This has probably been talked about before, but I'd be interested to know if this could apply to B.EXCH. The full release does reveal that the US Securities Commission actively monitors BITCOINTALK Forum. Most nations have a similar US Securities Enforcement counterpart. You might be of interest to them 20's as it appears you are offering THREE unregistered securities not just two like Voorhees. And this business with the daily NAVs makes things look like mutual funds. You are digging your own grave. Do seek legal advice before writing anymore (but I fear it is too late.)
No one is beyond the law.
And I'm extremely interested in this "full disgorgement" process i.e. does the disgorged money go to the "shareholders" or to the Feds? (We all know the answer.) So then, how many "shareholders" would actually petition the Fed for redress?
http://www.sec.gov/News/PressRelease/Detail/PressRelease/1370541972520#.U9b6rY1dUtQ:
Washington D.C., June 3, 2014 — The Securities and Exchange Commission today charged the co-owner of two Bitcoin-related websites for publicly offering shares in the two ventures without registering them.
An SEC investigation found that Erik T. Voorhees published prospectuses on the Internet and actively solicited investors to buy shares in SatoshiDICE and FeedZeBirds. But he failed to register the offerings with the SEC as required under the federal securities laws. Investors paid for their shares using Bitcoin, a virtual currency that can be used to purchase real-world goods and services and exchanged for fiat currencies on certain online exchanges. The profits ultimately earned by Voorhees through the unregistered offerings totaled more than $15,000.
Voorhees agreed to settle the SEC’s charges by paying full disgorgement of the $15,843.98 in profits plus a $35,000 penalty for a total of more than $50,000.
“All issuers selling securities to the public must comply with the registration provisions of the securities laws, including issuers who seek to raise funds using Bitcoin,” said Andrew J. Ceresney, director of the SEC’s Division of Enforcement. “We will continue to focus on enforcing our rules and regulations as they apply to digital currencies.”