Frequently Asked Questions
Does ReMeLife only apply to elder care and dementia?
Yes, at the moment ReMeLife (RML) is focused on elder care and dementia. But we have been working with organisations in relation to learning disabilities, mild cognitive impairment and strokes. And we see relevance in foster care.
So, the aim is for RML to be a membership platform that serves the needs of multiple conditions as it grows in stature, membership, funding and revenues
How long has ReMe been used in the UK?
ReMe has been used for two years in the UK, mainly in care homes and day care centres, as well as in hospitals to establish an evidence base.
We have spent a lot of time getting it right, To achieve the portability of data across multiple care sectors, to achieve adoption by non-tech-savvy carers and to design a UX interface that is also engaging to consumers, has taken significant time, as has gaining NHS validation as a digital therapeutic service and all necessary certifications.
With ReMe now being used in all care sectors and having validated its usability in many international markets, ReMe is now ready to scale—to be discovered and downloaded through the end user engagement portal of ReMeLife.
What is a DAT?
RML’s advisory partner, Network Society Lab (NSL) is helping RML to set up a new type of blockchain-based fractionalized digital corporate debt instrument called the Decentralized Autonomous Trust or CSO to help RML fundraise more efficiently. NSL is a pioneer in the use, design and implementation of CSOs.
The CSO is a new concept that is similar to a corporate promissory note or bond, with the key difference that the company that is doing the fundraising sets aside a portion of its revenue as a buy-back reserve fund to significantly reduce investor risk.
A smart contract is used to automate the CSO using a bonding curve formula for buying and selling the fractionalized units of the note/bond called FAIRs. Except for an initial holding period generally of one year, investors can be assured of liquidity through the buyback reserve fund. Since the concept is, at its essence, a debt instrument, it does not affect the company’s cap table in order to raise funds.
For full information on the origin and nature of the CSO please view Thibauld Favre's White paper at Github
Once the CSO is set up, can the CSO be used to raise money continuously, unlike traditional fundraising mechanisms like a private equity raise which have a fixed closing and limited timeframe?
Once the CSO is set up it for RML, it becomes a continuous fundraising mechanism for RML as long as the company wants to raise funds. The CSO ’s continuous nature is very attractive because it lowers the cost and resources necessary for a company who would otherwise have to set up traditional fundraising campaigns every 6-12 months.
Who can use the CSO for raising funds?
Since one of the key requirements of a CSO is a buyback reserve fund substantially built from a portion of the fundraising company’s revenue, a company like RML must have some future revenue to contribute to the buyback reserve fund in order to effectively set up a CSO . Since the CSO typically requires a minimum holding period of at least 12 months, there is time to properly fund RML’s buyback reserve fund.
Are there some verticals better suited to a CSO ?
Any company with revenue can set up a CSO . The industry vertical of the company doesn’t qualify or disqualify the company to use the CSO as a fundraising source.
Since the CSO requires a smart contract, and the CSO concept is brand new, it is logical that the first companies that are likely to be most comfortable to use the CSO as a mechanism to fundraise will be technology-based companies like RML that are comfortable with digital ledger technology commonly referred to as blockchain technology.
Is there an investor classification required?
Yes, in early days, whilst the RML CSO is subject to a regulatory sandbox and its likely limitations, the investors will likely need to be “qualified”, “accredited” or “sophisticated”. This requirement depends on the laws of the jurisdiction in which the investor is a resident and the required regulations of the jurisdiction that the CSO is based (which is likely to be Malta where NSL is discussing a regulatory sandbox to test the concept).
After the sandbox experiment satisfies the regulator, then there is likely to be a gradual relaxation of the investor status requirements.
How do you confirm sophisticated investor status, which we assume is required?
The investor status is defined by the compliance regulations of the country of residency of the investor. The compliance regulations of the country of residence are used to confirm investor’s status. Many countries like the UK allow for self-certification of sophisticated or similar investor status.
How do you undertake KYC and AML to ensure no inappropriate secondary market use of FAIRS?
Yes, this will be a likely requirement of Malta or any other jurisdiction. RML will use an established third-party KYC/AML provider to perform the requisite KYC and AML checks. There are several such providers that have international experience in this regard. Also, any secondary market exchanges formed that trade in FAIRs will very likely be required to do so this as well.
Furthermore, when there is a secondary market how is investor suitability monitored?
Investor suitability in a secondary market is a function of the requirements of the CSO exchange. NSL plans to launch one of the first CSO exchanges in Q4 2019. Any CSO exchange will require extensive disclosure, KYC and AML requirements which will be outsourced to third party service providers as discussed in the previous question. The rules of the CSO exchange will also place key limitations on certain trading activities to protect against market manipulation and illegal behaviour.
How does the CSO model remove the risk of manipulation by third parties for the purpose of money laundering? i.e. organisations could be purchasing FAIRs with the end goal of transferring to fiat without an audit trail.
The risk against money laundering is significantly lower than in most traditional investment situations like in real estate and other traditional markets which are not subject to the blockchain. Within a CSO one can’t buy or sell FAIRs without meeting extensive KYC and AML regulations either inside of the CSO itself or on the CSO secondary market/exchange. And all transactions are transparent and are written to the blockchain—a transparent audit trail. The CSO smart contract and the CSO Exchange will have rules and limitations on trading (e.g. size of transaction/frequency of transactions, among others) to severely limit the possibilities of market manipulation and illegal activity.
How does the CSO model remove the risk of ‘Pump and Dump’ activity whereby large amounts are invested to artificially spike the price? By doing so a third party could manipulate the system to obtain profits.
It would be extremely difficult to effectively succeed in a “pump and dump” scheme within a CSO for the following reasons: (1) The CSO is structured for longer term investing and not geared for unregulated speculation. There will very likely be at least a one year holding period for all CSO investors in the Malta jurisdiction and the jurisdictions that RML is considering. In order to effectuate a “pump and dump” you need to get in and out of an asset quickly which you can’t do with a significant holding period. (2) There will also very likely be restrictions on the size of the daily, weekly, and perhaps even monthly transactions possible both in the smart contract and also on the secondary market depending upon the exact CSO exchange rules. To effectively manipulate the price or significantly profit through a “pump and dump” strategy, you need to be able to “pump” with large transactions and get the market to follow you and “dump” with large transactions within a short period of time. This will not be possible with a CSO that is properly designed that meets jurisdictional compliance and best practices. (3) Finally, the buy and sell price of the FAIRs are automated and are based on different bonding curves—one for the “sell” and a different one for the “buy”. As such it would be extremely difficult to successfully engage in a “pump and dump” strategy—because buying and selling prices are separated.
Are CSO Smart contracts transparent?
Yes, and to lower liability and regulatory risk best practices dictate a mandatory third party audit of the CSO smart contract. In jurisdictions like Malta, CSO s are likely to be subject to third party or government audit or certification.
Does the CSO smart contract handle KYC and AML on an automated basis and if so which company/software will handle this?
Beyond Enterprizes or one of NSL’s other trusted software developer contractors would write the smart contract. The smart contract would make an API-call to the KYC/AML third party service provider to make sure that appropriate KYC/AML requirements were met. The smart contract would be audited by a third-party systems auditor and would also likely be certified by the Malta Digital Innovation Authority.
What are the benefits of the CSO?
The CSO has many advantages over other means of raising money like traditional equity raise or even an ICO. Here is a comparison chart of the CSO versus other popular fundraising mechanisms such as an equity raise, ICO, IEO (Iniital Exchange Offering) or STO (Security Token Offering):
The key benefits of the CSO to the company’s key stakeholder constituencies are as follows:
- Company/Company Founder’s/CEO:
- Continuous raise: Rather than burden the founders or CEO with raising money every six months or so, the CSO , because it is continuous fundraising mechanism, diminishes the burden of the company to raise money because it remains as a fundraising mechanism for as long as it is in place–perhaps several years.
- No equity dilution: FAIRs in the CSO are not shares in the stock of the company so there is no dilution.
c. Incentivize employees better: FAIRs can be granted to employees like stock options with a vesting schedule. But unlike stock options, FAIRs are liquid and can be sold by the employee (within the rules of FAIR grant).
- Strong investor interest because of better liquidity: Investors are very interested in investing in CSO ’s set up by good revenue generating companies because of the better liquidity of the FAIRs versus equity or ICOs.
- Better liquidity: After the investor meets the holding period, typically of one year, the investor can sell his FAIRs in a secondary market or as a last resort to the company’s CSO as governed by the smart contract and the price automatically calculated therein using a formula based on a bonding curve.
- Lower risk because of the buyback reserve fund: The investor’s investment risks are much lower than with an equity investment or an ICO investment because the investor can sell his/her FAIRs to the buyback reserve fund which is funded usually by two streams– a small part of the investor’s investment monies and a small but significant portion of the company’s revenues. The investor’s holding period is similar to a maturity date for a promissory note or bond and that makes sure that enough money has accumulated in the buyback reserve fund to provide meaningful liquidity for the investor.
- Automated pricing because of the bonding curve: There is no subjectivity to the price for the investor to buy or sell FAIRs. The spread between the buy and sell price of the company’s FAIRs is determined by a formula using a bonding curve that is fixed in the smart contract.
- A secondary CSO market and even better liquidity for CSO investors: NSL, along with several key investors, are planning to launch a secondary market for FAIRs from CSO s by Q4 2019. NSL believes that most buying and selling of company FAIRs is likely to occur in the secondary market in between the fixed spread of the buy and sell price as determined by the bonding curve of the CSO fixed in the smart contract. NSL believes this because an investor will almost always get a better price on the secondary market between the price spread rather than the buyback fund, the buyer of last resort, at the bottom of the price spread.
- Employee: Better incentivization and alignment with the company’s interests: As discussed above, employees are not incentivized by stock options or tokens that may never be worth anything. Since FAIRs will be liquid and have value when the employee has met the vesting schedule, the employee’s FAIRs will provide better incentivization than stock options (or tokens). This will better align the interests of the company and its employees.
- Regulator: Much lower risk than equity investment or investment utilizing an ICO: As discussed above, the risk to investors is much lower than investing using traditional equity or an ICO. The need for regulation for the CSO concept is significantly diminished because of the buyback reserve fund, the automated way the buy and sell price is determined by the bonding curve and the similarity of raising money using the CSO concept to the issuance of a promissory note or bond. And there is also the possibility that the CSO is already compliant in a few jurisdictions because of the CSO ’s similarity to a promissory note or bond issuance. All of these factors diminish regulatory concern.
Are the slopes variables (b/s) already fixed? If not when will they be fixed? According to which criteria? Once fixed are they captured in the Smart Contract and therefore permanent going forward?
FAIR price calculation is determined by 2 functions (buy and sell) both curves are increasing with amount of FAIRs issued. So this rewards primarily early investors. The slope variables for the buy and sell bonding curves are fixed as part of the CSO architecture process to make sure (1) that there is sufficient “spread” between the buy and sell price to generate a healthy secondary market; and (2) that the company's profits captured in the buyback reserve fund will be sufficient to reduce investor risk and motivate investor participation. Once the slopes formulas are fixed they are captured in the Smart Contract and are permanent going forward.
Does the company buy / sell FAIRs at the same price as any other investor?
Yes, in the sense that the company buys under the same terms as other buyers. Because of how the bonding curve works, the FAIR price changes with every purchase of every FAIR so no one gets exactly the same price.
Will there be a secondary market for FAIRs?
Yes definitely. A secondary market will be the place for most transactions because of the spread between the buy and sell price and the fact that most investors want to sell their FAIRs at a price better than the price offered from the buyback reserve fund which is the buyer of last resort and will always offer a price that is worse than the one offered in the secondary market. Network Society Lab will have a CSO Exchange/ secondary market up and running with the first group of CSO s launched which include ReMeLife’s CSO. We expect there will be other exchanges as well that will trade FAIRs.
Do investors sell their FAIRs back to the company, assuming there is no secondary market.
They would normally sell their FAIRs to the buyback reserve fund if there is no secondary market (i.e. if there are no others that would buy their FAIRs
Can company decide to burn these or to keep /own these at current price?
A company can decide to burn FAIRs that it owns. The result of the company burning some of its FAIRs would be to raise the value of everyone’s FAIRs because there would be less number of FAIRs in circulation which would result in an increase in FAIR price
Who owns new minted FAIRs from company revenue? Company?
contractually bound amount of profit from the Company. FAIRs are newly minted at the time that they are bought by buyers whoever the buyers are.
Is the revenue amount allocated to go into fund fixed (aka written into smart contract) or does company reserve the right to change this over time?????
Yes the revenue (usually EBDITA) that is allocated into the buyback reserve fund is fixed and written into the smart contract. It can be a fixed percentage or it can be a formula so as to provide a bit more precision and flexibility but it cannot be changed as it is fixed in the smart contract.
What about losses, will they affect fund in any way? Ie if new minted FAIRS in fund are owned by company, can company sell to cash out as any other investor would do?
Company losses (or at least a string of monthly losses) might affect the psychology of the FAIR owners and they might sell their FAIRs if the Company’s performance looks bad just like with share owners that own shares of a company with mounting losses. The Company can sell its FAIRs but in doing so it will move the FAIR price lower (based on the bonding curve) so it has to be careful when it sells its FAIRs so as not to motivate a sell-off of FAIRs amongst the FAIR holders which could cause a precipitous fall in FAIR price.
What is cash out mechanism: always via Ether?
The cash out mechanism is whatever has been designed into the CSO — usually either some form of cryptocurrency or fiat— to ease purchasing and selling by FAIR buyers.
Is there a risk of FAIR dump after minimum investment period?
There is always a risk of the selling of an asset after a minimum holding period no matter what it is. To ameliorate the effects of that possibility, there will be some selling restrictions on the amount of FAIRs that you can sell during defined time intervals— which is the case for many assets. And since a large holder of FAIRs cannot sell his/her entire holding in one shot but has to stage his/her exit over a series of transactions, he/she will be motivated to not adversely affect the FAIR price too precipitously.
Will you be able to use the CSO as utility token in the future (this was one of your desires, if I remember correctly), or do you see yourself setting up a separate token mechanism for this model?
Even though the DAT funding mechanism is separate from the Company's utility token regime the Company plans to offer some incentivisation’s that will allow for utility token holders to benefit either directly or indirectly in buying FAIRs or offering some “conversion” regime for utility token holders.
& Current Status
What level of interest does Malta and other governments have in CSO's? Will Malta or another government allow a “sandbox” for CSO's?
NSL has discussed the CSO concept with government, industry and legal officials in three jurisdictions including Malta, Andorra, and Spain. There is great interest in the CSO concept, particularly in Malta and Andorra where those governments think that supporting and nurturing the CSO concept could provide differentiation for their respective countries and better attract key growth companies to relocate to their countries-- significantly improving economic development in their respective countries.
In Malta, key blockchain legal experts and regulators are currently reviewing the CSO under the new Maltese DLT law and possibly allowing the concept to be piloted in a legal/regulatory approved “sandbox”. NSL has discussed the “sandbox” with key government officials who have indicated support for the creation of a “sandbox” for the first CSO's created by NSL.
In Andorra and Spain, a preliminary legal analysis from a prominent Andorra and Spanish blockchain lawyer points out that the CSO is more similar to the issuance of the promissory note or a simple bond and is likely to be regulated as such.
Is NSL also pioneering the creation of a CSO Exchange in Malta? Will that help with investor liquidity?
Yes, NSL is pioneering the creation of a CSO Exchange in Malta—the first in the world-- and RML will be the beneficiary of being one of the first CSO's to be listed on it. NSL is planning to spend hundreds of thousands of euros to set it up and launch the DAT Exchange. Again, RML will become the beneficiary of all this expenditure to create and market the CSO Exchange.
The underlying CSO Exchange technology has been finished and the Exchange is planned to be launched in Q4 2019 in parallel with the setting up of RML’S CSO.
This new CSO exchange will instantly create a secondary market for CSO'significantly improving investor liquidity for the already liquid FAIRs.
The Blockchain Investor Consortium (BIC) has contacted NSL about its creation of the CSO Exchange and is showing significant interest. BIC members are contacting NSL about investing in the CSO Exchange. Once RML’s CSO is set up, NSL can include investment in RML’s CSO as an additional focus for BIC members’ investment monies.
How is NSL related to the emerging general AI ecosystem like Singularity.NET?
The founders of NSL (David Orban) and SingularityNET (Ben Goertzel) are friends and general AI colleagues. Both Orban and Goertzel have been experts in AI for more than a decade. Both companies set up and sponsored a general AI track at the Malta Blockchain Summit in May 2019 and announced the following partnership at the Malta Blockchain Summit in May 2019:
SingularityNET, whose decentralized platform lets anyone create, share and deploy AI services at scale, and Network Society Lab (NSL) who is pioneering the CSO, a new blockchain-based funding concept, announced a new partnership. SingularityNET will offer the CSO concept as one option available to members of the SingualrityNET X-LAB, their recently announced accelerator program. See http://netsoclab.com/2019/05/23/network-society-and-singularitynet-announce-new-partnership-to-grow-emergent-ai-networks/
Why did NSL choose ReMeLife to be included in one of its first 3 CSO’s?
NSL chose RML to be in the first group of CSO's because it wanted one of the first CSO's to not be in the financial services or fintech space like the other two. NSL also wanted a company poised to make a strong social impact globally in a critically needed area (like health care for the elderly). Plus, NSL was impressed with the traction that RML has made to date especially with UK’s National Health Service, Sharp, Amazon and the achieving of other critical UK go-to-market milestones. NSL also liked the tokenization/democratization of RML’s business model.
Is there any documentation to date in Malta re their evaluation of the CSO proposition?
NSL had four briefing sessions about the CSO with senior officials with Ministry of Economic Development—twice at their offices in April and May, once at a meeting at the Malta Blockchain Summit in late May and once in mid-September. At all four meetings the Ministry of Economic Development told me that the DAT concept, if approved in Malta, which it would very likely be, could be a substantial differentiator for Malta in attracting early stage and growth stage technology companies to relocate to Malta and also for top talent to relocate to Malta because of the difficulty that such companies in all countries have in raising money and how important money is to sustain technology companies. They cited that running out of money was the single biggest reason for failure of early stage companies and that good access to investment monies was one of the biggest reasons for companies to relocate to a new jurisdiction. They said that because of the strategic nature of the CSO and what it could mean to Malta, that it would be very likely for Malta to agree to a sandbox to test the concept. They invited NSL to present the DAT and the results of the regulatory sandbox tests at their next annual conference.
NSL also met with the Malta Digital Innovation Authority leadership three times—in April, May and late May. In all three meetings he told me that the CSO concept is compelling and that a sandbox would be the likely way forward. He told me to coordinate CSO approval with the Ministry of Economic Development and also to coordinate with a top blockchain law firm and he and they would package it up for approval by the Ministry of Financial Services (MFSA) because the Malta government was imminently looking to do two things quickly:
(1) to extend the scope and flexibility of the recent blockchain regulations to any blockchain-based financial instruments (like the CSO ) including STOs; and (2) while they were promulgating such new regulations they would be formalizing the process for testing such new blockchain/traditional financial instruments (like the CSO using the sandbox concept. The government issued documents and sought public comment for both subjects with the public comments due today. See the following link to the public comment documents:
With regard to STOs and blockchain-based financial instruments:
With regard to MFSA regulatory sandbox:
NSL and its top blockchain law firm E&S provided its comments to the Maltese government on both documents.
Now that all of the above is has been done, NSL is in the midst of a series of meetings and discussions with both the Ministry of Economic Development and the Ministry of Digital Innovation to:
- Discuss NSL’s thoughts how we should proceed with respect to the DAT sandbox including recommending sensible guidelines/limitations;
- Reveal the first 3 CSO clients; and
- Providing an update on the progress with SiGMA for the market launch of the CSO at the Malta AI and Blockchain Summit in November.
And after those meetings with the Ministries, then NSL, E&S and those Ministries will push for the formal authorization of the CSO sandbox at the MFSA during the next 30-60 days.
Keep in mind that although Malta approval of the regulatory sandbox is highly likely, NSL’s discussions with key knowledgeable legal authorities in Andorra and Spain point to the fact that we can launch a CSO , with minor adjustments, without further governmental action—meaning that we can launch RML’s CSO without any delay if any complications arise in Malta.
Can the smart contract ‘algorithm’, that manages the transaction and the bonding curve, be changed by the company representatives at any time? Thereby disadvantaging FAIR holders. Or is it locked up in the first block and so is unchangeable?
The smart contract cannot be changed after it is published. It is locked and unchangeable.
What happens if a company wants to change the terms of the CSO?
The most likely scenario would be to start a new CSO with new smart contract with different terms than the first CSO while the first CSO is still running. There is no reason why a company couldn’t have multiple CSO's with different terms just like a company could issue multiple corporate bonds.
What happens to the FAIR holders, if the company closes the CSO?
A company shouldn’t close their CSO if there are still FAIR holders. In the worst case scenario, the company should contact each remaining CSO FAIR holder and negotiate a suitable mutually acceptable deal so the company could wind up the CSO.
What is NSL’s role in the CSO?
The CSO is a brand new fundraising concept and NSL proposes to set up a CSO for RML as one of the very first set of CSO's, in order to gain compliance with jurisdictions like Malta and others that have informally shown interest in the concept and have a history of innovation in the areas of blockchain technology and financial services.
NSL provides 360-degree services to create CSO'sfor clients including strategic consulting and development which includes writing the smart contracts which contain the requirements for the CSO including the bonding curve algorithms which control the buy and sell prices of the fractionalized portions of the CSO called FAIRs.
What experience does NSL and its partners have in helping companies fundraise using fundraising mechanisms other than the CSO?
NSL and it partner Beyond Enterprizes have considerable experience in many traditional and non-traditional fundraising mechanisms beyond the CSO including:
- Equity: Raising money using a private offering or a convertible promissory note. The combined team has decades of experience advising companies about equity raises.
- ICO: Raising money using an initial coin offering (ICO) also known as a token offering. The combined team has been involved in advising and investing in more than 30 ICOs.
- IEO: Raising money using an initial exchange offering (IEO). This mechanism has only in been in vogue for about a year or so. Beyond Enterprizes has been involved in several IEOs.
- STO: Raising money using a secured token offering (STO). This mechanism is new and the team has limited experience in this mechanism. Blockstack, the first STO done in the US under the SEC’s Regulation A+ was just completed in September 2019 and cost more than $2 million and took nearly one year to complete.
In addition, NSL and Beyond Enterprizes have considerable experience in helping client companies tokenize their businesses.
& The DAT
What benefit does RML receive as one of the first CSO's?
NSL has spent the last nine months educating the government of Malta—specifically its Ministry of Economic Development called Malta Enterprise and the Malta Digital Innovation Authority-- and key legislative, technology, legal and business influencers about the benefits of the CSO concept and how the CSO can be a key strategic advantage for Malta in attracting foreign investment and attracting new companies in key technology sectors like blockchain.
NSL spent more than EUR 30,000 in cash and equivalent value at the Spring Edition of the Malta Blockchain Summit in May 2019 marketing the concept to the blockchain industry. NSL is about to invest even more money and resources at the Fall Edition of the Malta Blockchain Summit in November 2019 including sponsorships, booth space, social media video production and text posts, and speaking engagements. NSL’s marketing focus will be to make the attendees (likely to be more than 8,500 of the world’s pre-eminent blockchain industry luminaries and investors) aware of the CSO and aware of the first CSO's including RML’s CSO . RML representatives will be featured in NSL’s booth, social media posts and all of its marketing activities. The value of all of these activities if RML were to buy them separately, would be well in excess of EUR 50,000— with just the value of the Gold Sponsorship that NSL has acquired at the show from its organizers costing EUR 20,000.
And, NSL plans to spend hundreds of thousands of euros and pioneering the creation of a CSO Exchange in Malta—the first in the world-- and RML will be the beneficiary of being one of the first CSO's to be listed on it.
We need to ensure our existing Directors Liability cover Insurance coverage satisfactorily covers risk in relation to this novel financing methodology. The insurer has asked; Is there a barrier to entry for the purchase of FAIRS? As tokens FAIRs will purchased in anticipation of future profits how do you ensure all those investing are aware of the risks?
The CSO disclosure document –similar to an ICO white paper--that will likely be required by the regulatory sandbox in Malta and will likely be seen as a best practice, will be required to thoroughly disclose all risks to investors.
In the earliest stages of the RML CSO in order to qualify for Malta (or any other jurisdictional compliance), there will also very likely be a requirement that such investor prove that he or she is a qualified, sophisticated or accredited investor status as those terms are defined in the country in which the investor has legal residency. Such investors because of their experience are used to asking the right questions and seeking the necessary information to evaluate investor risks.
What is your NSL’s relationship with Thibauld Favre, and how is he working with regulators to achieve a successful outcome? Are Is you NSL working in together with him?
Thibaud Favre invented the Continuous Organization and CSO concept in September 2018. NSL have been in discussions with Thibaud and his company, Fairmint, since April 2019 including inviting Fairmint representatives to present at the Malta AI and Blockchain Conference in November 2019. Fairmint and NSL are in the midst of discussing a partnership. Fairmint is primarily focused in the US market which arguably has the most difficult compliance regime in the world. For example, the first blockchain-related fundraising offering to secure approval by the SEC was just accomplished in September 2019 by Blockstack https://www.crowdfundinsider.com/2019/09/151426-blockstack-reports-23-million-raised-in-first-reg-a-token-offering/ The cost for Blockstack to secure SEC approval was more than USD 2 million and the time it took Blockstack to secure SEC approval was almost a full year. Whilst NSL applauds Fairmint in tackling the US jurisdiction, many companies don’t have the financial resources or time required to properly secure US regulatory approval under the current SEC regulatory environment. Hopefully, over time all key jurisdictions will come to see the CSO as a straightforward way of raising money that is not too much different than raising money using a corporate bond or other such debt instrument and will not require a complex, expensive and time consuming process to launch it. NSL has found the experience in discussing the CSO concept with blockchain-friendly European jurisdictions to be a more promising, lower cost and faster approach at least at the moment.