, Huobi showed DCR trading volume above USD 5M and this coincided with a minor recovery.
@ImacallyouJawdy posted some creative analysis based on ticket data.

Relevant External

StopAndDecrypt published an extensive article "ASIC Resistance is Nothing but a Blockchain Buzzword" that is much in line with Decred's stance on ASICs.
The ongoing debates about the possible Sia fork yet again demonstrate the importance of a robust dispute resolution mechanism. Also, we are lucky to have the treasury.
Mark B Lundeberg, who found a vulnerability in atomicswap earlier, published a concept of more private peer-to-peer atomic swaps. (missed in July issue)
Medium took a cautious stance on cryptocurrencies and triggered at least one project to migrate to Ghost (that same project previously migrated away from Slack).
Regulation: Vietnam bans mining equipment imports, China halts crypto events and tightens control of crypto chat groups.
Reddit was hacked by intercepting 2FA codes sent via SMS. The announcement explains the impact. Yet another data breach suggests to think twice before sharing any data with any company and shift to more secure authentication systems.
Intel and x86 dumpsterfire keeps burning brighter. Seek more secure hardware and operating systems for your coins.
Finally, unrelated to Decred but good for a laugh: yetanotherico.com.

About This Issue

This is the 5th issue of Decred Journal. It is mirrored on GitHub, Medium and Reddit. Past issues are available here.
Most information from third parties is relayed directly from source after a minimal sanity check. The authors of Decred Journal have no ability to verify all claims. Please beware of scams and do your own research.
Feedback is appreciated: please comment on Reddit, GitHub or #writers_room on Matrix or Slack.
Contributions are welcome too. Some areas are collecting content, pre-release review or translations to other languages. Check out @Richard-Red's guide how to contribute to Decred using GitHub without writing code.
Credits (Slack names, alphabetical order): bee, Haon, jazzah, Richard-Red and thedecreddigest.