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The text below is repeated on my google drive here you can comment as well. https://docs.google.com/document/d/1yWXetja-k0nW121p0aHAr9s9OwEeXMRoQ-goad38Oac/edit?usp=sharing ------------------------------------------------------------------------------------------------------------------------ To understand the issues, you need to read the above first. https://www.fdic.gov/news/news/financial/2015/fil15002a.pdf The FDIC has made forbidden what is known as “brokered services” (see above ) for undercapitalized banks . It makes brokering of deposits difficult even for well capitalized banks. There are many ways to get around this for example the reciprocal brokered deposits where banks placed deposits with their own network up to the insured amount etc. There is also an exemption for Listing services ie where website only provides “rates”. This can be found under the above FAQ at page 5. I have cut and paste below in RED. I will also attempt to answer each of the criteria below against what I am building here in depositoffer. "The FDIC does not treat the listing service as a deposit broker if the company satisfies each of the following requirements: (A) The person or entity providing the listing service is compensated solely by means of subscription fees (i.e., the fees paid by subscribers as payment for their opportunity to see the rates gathered by the listing service) and/or listing fees (i.e., the fees paid by depository institutions as payment for their opportunity to list or “post” their rates). The listing service does not require a depository institution to pay for other services offered by the listing service or its affiliates as a condition precedent to being listed. " REPLY: Depositoffer asks for listing fees from depositors and/or banks. In our scenario, we ask the depositor to provide their minimum deposit rates and the banks may if they so wish post a bid rate against that minimum deposit rate. This way we have real competition and better rates for the depositors. "(B) The fees paid by depository institutions are flat fees, not calculated on the basis of the number or dollar amount of deposits accepted by the depository institution as a result of the listing or posting of the depository institution’s rates. " REPLY: The bid fees to post a rate is a flat fee. This is a bid and in our depositoffer is the depositor that decides. "(C) In exchange for these fees, the listing service performs no services except: (1) the gathering and transmission of information concerning the availability of deposits; and/or (2) the transmission of messages between depositors and depository institutions including purchase orders and trade confirmations. In publishing or displaying information about depository institutions, the listing service must not attempt to steer funds toward particular institutions, except that the listing service may rank institutions according to interest rates and also may exclude institutions that do not pay the listing fee. Similarly, in any communications with depositors or potential depositors, the listing service must not attempt to steer funds toward particular institutions." REPLY: Depositoffer has no role in the deposit auction other than to facilitate a platform, the depositor will select the “best” bid and follow through the instructions given to complete the deposits with the selected bank directly. "(D) The listing service is not involved in the physical placement of deposits. Any funds to be invested in deposit accounts are remitted directly by the depositor to the insured depository institution and not, directly or indirectly, by or through the listing service." REPLY: Depositoffer is not involved with the physical placement of deposits The objective behind can be read in my paper here https://docs.google.com/document/d/1utz6iPu-CPPntkhr__4-UuD5ulwZXBwtsCkrnbkGkt8/edit?usp=sharing click here to go to https://token.depositoffer.com click here to go to our https://bitcointalk.org/index.php?topic=3261714 Our latest peer to peer loan syndication applet at https://play.google.com/store/apps/details?id=com.quad.loansyndicate I have clients wanting to take deposits for AngelList, Atlassian, BlaBlaCar,Domo,Etsy,Flipboard,Houzz,Kickstarter,LegalZoom,Lookout,MapR Technologies, You can lend them those securities and they will use them as collateral and when you have the money you can redeem them, otherwise they are transfer to them. Email me should you be interested. FEES are calculated from actual interest/profit bids. Unlike other sites, we do not hold client's money or anyone's money except our own. We just want to provide a platform for our clients to get competitive rates and exclude ourselves from the transaction side. Therefore, clients must understand that they will be dealing with people or banks who will take their deposits, just like any ordinary cause of business, caution is required. You should always have a good contract if you are lending/depositing to non-financial institutions. You should be careful when dealing with individuals who offered unsustainable rates. If they are not in your state, then you should not deal with them. Do not deposit/lend more than $5000 as this is the probably the maximum amount you can claim in a small claims court should borrower defaults, for banks check out their FDIC status. If you are lending to strangers, you should check their identity, do a pipl.com search, paypal search, bank search (deposit a penny into their account) and ebay or amazon search. Give them a call and ask whatever documents you need to verify their status. If you lend money to someone living in your city, then the risk is even lower as you can check them out in person or have a skype video (record the video for goodness sake). I do not have the resources to implement all these features in depositoffer but suffice to say, this is still experimental. I have added bitcoin (and others will be followed soon) as it is unregulated under Virtual Currencies. This means it is anyone can bid to accept BTC. I have limit this to 30 days given the volatility. Obviously, you need to know who the taker (borrower/depositee) is and get a clear indication whether he will pay you in BTC or other currencies (the system is setup to receive BTC but you can use the swap option). I decided on this as I know many bitcoin owners are merely sitting on their bitcoins which is a shame as a currency in order to be accepted must be circulated in the economy (remember multiplier effect from econ 101 ?). So why not. As usual caution to whom you are lending to (make sure at least 6 blocks have passed ie 2 hours and longer) before passing the BTC. As you know BTC is not a fiat currencies so you should be extra careful to include a loan agreement, if you have difficulty ask me for a sample. The best ones are usually along the terms of a credit card. There is another website btcjam.com which is also offering the same but recently have been hit by defaulters/scammers. Obviously people lose their BTC. Depositoffer is different as we do not hold your BTC and you deal directly with the borrower (in btcjam, the website deals with the borrowers). The obvious point here is that as the lender/depositor you can sue in your own name to get your BTC back but in btcjam you are limited to an Arbitration Award. The latter has no enforcement effect, ie you need to go to court to get a judgment before you can enforce and enforcement by itself is something that I am well acquainted with as I am a lawyer. Its not cheap, so I would not lend any money to anyone unless, I know their identity, where they live, their income, video chat with them (record it) and so on. As lender, your rights is protected by the contract so you need to make sure you get this correct and you can bring someone to Court. In my experience, is very likely this someone will pay once they are summoned to Court because the alternative is court expenses and blacklisting by credit companies which extracts court's records. If you are unfamiliar with BTC workings please have a look at this video which I find is the easiest for anyone wishing look under the BTC hood. https://www.youtube.com/watch?v=Lx9zgZCMqXE Personally, if you are not experience with BTC stayed away until you are knowledgeable. We offer the only space in USD/AUD/YUAN/EURO/Virtual Currencies such as Bitcoin This is a LIVE-BETA site with live transactions. For demo, please visit depositoffer.com/demo/ |