Utility vs. Security Tokens and China’s Leadership
China could lead the emergence of a Token Economy
I’ve gotten a lot of interest from my Chinese readers on my post on Security Token Offerings (STOs). Academics and entrepreneurs from China have contacted me on WeChat to discuss it. China might lead the world in the adoption of blockchain. Alibaba patents, Bitmain’s hardware and IPO, and how Singapore projects that are partnering with Chinese businesses are just some major indications of this.
This piece is part of a monthly series covering regulatory updates related to cryptocurrencies (here are the updates from July, August, and September). This piece provides important regulatory updates since the September piece, broken down by developments in the United States and the rest of the world.
A federal judge ruled that U.S. securities laws may cover an initial coin offering (Sept 11th), potentially giving securities regulators the legal purview to regulate the large initial coin offering market. Coinschedule.com estimates that more than $18 billion has been raised via ICOs so far in 2018, a figure that more than triples the $5.6 billion raised in ICOs over the entire year of 2017. The case dealt with a man charged with promoting digital currencies backed by investments in real estate and diamonds. According to Bloomberg, “U.S. District Judge Raymond Dearie in Brooklyn, New York, said on Tuesday that the government can proceed with a case alleging that an initial coin offering is a security for purposes of federal criminal law.” While the case is interesting given that it is linked to the fundraising mechanism of an ICO, the sale conducted in this scenario clearly resembles a security given that the tokens being sold represent a claim on physical assets (real estate and diamonds in this case) rather than a sale of tokens that provide “utility” in a network. This second category of “utility tokens” that do not represent a claim on assets or cash flows from a business is a much more interesting scenario that implicates large existing cryptocurrencies, like Ethereum. Earlier this year in June, SEC Director of Corporate Finance William Hinman stated that he did not believe that Ethereum should be treated as a security. Additionally, he suggested that an asset could be born via an ICO process and transition from being a security to not be a security. Future editions of this series will provide updates on the case and implications for the ecosystem.
Chris Giancarlo, Chairman of the CFTC, advocated for avoiding regulation that may unnecessarily hamper the growth of the cryptocurrency industry (Sept 14th). Chairman Giancarlo made an analogy to the early days of the internet, which he says flourished in part because the government avoided stepping in too heavily when it instead applied a “do no harm” approach. Relating this analogy to cryptocurrencies, he explained that he is “advocating the same approach to cryptocurrencies and all things having to do with this new digital revolution of markets, and of currencies, and of asset classes.” He was direct in addressing malicious behavior, however, and made clear that “when it comes to fraud and manipulation, we need to be strong. When it comes to policy making, I think we need to be slow and deliberate and well informed.” The CFTC ruled in 2015 that virtual currencies should be considered commodities and regulated under the existing legal framework. Given that many aspects of the cryptocurrency space are novel, it will be difficult for regulators to separate fraud from innovation early on. It will be interesting to see where regulators land on the balance between protecting investors and allowing creators of cryptocurrency projects to experiment with crowdfunding and incentive structures for holders and participants in cryptonetworks.
A group of cryptocurrency industry members met with members of Congress to express the collective desire for greater regulatory clarity in the industry (Sept 25th). Representatives from firms like Fidelity, Nasdaq, State Street, Andreesen Horowitz, and 40+ other industry participants lobbied for greater regulatory clarity while expressing the urgency for action due to the risk of losing innovation in the space to other regions of the world that offer more concrete regulatory policies. Jesse Powell, CEO of crypto exchange Kraken, explained the advantage that foreign competitors have in the capital raising process by explaining that “foreign companies are able to outraise their U.S. competitors and often whoever raises the most money is who wins. Not only are U.S. companies not able to raise enough to compete globally, U.S. investors are not able to invest in these global companies.” Darren Soto, one of the Congressional representatives at the hearing, offered hope to the industry members by saying “I’m sensing we may need an entirely new category that treats this like a new asset, so that we’re not trying to squeeze a square peg into a round hole. There needs to be some streamlining based on the definitions of digital assets.” This coordinated effort adds pressure on regulators who may be pushed to take action sooner rather than later. Indeed, it complicates the guidance given by CFTC Chairman Giarcarlo in the section above to be patient and avoid overregulating; it may be possible that the strategy of “wait and see” is insufficient for US participants who are deeply concerned about potential ramifications if they overstep boundaries.
Rest of the World
European Union officials are not in a rush to regulate the cryptocurrency market (Sept 8th). As reported by Fortune, “Finance ministers gathering in Vienna agreed that they won’t rush with steps to further regulate the market, and that they’ll wait for the outcome of a thorough analysis by European authorities before deciding on any steps, according to officials involved in the talks.” For now, the Financial Stability Board continues to feel strongly that cryptocurrencies do not pose a threat to the larger financial system. Bruegel, a Brussels-based think tank, suggested that it could be beneficial for each country to take an independent approach to regulation before moving to a coordinated approach with a central supervisor via the EU.
A Japanese regulator released an updated report on the state of the cryptocurrency market (Sept 18th). The Financial Services Agency released a series of documents related to its ongoing surveillance and regulation of cryptocurrency exchanges operating in the country. Regulation for exchanges is being guided both by the FSA as well as an industry self-regulation group known as the Japan Virtual Currency Exchange Association. The report released suggested that the FSA will conduct regular on-site examinations of the exchanges that it extends licenses to. To carry this out, the FSA will develop its own crypto team internally. There have been numerous exchange hacks in Japan, including the hack of Coincheck in January 2018 that led to a reported $500 million in stolen funds.
If you’d like to chat about cryptocurrencies or anything else technology related, Tweet at me here https://twitter.com/phil_glazer (DMs are open, too). You can also email me at phil@bitwiseinvestments.com.
Note: I do not and will not provide investment advice or recommendation.
Product Manager & UX Strategist. Cryptopragmatic. Helping businesses bring value to the world.
Current UX Issues of the Blockchain Technology
Emerging technologies require both high value and good UX to be successful. In fact, the popularity of a technology correlates strongly with excellent and straightforward UX. This is a story of iconic, successful companies — Apple, Google, Uber, etc. Those exciting companies represent a perfect blend of a strong team, advanced technology, and satisfied customers.
User experience is all about customer satisfaction. Do you think iPhone would have been so successful if it had common user experience, just like as competitors had? Yes, iPhone had cutting-edge technologies, like a huge multi-touch screen or gyroscope. But people (including me) were mostly excited with its clear easy to use interface, pinch-to-zoom, and acceptable web browsing experience.
Why no gyroscope, proximity sensor, and 4 GB flash memory?
The same thing goes within the blockchain. I don’t think people really “need” the technology, but I am sure people need technology outcomes — freedom, trust, and privacy. So the question I asked for myself is “what hides those incomes from people around me? Why others are not so excited about new fascinating opportunities via blockchain?” And the issue of a blockchain adoption is in the user experience.
The issue of a blockchain adoption is in the user experience.
I see the next crucial distinctive features of any blockchain-based technology that impacts UX:
jargon makes communication harder and costly regarding time;
unreadable address names expose complexity;
engineers-only features could not be easily adopted by the mass market;
transaction speed and commissions cause lousy experience;
declared transparency is not usable;
Overall, the current state of blockchain user experience creates high entry barriers for newcomers, lowers adoption rate and raises more questions than solves actual needs.
So, let us dive into each issue and discover possible solutions.
Blockchain jargon
Let us imagine, you travel a lot, and you just want flight delays covered easily. That’s why you are giving a try a promising, peer-to-peer blockchain-based travel insurance. It sounds like it will save you money! Then you open “how it works” section and you see that you just need to select a flight and then make a signed transaction in ether to a dApp address to create a smart contract. Ugh, even if you understand what is stated above, that is not a correct way to describe this process to your grandma or your 5-yr old son, right?
As potential users, we want to be sure that we would be covered in case of flight delay, and we don’t care about transactions, smart contracts, etc. We don’t care about the underlying technology, and we don’t want to adopt a new way of using it. Technology should follow existing user behaviors and habits instead of reimagining user experience — that could make it successful. Same applies to the communication — to be heard, blockchain-powered services should talk user needs and potential values, not cool features or technologies.
Let us decompose what was stated above and find key value points. “Signed transaction” means your payment will be secure, “ether” and “dApp” keywords mean your insurance is worth to be trusted, and “smart contract” means you will be automatically and instantly paid. Seems like this it could bring large value for a user, but jargon raises the wall of a misunderstanding between technology and user experience.
Solution
So what do I suggest? I am sure we need to speak with people using their language and use blockchain-specific terminology only in absolute need. Yes, it is trendy, but if you are trying to reach a wider audience, use words that people are familiar with. And… it is time to stop talking about “what is Bitcoin” — there is a ton of good and bad materials about it already.
In case you are accepting bitcoins, use “buy” instead of “send” to initiate checkout, for the status of a payment, use “your purchase is almost verified” instead of “your transaction needs two confirmations”, and just “fee” instead of a “mining fee.”
Unreadable addresses
We all love names, we like to give names, we like to hear our names. We give nicknames to our pets, we use aliases while writing books. Those names could sound gently or aggressively, confidently or miserably. But in a blockchain world, we face horrible and meaningless addresses, and we can not rename them. 1EQoU9muLBu4MF9gon3o9Tm8nQwwK6DVmu — what da heck is it? Nobody could even memorize this sequence, this address that represents me. Can I use a more friendly name? Nope. Technology does not support this.
Some people could say that it does not matter, you can copy and paste this lengthy string, this is done for privacy and security, etc. Still, it is all about ease of use — domain names are way more readable than IP addresses, you can easily remember godaddy.com instead of 104.238.65.160.
QR codes are in great help here, but you need a QR reader handy. Given, it is trendy in China due to some outstanding factors, but it sees narrow adoption in other countries. Personally, I don’t believe in QR — it requires to use a camera, it is not quickly accessible. And, finally, current progress in AI that could recognize objects, read texts and determine sensitive characteristics by just a photo. It seems like AI is more promising and it is way more applicable.
(Hypothetical) Solution
I truly believe we need a global yet anonymous and decentralized naming system like DNS, supported widely by a majority of blockchain foundations. Sounds like a start-up idea? It is not, it should be entirely free and non-commercial. Seems like an impossible romantic idea? Not so impossible, if the community understands the value.
However, there are some quick solutions, like custom contact lists inside a wallet or blockchain-based services. Some blockchains like NEM and EOShave embedded functionality to solve this issue. It could also be a must-have feature in the near future, as the adoption is key for the growth.
Exceptional features… for engineers only
You all know what awesome opportunities smart contracts bring to us. Programmable money, decentralized autonomous organizations, automatic contracts! Those could dislodge or, at least, revolutionize current legal and executive systems and change the world we know now. And I’m not talking about other industries like accounting, betting, risks hedging, insurance, etc. This sounds exciting in theory, but the creation of a simple, smart contract requires expert engineering skills and takes a significant amount of time.
First, incorporating your ideas and leveraging the true power of the tech requires to know a specific programming language, Solidity, C++, Haskell, and others. Thus, it is not available for non-engineers. And even for tech-savvy guys, they need to learn a new programming language and embrace blockchain-specific nuances. The user experience of setting up a smart contract is the same as of writing the code — not so exciting and friendly.
Second, deploying a smart contract and bringing it to live is a risky thing. The issue is — decentralization means you can not fix bugs or do changes easily after launch. To make changes, you need to get an agreement among all stakeholders, all smart contract participants. Also, your contract is always vulnerable to hackers. Actually, no “hacking” is applied here, but the smart contract could be simply exploited to work unexpectedly. That already happened with The DAO project — 3.6m of ether was drained for the value of over $70m at that prices (you can dive into details in this article). A “hacker” (or a team of them) just found an exploit in the smart contract code and used it, and nobody was able to block the leak, deploy a quick fix or retrieve ether back. To fix it, it took enormous engineering effort, splitting the network and it even led to a community split.
Third, even the most secure smart contract is not easy to read and understand. It seems like you are trying to understand terms of use but in engineering style. And while smart contracts utilize code, they will not be so clear and safe for public use.
Solution
As a first step, we all lack of trustworthy people, organizations, and institutions. Those we could trust, those who could dive into details and who will value their name. In economics, The Big Four accounting firms exist to ensure corporate transparency. In crypto-industry, some communities emerge (take Hacken as an example) to settle an appropriate level of trust. Still, those communities are young and small. We need to establish new institutions, new organizations, and help grow existing ones to achieve an appropriate level of trust.
From the other side, we need to come up with easy to use tools to monitor, check, and verify blockchain-based products. It consumes time, there is no bullet-proof visual solution for it, but it could bring real transparency and trust.
Transaction speed and cost
I always smile while watching old videos about people spending Bitcoins to buy a coffee. It was so user-friendly even the technology is so young. In 2018, you enter a coffee shop and order a nice cup of energizing americano. Then you pay bitcoins (or, it is better to say, fractions of a bitcoin). And then real life happens — you wait for at least 30 minutes and pay commission on a top of your $4 cup of a cold coffee. Technology stays the same, but it is not so thrilling right now. What happened? The truth is — blockchain by itself does not give you free transactions, instant speed, or hot coffee.
You say, transactions are faster this at this moment, and you are right. But again, technology hasn’t solved the issue. Decentralization brings freedom, within a variety of tools to exploit it. Right now, companies take those risks and earn money on a top of it. And it is 100% fair, that is how our world works.
In fact, we could divide all cryptocurrencies and underlying technologies into two groups by that characteristic — those that were developed with transaction speed problem in mind, and others. And I have sad news for others — users hate waiting. In 1982, the research paper described Doherty threshold that set the requirement for computer response time to be 0.4 seconds, not 2 seconds which had been the previous standard. Just hear it out — 2 seconds is already boring for a human being. Of course, we could do our design magic, and cover several seconds under micro-animations, progress bars, but we could not hide 6 minutes of a regular transaction speed in the Ethereum network.
Solution
Good news, there is another group of blockchain technologies that was developed with this issue in mind. My bet is on Nano-like technologies (block lattice) that provide transaction speed at the level of 4–6 seconds with no transaction fees. EOS, Stellar Lumens and Ripple have same benchmarks that could compete with Visa transaction speed and volume. And for other networks, they’d better get this issue as a priority.
Transparency
Well, blockchain technology offers you full disclosure of everything that happened. Do you want to know all the previous owners of your Bitcoin? Or the exact time your Litecoin was mined? You can do so! But there is a little thing there… There is no easy way to understand that amount of information that blockchain provides you.
Yeah, right, transparency
Have you ever seen those blockchain explorers? Tried to understand what’s happening there? It could take weeks for a regular person to verify the true source of their cryptocurrency. And this is what people call blockchain transparency. When we are talking about it, what do we expect from it?
We expect getting fast, reliable, and easy to understand answers to our questions from the transparency.
Let us run through each of those characteristics, starting from the easiest one — speed. We could get almost all the information about any transaction fast enough, and this data will be fresh and nearly precise. Reliability is also covered by existing technology — all blockchain data is stored, all algorithms are available to download.
But when we start asking real-life questions, the system continually fails to answer. Have my current bitcoins went through any blenders? Is that or this ICO scam or not? Am I correctly treated with this medication based on blockchain-driven healthcare platform?
Solution
Frankly, transparency could be achieved within the variety of technologies, and blockchain is not a silver bullet for this. And we’d rather stop treating blockchain as a sweet pill that ensures full transparency, and we’d start developing tools that provide real-world answers. Let us move from “blockchain explorers” to the toolset that could provide an easy answer for just one question: Am I safe and secure?
The Take-Away
So what is the main point of it? I am sure, user experience should go first, adopting and leveraging new technologies but hiding them from the end-user. If you want to succeed with your blockchain-driven start-up, or you want to implement blockchain technology somewhere else, or you just want to evangelize this technology, here are my bits of advice:
Bring value upfront instead of exposing the technologies;
Speak with people using their language, avoid blockchain jargon;
Hide blockchain under the hood;
Commit to the community;
Think about people and their problems rather than about fascinating technologies and exciting opportunities.
