Net Neutrality- What is an NPRM?

An NPRM is a Notice of Proposed Rule-Making. 

This is fancy-speak, but basically it describes an announcement that the government agency (in this case the FCC) is considering making rules about an issue (can be anything) and will be giving the public of the US the chance to have their voices heard. This is called a period of public commentary, BUT all comments to be considered must be submitted through an official form ( For this proposal and your comments, all comments must be submitted by Monday the 15th of September, EOD. 

The contents of the NPRM contain three highlighted three rules:  keep the Internet “as an open platform enabling consumer choice, freedom of expression, end-user control, competition, and the freedom to innovate without permission.” These “rules” would make transparency on all broadband provider’s practices a requirement. Basic practices include: blocking any lawful website, app or mobile website and the banning of “commercially unreasonable practices.” A reason these practices are emphasized is this: there is no standardized process through which broadband providers can choose which sites and which content can be displayed. As it is, without transparency in these practices, ISPs are left to their own discretion. 

But… what do these rules even mean?

The requirement of transparency would make it an obligation for ISPs to share a performance report publicly. This performance report would include necessary information- Internet speed, traffic/congestion, blocking and paid priority agreements. After all, transparency means… just that, transparency!

"No blocking" would keep any ISP from the straightforward blocking of any lawful content or site, for whatever reason. An example: blocking sites of ISPs competitors! Practical, I think. 

The last rule mentioned, the banning of commercially unreasonable practices,” has a bit of grey area. It is a tiny step towards the banning of unfair business practices. i.e. slowing down your internet access if a consumer pays for a particular internet speed. Basically, if you pay for a service, you get the service you pay for. Simple. 

This blog entry is the second in a short series on net neutrality and how it affects businesses, consumers and society at all levels. It will be an impartial series, stating fact and not bringing opinions to the table. As a blogger for a company, I will remain objective and leave the debates up to the audience!

Links below for pertinent information:

For more information on net neutrality, here’s the wiki:

To submit comments to the FCC on the new proposal,

For more information on the proposal itself:

Thanks for reading, 

Emily Kaput

Net Neutrality- A Short (American) History

What, exactly, is net neutrality? ….”the principle that Internet service providers should enable access to all content and applications regardless of the source, and without favoring or blocking particular products or websites.”

The Federal Communications Commission has been acting on net neutrality for quite some time now. In 2010, the FCC issued its Open Internet Order, where Internet service providers were now prohibited from blocking content and prioritizing certain kinds of traffic. Ont he consumer side, these rules looked like they were too weak (they did not cover mobile web providers), but on the telecommunications established companies side it looked like the Open Internet Orders new regulations were too strong (they would have preferred more wiggle room.) 

Internet Service Providers (ISPs) are classified as “Information Services. Law states that no discrimination/price regulations are necessary for “consumer protection.” Essentially, what this means is that the FCC hasn’t the authority to regulate ISPs. On the flip side, however, the FCC does have the authority to regulate inter-state and international communications. 

After a considerable amount of back-and forth between Verizon, the FCC and the DC Court of Appeals, the judicial system agreed with Verizon- the Commission did not, in fact, have the authority to implement regulations that would limit ISPs (like Verizon) in their ability to block/discriminate against websites. Reason: unless the Internet is reclassified as a public utility, the FCC has no jurisdiction. 

However, the DC Court of Appeals did say that the FCC has some ounce of authority to establish net neutrality rules as long as it promotes broadband deployment all across the nation. 

That tiny bit of leeway was all the FCC needed to bring forth this new proposal. It’s open for comment to the public, until Tuesday September 15th, 2014. 

This blog entry is the first on a short series on net neutrality and how it affects businesses, consumers and society at all levels. It will be an impartial series, stating fact and not bringing opinions to the table. As a blogger for a company, I will remain objective and leave the debates up to the audience!

Links below for pertinent information:

For more information on net neutrality, here’s the wiki:

To submit comments to the FCC on the new proposal,

For more information on the proposal itself:

Thanks for reading, 

Emily Kaput

After such an act of realpolitik from the island we have seen incoming due diligence demands from various part of the world including Jersey. It wasn’t just our traditional fund client base that contacted us but also more conservative industry players, such as private banks that are approaching us due to increasing requests from their high net worth, risk aware clients. It’s the first time we’ve seen such traction.
Director Jean-Marie Mognetti, Global Advisors

Daniel Cawrey from CoinDesk gives a straightforward account of what happened at CoinCongress last week- 

CEO Alan Safahi delivered the Keynote talk to open the conference, playfully noting: “I guess I am the oldest guy in this space, so they asked me to talk about the state of bitcoin.” 

Alan also spoke of how companies have emerged in the Bitcoin space, and how they are actively lending further legitimacy to the currency (even without regulation from an overarching power.) Important companies noted were Coinbase, Kraken, BitGo, and Circle. 

BitLicense- Some Comments from CEO Alan Safahi of ZipZap, Inc.

As a community, we all knew that regulation would come down onto virtual currencies at some point. In fact, it is incredible that a BitLicense hasn’t been proposed before now.

The New York Department of Financial Services (hereinafter NYDFS) is the first institution to attempt to make a BitLicense framework that could both protect the general public and provide clarity for virtual currency entrepreneurs so that they can continue building their businesses without fear of being in violations of any laws.  

I have, in the past, alluded to how regulations would affect the Virtual Currency Community and why regulations are necessary (NY Bitcoin Conference, 2013.) Many people rejected this idea that regulations are necessary- yet here we are today, faced with a BitLicense proposal that could either stifle the market OR aid it in growing to its full potential.

 This first draft of the BitLicense is important. The weight and levity of this document cannot be stressed enough. Once this document, with its regulatory clauses and sub-clauses, is passed it will set precedent for all BitLicenses to come.

 As it stands, it is very much a well-rounded and well-thought through document. As many of you can see, it is also very biased (in favor of stringent regulation.) NYDFS has given the Virtual Currency Community an opportunity to have its voice heard, albeit in a totally unreasonable timeframe of 45 days. Many small entrepreneurs (majority of bitcoin startups) do not have resources at their disposal to properly analyze and respond to this proposed legislation in such a short period of time.

 Market and community leaders have voiced strong opinions on the majority of the document including the need to extend the time for comments by several months. To effect real change in the document itself, however, there cannot be a mass of incoherent complaints, suggestions and opinions. If the Virtual Currency Community could band around a few of the proposed changes surely we could affect some change in the framework.

Some of my observations on the BitLicense framework (what needs to be changed/paid more attention to):

-       Clarifying the definition of digital currencies (what’s included, what’s not).  This is not a simple task, but it must be done. 

-       Limiting licensing requirements to apply only to custodial relationships such as exchanges (those involved in buying and selling currencies) not other categories like multi sig wallets, software providers or anyone who receives or transmits crypto currencies

-       Applying licensing requirements only to exchanges based in NY or those doing buy/sell orders with people in NY

-       Creating several tiers of licensing for start ups (less than $1M in annual volume, no license needed), small enterprises ($1M-$10M/yr, one page application), medium enterprises ($10M -$100M/yr, long form application with small bond and fee requirements ), large enterprises ($100M-$1B/yr, audited financials, higher fees and bonds) and global enterprises ($1B+/yr, highest fees and bonds, annual audits).  Tiered licensing has proven to be a successful tool in allowing smaller businesses to abide by regulations while not crippling them. 

-       Changing “Permissible Investments” to allow investments in digital currencies for all using their own funds and to vary for custodial funds depending on licensing tiers proposed above (e.g. no regulation for startups and small enterprises, moderate “guidelines” and controls for larger enterprises for risk management and asset allocation purposes). 

-       Limiting KYC requirements to purchases made in excess of $1000 (similar to prepaid cards bought at grocery stores)

-       Changing Reserve requirements to mirror that of banks and credit unions.  The capital reserve requirements for a business in Virtual Currencies should not be any different than capital reserve requirements for existing banking and financial institutions. To force larger reserve requirements on virtual currency businesses would give an unfair advantage to the already-established banking and financial services businesses. By holding virtual currency businesses to the same standards as existing financial institutions it will increase the accountability of the new virtual currency institutions while not unnecessarily crippling them. *Capital Reserve Requirements: Reserve requirements are the amount of funds that a depository institution must hold in reserve against specified deposit liabilities.

-       Eliminating the redundant need for state level monitoring (if FinCEN rules were good enough for Financial Institutions, they are good enough for Bitcoin exchanges).

Many of these points have been repeated across the internet, and I hope that adding my voice to the masses will help influence this momentous development in the Virtual Currency realm. BitLicense is here, let’s get to work!

Have we got some news for you! ZipZap is now open in 34 countries around the world!

From Simon, SVP of BizDev at ZipZap: “ZipZap has a commitment to simplify and democratize payments worldwide,” said Mr. Simon Nahnybida, Senior Vice President of Business Development at ZipZap. “We are now enabling more consumers with the power to easily, safely and securely buy digital currencies at affordable prices using multiple payment options.”

Here’s a short piece by Newsbtc - Today’s Bitcoin News on the expansion through Europe:

Transaction network ZipZap has announced plans to expand into a whopping 34 countries in Europe thanks to strategic partnerships.

Buy With Cash Anywhere You Go: ZipZap Expands Global Cash Transaction Network To 20,000 UK Retail Locations Through Payzone Partnership

SAN FRANCISCO, June 24, 2014 /PRNewswire/ — ZipZap, Inc. (, the leading global transaction network, today announced its expansion to the UK through a partnership with Payzone (, one of UK’s leading consumer payments and cash distribution networks.

With this partnership, ZipZap now offers an easy way for UK residents to buy digital currencies at more than 20,000 retail payment center locations; UK users can also buy digital currencies like bitcoin, Lite coin and Dogecoin through one of ZipZap’s exchange partners such as ANX, Bittylicious and

"Many UK consumers prefer dealing with cash without having to disclose their banking information," said ZipZap’s Simon Nahnybida, SVP of Business Development. "Our partnership with Payzone allows customers to easily buy digital currencies online and pay at convenient locations within a walking distance from their home or work."

Payzone is one of the leading consumer payments and cash distribution networks in the UK, allowing consumers to manage prepaid phone plans, transportation ticketing and now their digital wallets.

"We are very excited to partner with ZipZap and participate in the digital currency economy," said Mark Mellor, Director of Sales and Marketing at Payzone. "We strive to provide the best products and services with the utmost convenience and ZipZap’s practices fall in line with our belief of providing quick and cost-effective payment services to consumers whilst offering an extra service for our merchants to add to their Payzone basket of services."

While electronic payments (via credit cards, debit cards, PayPal, etc.) overall will see double digit growth in the next few years, we expect to see an exponential growth with digital currency and cryptocurrency in the next two to three years,” said Gil Luria, analyst and managing director at Wedbush Securities. “We believe the UK, in particular, may be an early adopter of Bitcoin technology because of its substantial money remittance markets, which can be served by the lower price point of Bitcoin-based remittance services. “

In additional support of the UK expansion, ZipZap recently partnered with IDology one of the leading provider of innovative technology solutions for businesses, to support ID verification to help deter fraud and meet compliance standards.

About ZipZap:

ZipZap, Inc. is a global payment network, enabling consumers to buy, sell or use digital currencies with cash or other payment options. Founded in 2010, ZipZap is headquartered in San Francisco, California, with operations around the globe. For more information about ZipZap,

About Payzone:

Payzone is one of the leading consumer payments and cash distribution networks in Europe. Headquartered in Dublin, it has operations in 21 countries across Europe, processing over 630 million transactions per year on behalf of its clients. These transactions have a yearly value of over €13 billion Euro and are handled electronically through the Payzone network of over 240,000 points of service (terminals, vending units and EPOS tills) at more than 170,000 retail locations across Europe. Payzone offers a wide range of services including pre-paid mobile phone top-ups, energy pre-payments, bill payments, pre-paid Visa vouchers, local and housing authority payments, pre-paid Visa and MasterCard payment cards, payment vouchers for on-line shopping, gift card and loyalty programs, transport ticketing, lottery games, parking and electronic road tolling, debit and credit card acceptance, contactless payment solutions and world-wide money transfer services. Payzone also operates approximately 6,000 ATM cash dispensers in the UK and Germany. For more information, visit

Karen Sorenson