Cryptocurrency Exchanges Should be Self Regulated - US Think-Tankhttps://cryptovest.com/news/cryptocurrency-exchanges-should-be-self-regulated---us-think-tank/
I agree with this sentiment, but what it will take for self regulation of this industry is a group of highly motivated individuals to get the ball rolling. What better place to get the brainstorming started than right here with the DNotes community?
First we are going to need to draft up policies, guidelines, and standards that the entire industry agrees to abide by. For those who are unfamiliar with these concepts, here is a great breakdown:
https://frsecure.com/blog/differentiating-between-policies-standards-procedures-and-guidelines/Procedures are decided by individual exchanges in house, but we can start a list of proposed policies, guidelines and standards that will help keep cryptocurrency innovative, competitive, safe, practical, and ethical. Add to this list of suggestions as you see fit.
POLICIES-Universal know your customer policy on transactions involving large sums of money
-Abide by the laws in your jurisdiction(s) of operation or make a good faith attempt to do so if operating in a new sector that is devoid of applicable legal framework (eg. ICO)
-Customer funds may not be traded, sold, or transferred (without good reason and due care) unless these actions are initiated by the customer who owns those funds.
STANDARDS-Minimum fractional reserve requirements that must be met by all institutions who practice fractional reserve banking schemes
-Quantification of usury as a percentage and condemnation of its practice
-Transparency in listing fees and maintenance costs
-Truth and transparency standards in advertising
-Loan screening/background checks above a certain dollar value threshold
GUIDELINES-Offer responsive customer support
-Provide business credentials and contact information to your customers
-Report suspicious activity to the proper authorities
How about NO fractional reserve banking at all. Just use funds the way the customer thinks they are being used. If a customer wants to tie up some funds in a loan, maybe said exchange could offer some options. A few exchanges already offer the ability to lend to margin traders at interest and that's always fun to participate in if you have some BTC you're willing to tie up for a few days. There could be some kind of interest bearing loan for a set amount of time where the user lends money to the exchange for the exchange to invest in infrastructure or whatever and the loan gets paid back in an agreed upon manner. But I don't think an exchange should ever believe that because they consistently have a certain amount of funds on their exchange at any given time, they are free to spend those funds in other ways. To be able to do that, you really need to be a bank, not an exchange, and it's arguable as to whether or not banks should even be doing that in the first place.
The way in which limit orders are processed needs to be fully disclosed. Most people assume limit orders fill in the order they were placed. That should be stated. If there's a different process, that should be disclosed as well. If there are hidden orders, that needs to be disclosed (not the individual hidden orders, but the fact that there are hidden orders), and the way to place a hidden order should be clearly explained.
Any wallet maintenance that disables any part of the wallet function (such as withdrawals, deposits, etc.) needs to be done with very regular progress updates and ETAs for going back online. And if for any reason an ETA can't be reached, then a new ETA with a good explanation for why earlier one wasn't reached needs to be posted. All that info should be accessable from each user's wallet page. That will cut down significantly on support requests so I don't see why more exchanges don't do this anyway.
State of the art security for customer funds needs to be a high priority. I believe specific security standards should be developed by IT people who understand that stuff. Related to that, there should be standards set for how many "glitches" are allowed per day or any other interval, where things aren't working as expected, and standards can be drawn up for how to minimize those issues, which are usually related to scaling. Some kind of minimal infrastructure could be a requirement to receive a certain type of rating (such as A, B, C, etc.). I think in a similar way to how there are standards and recognized procedures for how to build bridges, automobiles and airplanes, there can be those standards and procedures for how to build exchanges. Some things that you can throw together in your garage may be OK for a very small group of people but won't hold up when your user base grows beyond a couple thousand users.
All fees need to be clearly disclosed both ahead of time and as transactions are being set up.
A really nice feature BitTrex has is the ability to go straight to a coin's wallet from the market page so you can make a deposit of that coin without leaving the market page. Another feature I like in BitTrex is having a coin hyperlinked to its market so you can go directly to the desired market from your wallet.
Thorough transaction records need to be kept and made accessible to users via export and API at any time (with maximum allowed "outage" periods). Trading records need to include what coin was bought, what coin was sold, and how much of each, time stamp of trade, and what fees were paid in what currency.
Full disclosure on procedures for customers reclaiming funds in the event of a hack. I would like to log in to an exchange and be able to know ahead of time how the exchange will handle the return of my funds if despite all security measures, funds get stolen. The main reason is that the better prepared to handle an event such as a hack resulting in loss of funds, the less likely such an event is to happen.
I'm sure I can think of more...