If you deposited €100 into a pegged account this would display €100 on your statement. This does not mean we are holding Euro deposits but simply that the balance of btc in the account in denominated in Euros. As the btc/Euro rate rises and falls adjustments will be made to the underlying Btc balance to ensure its Worth is €100. It's expected that 98% of the accounts will be pegged accounts
The statment is in Euros, you are in effect holding Euros, nothing to do with Bitcoins whatsoever, as Bitcoins are not pegged to Euros. The regulators will see through that.
Do you intend to actually give the customer access to Bitcoins or the details of the Bitcoins they own, or just suggest that somehow their Euros are invested in Bitcoins 'behind the scenes'?
I thought the same as you - until I read the prospectus.
When you 'deposit' euros with them what's actually happening is that:
1. They're selling you bitcoins - which are held in an address that is specifically yours.
2. If you choose to leave the bitcoins with them then thereafter the amount of bitcoins in that address are adjusted so as to always have a value equivalent to the euros you deposited.
3. They agree to buy the bitcoins back from you at their current value at any time.
Because they immediately sell you bitcoins, for it to be a banking arrangement bitcoins would need to be considered currency. But at present Cyprus are explicit that bitcoins are NOT currency. So whilst they're holding SOMETHING on your behalf it isn't the type of something (currency) which requires a banking licence according to the relevant authorities.
That's the theory anyway - and they've been told it's fine. Which I have no reason to disagree with. It may SEEM like it's a pretence to avoid admitting that they're running an unlicenced bank - however any such pretence is only occurring at the request of the authorities who would be the ones to complain if they believed it WAS an unlicensed bank.
If the very people who are responsible for regulating banks say "That isn't a bank because bitcoins aren't money" then you have a pretty sound basis for believing you're fine with them. Doubly so if you're the ones saying "but we WANT bitcoins to be treated as currency and for us to be able to register as a deposit-receiving institution" - which IS what these guys are saying.
It'll be interesting to see the contracts for customers.