Benjamin Lawsky: ‘I’m Doing No Work in the Digital ...

XRP Isn’t A Security, Declares Former CFTC Chairman

XRP Isn’t A Security, Declares Former CFTC Chairman
https://preview.redd.it/8yehv8lzsce51.jpg?width=960&format=pjpg&auto=webp&s=69f0a6eb4973a5a9974e42d15709434719a26a81
When Chris Giancarlo was the chairman of the Commodity Futures Trading Commission he became a rock-star of sorts in certain corners of the cryptocurrency community, helping establish criteria that eventually led to bitcoin and ethereum being declared commodities, more like coffee or sugar than stock in a company. The U.S. Securities and Exchange Commission largely followed suit, eventually also declaring that bitcoin and ether, the cryptocurrency powering the ethereum blockchain weren’t securities.
Now chairman emeritus Giancarlo, who was deemed “Crypto Dad” following an impassioned speech he gave to Congress where he credited bitcoin for finally getting his kids interested in finance, is at it again, having co-written a detailed argument published this morning in the International Financial Law Review for why XRP, the cryptocurrency formally known as “ripples,” was also not a security. The only problem is he’s no longer a regulator. In fact, his employer is on the payroll of Ripple, the largest single owner of XRP, whose co-founders actually created the cryptocurrency.
The bombshell paper, titled, “Cryptocurrencies and U.S. Securities Laws: Beyond Bitcoin and Ether,” co-authored by commodities lawyer Conrad Bahlke of New York law firm Willkie Farr & Gallagher LLP, methodically reviews the criteria of the Howey Test, established by the SEC in 1946 to determine whether something is a security, and point-by-point argues that XRP does not qualify. Rather, the paper argues, like its name would indicate, cryptocurrency is a currency of perhaps more interest to the Federal Reserve and central banks than securities regulators.
What’s at stake here to the cryptocurrency world cannot be overestimated. XRP is now the fourth largest cryptocurrency by market cap, with $5.9 billion worth of the asset in circulation according to cryptocurrency data site Messari. While Ripple was valued at $10 billion according to its most recent round of funding, the company continues to fund itself in part by selling its deep war chest of 55.6 billion XRP, coincidentally valued at the same amount as the company itself.
Not only could an eventual decision by the SEC to classify—or not classify—XRP as a security impact the untold individual owners of the cryptocurrency, but other clients using Ripple services that don’t rely on the cryptocurrency, including American Express, Santander, and SBI Holdings could stand to be impacted positively or negatively depending on the decision. After all if XRP were to be rescinded it would be a huge cost to their software provider. If Giancarlo is right though, Ripple could end up being one of the most valuable startups in fintech.
“Ultimately, under a fair application of the Howey test and the SEC’s presently expanding analysis, XRP should not be regulated as a security, but instead considered a currency or a medium of exchange,” Giancarlo and Bahlke argue in the paper. “The increased adoption of XRP as a medium of exchange and a form of payment in recent years, both by consumers and in the business-to-business setting, further underscores the utility of XRP as a bona fide fiat substitute.”
Giancarlo was nominated to be a commissioner of the CFTC by then-President Barack Obama in 2013. In 2015, he helped lead the thinking behind the CFTC’s decision that bitcoin and other cryptocurrencies were commodities, paving the way for the SEC’s related comments that neither bitcoin nor ethereum are securities. Then, at the height of the 2017 cryptocurrency bubble President Trump nominated him to be Chairman of the CFTC, where he oversaw the creation of a number of bitcoin futures projects, including at CME Group and the short-lived effort at Cboe.
While many blame the creation of bitcoin futures for popping the 2017 price bubble, which almost hit $20,000 before halving today, others have seen the works as a fundamental process of maturity, helping pave the way for more sophisticated crypto-enabled financial offerings. Giancarlo’s last day in office at the CFTC was in 2019, after which he promptly got involved helping envision the future of assets issued on a blockchain. In November he joined as an advisor to American Financial Exchange, using ethereum to create a Libor alternative. The following January he co-founded the Digital Dollar Project leading the push to use blockchain at the Federal Reserve and now it would seem he’s hoping to influence the classification of XRP as he did for bitcoin and ethereum, but from the other side of regulation.
Importantly however, a footnote in the report discloses that not only is Giancarlo and Bahlke’s firm, Willkie Farr & Gallagher LLP counsel to Ripple Labs, but they “relied on certain factual information provided by Ripple in the preparation of this article.” While it’s impossible to parse what information came from the co-authors and what came from Ripple, the resulting legal argument is fascinating, even if it does leave room for doubt.
The Howey test Giancarlo uses to bolster his arguments is a three-pronged definition used by the SEC, none of which he says apply to XRP. The first prong, is that an investment contract should be implied or explicitly stated between the issuer of the asset, in this case XRP and the owner, in which money exchanges hands. “The mere fact that an individual holds XRP does not create any relationship, rights or privileges with respect to Ripple any more than owning Ether would create a contract with the Ethereum Foundation, the organization that oversees the Ethereum architecture,” he writes.
This does however overlook the fact that OpenCoin, credited on Ripple’s own site in 2013 for creating XRP (then tellingly described as “ripples”), was run by many of the same people that founded Ripple. The original creators of XRP then donated the vast majority of the assets to Ripple, which they also ran, creating a sense of distance, tacit though it may be. The actual data around the creation of XRP was also muddled by a glitch in the code that means unlike bitcoin and ethereum the crucial genesis data is no longer attached to the rest of the ledger. The rebranding of “ripples” as XRP further extended the sense of distance between XRP and Ripple, followed by an aggressive campaign to get media to stop describing the cryptocurrency as “Ripple’s XRP.”
With so much distance between the company that actually created XRP and the company that now owns more than half of it, one would be forgiven for wondering, if there was an implied contract between OpenCoin and XRP owners, does the donation from one group of people at one company to a very similar group of people at another company sever that responsibility? In spite of the sense of distance created by Ripple between itself and the cryptocurrency its co-founders created, a number of active lawsuits alleging securities violations have been filed. In all fairness though, Giancarlo appears to recognize this prong may not be Ripple’s strongest defense and concludes the section, hedging: “Even if XRP were to satisfy one or two of the “prongs” of the Howey test, it does not satisfy all three factors such that XRP is an investment contract subject to regulation as a security.”
The second prong of the Howey test stipulates that there can be no “common enterprise” between shareholders or a shareholder and the company. While refuting both relationships, Giancarlo curiously goes onto to write that “given the juxtaposition between XRP’s intended use as a liquidity tool, its more general use to transfer value and its potential as a speculative asset, XRP holders who utilize the coins for different purposes have divergent interests with respect to XRP.”
Ironically, there has always been a widely held belief that owning a cryptocurrency would unify interests around a single goal: to co-create the infrastructure that lets the cryptocurrency exist and ensure it was vibrant and diverse. Meanwhile, XRP, in spite of its aggressive supporters on social media, is one of the least diverse ecosystems, with the vast majority of serious development being done within Ripple. If XRP owners aren’t expecting an increase in value from the work being done by Ripple, they certainly aren’t nearly as involved in helping build that future as are owners of bitcoin and ethereum.
In a related issue, the third prong of the Howey test stipulates that “no reasonable expectation of profit should be derived from the efforts of Ripple,” according to the paper. Supporting this position, Giancarlo writes: “Though Ripple maintains a sizable stake of the XRP supply and certainly has a pecuniary interest in the value of its holdings, it is not enough to suggest that a mutual interest in the value of an asset gives rise to an expectation of profits as contemplated by Howey.” Again, this strains credulity.
According to its own site, Ripple currently has access to 6.4% of all the XRP ever created. But that doesn’t count the 49.2% of the total XRP Ripple owns, but is locked in a series of escrow accounts that become periodically available to Ripple and Ripple alone. Adding those two percentages together leaves a float of only about 44% of XRP that has been distributed for public ownership. For some comparison, Facebook went public the same year XRP was created and has a 99% float, according to FactSet data, meaning almost all of its stock is in the hands of traders.While Ripple does also have more traditional stock, this distribution shows that Ripple might not be as distributed as it claims.
While it’s perhaps no surprise that Giancarlo would come out on the side of his own client, there’s also plenty of other reasons to believe his argument may in fact hold water. In February 2018, the notoriously compliant exchange Coinbase added support for XRP, something it would unlikely do if it were concerned it might accidentally be selling an unlicensed security. Perhaps most tellingly though, Ripple has also been granted a difficult-to-obtain BitLicense from the New York Department of Financial Services, giving it the blessing of a respected regulator. However, while the license was granted after then-superintendent Benjamin Lawsky stepped down from the regulator, it's perhaps no coincidence that a year later he joined Ripple on its board of directors and is now active in the cryptocurrency space. Perhaps a similar fate is in store for Giancarlo.
Editor’s note: This article has been updated to clarify that Ripple Labs is a client of Giancarlo’s law firm.
submitted by wazzocklegless to u/wazzocklegless [link] [comments]

Bitcoin 2017 a Comprehensive Timeline

Some of the most notable news and events over the past year:
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submitted by BitcoinChronicler to btc [link] [comments]

Altisource Portfolio Solutions S.A.

Altisource Portfolio Solutions S.A.
This is gonna be a long one.
"You don't have to know how much a man weighs to know he is fat."
Background:
Altisource Portfolio solutions "Altisource" was spun off from Ocwen Financial in 2009. Ocwen financial is a mortgage servicer. Of all the mortgage servicers, Ocwen is the most cost efficient, best run, and best capitalized. As a mortgage servicer, Ocwen acquires mortgage servicing rights (MSRs). Owners of MSRs collect a small fee from every mortgage payment it is servicing. Ocwen may service a mortgage by handling day to day tasks of servicing a loan, process payments, keep track of principal and interest paid, manages escrow accounts, initiate foreclosure, modify loan payments for subprime and delinquent loans and so on.
The reason Altisource was spun off from Ocwen in 2009 is because Ocwen's Chairman Bill Erbey knew the software division of Ocwen was not being valued properly within the business. Altisource is now incorporated in Luxembourg for tax reasons but it basically does everything a United States company would do. It files with the SEC, gets audited and does almost all business in the United States.
Thesis:
What does Altisource do?
From the 2013 10k-
"Altisource®, together with its subsidiaries, is a premier marketplace and transaction solutions provider for the real estate, mortgage and consumer debt industries offering both distribution and content. We leverage proprietary business process, vendor and electronic payment management software and behavioral science based analytics to improve outcomes for marketplace participants."
If you figured out what they did from reading that, congratulations, because I couldn't. I own the company and I still do not know all of the services they provide. What I do know is that more than half of Altisource's revenue is derived from Ocwen. Ocwen uses Altiosurce's state of the art servicing technology to service their loans. Altisource's technology allows Ocwen to be such a low-cost servicer. Altisource only provides their technology to Ocwen and no other servicers.
http://oraclefromomaha.files.wordpress.com/2014/04/1.png
In the above link, you can see the ways Altisource generates revenue. The main thing to know here is that Altisource generates a huge portion of their revenue from Ocwen. When Ocwen makes less modifications on loans, they use Altisource's services less so Altisource makes less money. When Ocwen modifies more loans then Altisource makes more money because Ocwen uses their serivices more. It provides a hedge against parts of their business that may struggle in a recession like any other business. During the natural economic cycle if there is a recession and Ocwen is modifying more loans because more homeowners cannot make payments then Altisource is making more money than they would during good economic times because Ocwen uses their services more. The more MSRs Ocwen acquires, the more Altisource makes.
Ocwen's growth (basically a quick long thesis on Ocwen)
When a bank loans money to an individual to buy a house, a mortgage is originated and an MSR is created. The bank then keeps the mortgage on its books or sells the mortgage to another entity. Perhaps Fannie or Freddie. But what happens to the MSR? The MSR is then sold to a servicer such as Nationstar, Walter Investment Management Corp, or Ocwen. The reason the banks or originator of the mortgage sell the MSR is because they cannot service it properly and/or they would lose money in the process of trying to service it. Because of Dodd Frank, banks are trying to get MSRs off their books even faster because they cannot service them efficiently as previously mentioned and because they will have to hold 250% more capital against the MSRs. All banks are moving away from owning MSRs and non-bank servicing is becoming a larger industry, and Ocwen is leading the way. Due to the high supply of MSRs that are wanting to be sold by banks the MSRs can currently be bought at a 20-30% yield. Ocwen can buy the most MSRs because they are the best capitalized and they use the most conservative balance sheet. Ocwen being the lowest cost operator provides them with a huge competitive advantage when bidding for MSRs as well. Ocwen will continue to lead the non-bank servicers in buying MSRs. Ocwen currently has $464 billion of unpaid principle balance of loans they are servicing and another trillion dollars of subprime (Ocwen specializes in subprime) UPB is expected to get into the hands of non bank servicers by 2018 (3-4 trillion in UPB of regular MSRs). Ocwen will get the most of that trillion dollars of UPB of any servicer because of their competitive advantages.
Another competitive advantage of Ocwen is their relationship Home Loan Servicing Solutions Ltd. HLSS was also created by Bill Erbey. HLSS provides the capital for Ocwen to service loans so Ocwen does not have to tie up their capital. In the future, HLSS will acquire more loans and allow Ocwen to sub-service them through a unique financing strategy. This strategy called the accretion model is a genius way to get capital for HLSS to afford a virtually unlimited amount of MSRs. HLSS pays a huge dividend and because of this dividend, HLSS trades above its tangible book value due to fixed income hungry investors who want a fat dividend. HLSS then issues more shares above tangible book value to then acquire more MSRs. Issuing shares above book value actually creates value for HLSS shareholders also instead of diluting value as many people would think issuing shares does. Those MSRs are then sub-serviced by Ocwen, who still uses Altisource's technology.
Ocwen is also getting into foreword and reverse mortgage origination so they can have a constant stream of MSRs.
Basically, Ocwen and HLSS are going to acquire more MSRs and Ocwen will be servicing more mortgages. More mortgages serviced by Ocwen = more revenue for altisource.
All MSR transactions have currently been stopped by a New York financial regulator but we will get to that issue later.
Share Repurchases
Up until a few months ago the laws of Luxembourg restricted the amount of shares that Altisource could repurchase. Altisource recently created a foreign subsidiary that does nothing called "MidCo" to hold all other parts of the business so there would legally be no restrictions on share repurchases. Until Altisource did this, they were repurchasing the maximum amount of shares that Luxembourg would allow.
Here is Altisource's entity structure to bypass Luxembourg share repurchase laws http://i.imgur.com/J6LPEc0.jpg
The highlighted dark blue entity will be the entity repurchasing unlimited shares because MidCo, its parent company is not in Luxembourg. How smart is that.
Altisource currently authorized the repurchase of up to 2.9 million shares. 2.9 million shares is 13% of their market cap. They could easily repurchase that amount. Altisource also just finalized a loan with BAC for $200 million to repurchase shares so the share repurchases will really start to kick into high gear with the new liquidity and cheaper price. Up until the sharp share price drop, Altisource was repurchasing for the past several months around $110. That shows the board and management think the company is undervalued at $110 and now it is at $84 and nothing fundamentally changed about the company.
Insider Purchases
During the past 6 months, 3 insiders have purchased at $102, $103, $106, and $120. Between 20% and 43% above current market prices. Bill Erbey also owns 30% of Altisource and 13% of Ocwen. His views are directly in line with other shareholders.
Bill Erbey and his Capital Allocation
Bill Erbey is the Chairman of Ocwen, Altisource Portfolio Solutions, Altisource Asset Management Corporation, Altisource Residential, and Home Loan Servicing Solutions. Bill has done a great job of creating shareholder value for Ocwen and Altisource shareholders. Bill has also greatly benefited from this because of his stakes in thise companies. Before the sharp share price drop due to outside forces, Bill compounded Ocwen's stock at 30% per year since 2002 WITHOUT including the Altisource spinoff which compounded itself since 2009 at almost 75% a year. Altisource then spunoff Altisource Residential and Altisource Asset Management. Every spinoff is a value creating machine. At one point AAMC had compounded 430% in a year and a half, although it was due to a stretched valuation. Bill is dedicated to doing whatever it takes to create shareholder value. He relocated to the Virgin Islands just to save Ocwen some money on taxes.
I once read a story about Bill in his Virgin Islands home and his electric bill for the air conditioning. Keep in mind, Mr. Erbey is a multi billionaire. Bill got his electric bill and saw his costs had skyrocketed due to his air conditioning. Bill then sat there after that baking and sweating in the heat in his home so he could save a couple thousand on his electricity bill. He will do anything to save a dollar.
Hubzu
Hubzu is owned by Altisource. Hubzu is currently an online marketplace to buy and sell foreclosed homes. Like Zillow and Trulia but for foreclosed homes. Hubzu takes foreclosed homes from Ocwen and lists them on their website Hubzu.com. Hubzu is trying to get into the non-distressed house listing like other real estate websites like Zillow and Trulia. This will grow Hubzu at an even faster rate. Altisource states Hubzu gets about 1 million unique new visitors per month. When you buy Altisource you are also buying the jewel of Hubzu. Bill Erbey claims that Hubzu makes "as much money in one quarter as Zillow does in 4 quarters" Zillow has a market capitalization of $5 billion. Zillow's market capitalization is definitely stretched but a spinoff would create a lot of shareholder value even if the market gave Hubzu a fraction of Zillow's valuation.
Why is the company undervalued?
All this greatness in one company so why is it so undervalued? Remember how Altisource's earning were pretty much directly tied to how well Ocwen does? A New York State Financial Department regulator named Benjamin Lawsky halted a $2.7 bilion ($39 billion in UPB) Wells Fargo MSR transfer to Ocwen. This also halted all of the other MSR transactions between banks and servicers. Benjamin Lawsky is probing into Ocwen and other servicers. He states that he wants to make sure Ocwen and other servicers have the capacity to service loans efficiently because they are "growing too fast". The relationships these 5 companies share though is somewhat sketchy. They have a lot of the same board members and they all work with each other and make money off each other. Ocwen is the best servicer of them all though. They provide more loan modifications than anyone else and they have the lowest re default rate.
A slide from an investor presentation shows how they compare to others http://i.imgur.com/YkIKD2O.png
Even if Lawsky did find that some servicers do not have the capacity to service loans then Ocwen would be the last one in question because it is easy to see they are doing the best for their consumer compared to anyone other servicer.
Benjamin Lawsky is doing this for his own political reasons. He wants his name on the news. He wants people to see his name. Perhaps he wants to run for governor or something. Why would he schedule an interview with CNBC about the probe into the mortgage servicers right after it is announced. Why would he send a letter to Altisource and at the same time send it to the press, therefore ruining Altisource's reputation without giving them a chance to respond. He is also really into regulating bitcoin in New York which is just another vehicle to get his name in the news.
There are very recent updates with the regulatory pressure and basically the probing is narrowed down to an issue with force placed insurance and Altisource. Ben Lawsky could not find anything else. He sent this letter on Aug. 4th to Ocwen. So this is what the probe is narrowed down to.
http://www.dfs.ny.gov/about/press2014/pr140804-ocwen-letter.pdf
Basically, if a homeowner is struggling to make payments and can't pay their insurance, Ocwen has the right to force place insurance into their payments so the mortgage owner does not incur massive losses if a catastrophe happens. Ocwen has to outsource whoever force places the insurance and the issue that Ben Lawsky was worried about was why Altisource was appointed to find someone to force place that insurance, why Altisource received commission for basically doing nothing, and why Bill Erbey did not consult with any of the Ocwen board before making this decision to allow Altisource to find an insurer.
Altisource will probably get a one time fine settlement and they will go on doing business as usual. I believe this because an almost identical situation happened with Assurant and the New York State Financial Department and they settled for $14 million. There is also an interview on CNBC with someone who talks to the CEO of Ocwen and they are sure that Ocwen and Altisource will just settle with a deal with Lawsky and that will be the end of it.
Interview:
http://video.cnbc.com/gallery/?video=3000298804
Risks Benjamin Lawsky actually finds something else that Altisource was doing wrong. Bill Erbey Dies. He is in his 60s and overweight.
Conclusion
In conclusion Altisource is extremely cheap. Remember that quote about not knowing how much a man weighs but knowing he is fat? That is the case with Altisource. Altisource is definitely undervalued but there are a range of possibilities of the valuation with Hubzu, regulatory matters, growth, etc.
submitted by nomcow to SecurityAnalysis [link] [comments]

A few thoughts - Monday, July 21, 2014

Good afternoon. A few thoughts for lunch today:

The market will reach an equilibrium

There are too many laws in our society, so many that it is impossible to live without breaking them constantly. While I don't live in fear, I do get anxious occasionally that someday cops will show up and start questioning me. For example, perhaps someone used my wireless network to access child porn sites without my knowing about it. Or, one of the programs I'm using for my mining pool had a license agreement that unintentionally prohibits its usage in the way I used it. Because I know that it is impossible to fully comply with the law, the best I can do is to minimize my risk of violation as much as possible.
What Benjamin Lawsky did was to cause people to disrespect the law even further. When you make laws that are difficult to enforce and cover every possible type of behavior, people don't respect lawmakers. Some crimes, like murder, are avoided not only because of the penalty, but because people agree that killing people is ethically wrong. However, manufactured crimes like the ones Lawsky is creating are not generally respected by the population and therefore people will willingly take a limited amount of risk in breaking them because they are not ethically wrong.
The state of the market does not change overnight from everyone in noncompliance to everyone in 100% compliance. Instead, the result of the regulations will be a fragile balance that CEOs agree is where the risks are outweighed by the possibility of making money. For example, most people would gladly spend a year in jail to make $1m. It doesn't make sense to spend a year in jail to make $100k, however, as I could do that elsewhere. Therefore, if the business makes $10m and the risk of going to jail is less than 10% ($10m * 10% = $1m) (and nobody is actually going to be harmed by your actions) then it makes sense to operate your business.
Suppose that the risk of going to jail for operating an unlicensed exchange in Vermont that blatantly serves New York customers is 25%. However, maybe you could reduce the risk to 20% by placing a notice stating that New York customers are banned from using the service. You could further reduce the risk to 15% by banning New York IP addresses, and to 10% by ceasing all ties with and punishing users who are determined by be from New York. You could reduce the risk to 5% if you paid $100k to hire lawyers to file paperwork, but at this point your expected value is past the point where your risk of jail is low enough to justify your continuing operations. Therefore, the equilibrium for you (and the market) is stopping before filing that expensive paperwork, but taking the other measures.
Other exchanges might have factors that make themselves more or less likely to be prosecuted, so they will adjust their compliance actions appropriately until they get to the right level of risk their operators are willing to take. This is the same way it works in drugs; traffickers will raise their prices until the benefits outweigh the risks; the prices go up when the government seizes drugs and go down when there are fewer seizures.
The BTC Guild created a rather arrogant drama over the past few days, stating that they were possibly going to shut down, and that they needed to talk to their lawyers, and so on. As the last part of that shows, it might have made sense to actually talk to the lawyer first before plastering what they were going to do if their lawyer told them to do something. However, most businesses are not likely to follow in the BTC Guild's footsteps. Instead, they will remove themselves from New York, and then evaluate their methods for avoiding New York customers. They will settle on the minimum level of compliance to reduce their risks of being fined to justify the money they are making. Since there is only one state trying to assert its authority, Lawsky isn't going to get anywhere close to 100% compliance. I'd be surprised if 50% of the bitcoin businesses took even token steps to get rid of New York customers.

False bubble is over; long period of stagnation ahead

Some people looked to these regulations as being some sort of catalyst. I think that they could have been, had they been favorable to everyone. Remember, the big complaint of banks was that there wasn't clarity in the regulations, not that they needed certain regulations to operate. Reasonable regulations would have made both banks and everyone else happy enough to start a run. However, these unfavorable regulations and the immense blowback against them creates the most uncertainty bitcoin has had in years.
Every once in a while, there is a period of time where everyone waits for something to happen before making moves. I'd say that this is the beginning of yet another of those periods, perhaps the longest one in bitcoin's history. The regulations need to be published, 45 days needs to pass, the legislators probably need another month to make changes, and then there will be another announcement, and even then there may still be more comments. That means that this period of uncertainty will last at least until October.
That means that we are again in a bear market. The bubble was one of those smaller false bubbles. It arrived earlier because many people wanted to get in on the action before the rise. Now, there are months ahead of stagnation and panics, as always happens on the downcycles.
I don't think these rules will take effect this year because even after all the time elapses, there is still more. Even if he does come out with a final version on time, it is likely that someone will sue, an injunction will be granted, and the parties will fight it out in court for some time. Whatever is looked back upon as the catalyst for the next bubble, it isn't going to be these regulations. If it is true that big exchanges like Circle just want any regulations to be passed as soon as possible, then this delayed bitcoin development because the court battle now needs to play out.

What was Lawsky thinking?

Given that the regulations came out of left field, it's worth considering how Lawsky could have been so off the mark. Let's consider the likliehood of some possibilities:
  1. Lawsky was unconsciously influenced by big business. You may remember that he invited lots of big bankers and big names in the bitcoin industry to the meetings he held over the past few months. These guys have lots of money and undoubtedly suggested regulations to him that favor their companies. If this is true, nobody is at fault for what came out of the meetings: Lawsky just listened to the advice, and the people he interviewed didn't know enough about the troubles faced by startups and non-financial firms because they weren't employed by them. The result is that the end regulations will contain exceptions for startups.
  2. Lawsky or a politician supporting him accepted contributions to bend the rules. If this is true, then corruption led him to add things into the regulations even though he himself opposed them. He decided that the political support was necessary for his future ambitions or because he cared more about some other issue on his desk and was willing to "trade" political capital in exchange for that other issue. The result is that the end regulations will be unchanged and most bitcoin businesses will leave New York, or he is sued with a later court battle.
  3. Lawsky is ignorant of how bitcoins actually work. The simplest explanation of them all, Lawsky simply is not well-informed as to how the protocol operates. He created a set of rules that is applicable for every currency that came before, when bitcoins are vastly different and can also function as more than a currency. He had no idea of the number of different types of business models other than exchanges that operate in the state. He also was not knowledgable about how software engineering works. If true, his ignorance led him to overlook the severe consequences the regulations would have on other areas of society unrelated to bitcoins. He was completely taken aback by the reaction in /bitcoin after he posted the regulations, and you can argue that if he were truly informed, he would have announced the regulations through the normal channels to prevent the embarassment of what happened. The result is that the end regulations will be a complete rewrite that is dramatically different than what is proposed.
  4. Lawsky is engaging in a PR campaign. If this case is true, then Lawsky purposely and deceitfully went overboard by placing regulations in the proposal that he knows are unreasonable. He appeared on TV repeatedly and posted on reddit to bolster his credentials and get people to mistakenly trust that he is a good guy before the release, knowing exactly what would happen later. Doing so will allow him to later argue that other members of the Department forced him to add the worst rules, and that he understands small business and supports freedom in open source development. He will apologize for the committee's conduct and then propose new regulations with half as many rules, which still make it infeasible to operate a business in New York. By that time, members of /bitcoin will change their minds and accept these new rules because they aren't as bad and because "they always expected that bitcoins have to be regulated." The result is that crippling regulations are still enacted, with modifications that make them just barely feasible for some types of businesses to comply.
  5. Lawsky is directly trying to suppress bitcoin adoption. If true, while he appears on TV and posts online, Lawsky simply is lying. He just wants to reduce the usability of bitcoins like China tried to do. The result is that the end regulations will be unchanged and most bitcoin businesses will leave New York, or he is sued with a later court battle.
I'm not going to make a suggestion as to which of the five is accurate. I think that more information will come out over the next few weeks to clarify exactly where these rules came from, and it will help in narrowing down what happened here.

Other

submitted by quintin3265 to BitcoinThoughts [link] [comments]

A few thoughts - Friday, July 11, 2014

Good afternoon! A few thoughts for lunch today:

Dark Wallet making waves

There's a cover story at Wired today about the Dark Wallet software that aims to completely anonymize transactions. Built on top of bitcoin, Dark Wallet merges transactions through a method known as CoinJoin, making it impossible to trace the destination of funds. The creators state that the goal of Dark Wallet is to make bitcoin transactions completely anonymous.
I like Dark Wallet because it is built on top of the bitcoin protocol. Darkcoin, an alternative system that aims to accomplish the same thing, is more centralized (it has masternodes). Darkcoin also suffers from the simple fact that it is an altcoin, which is reason enough to believe that it is unlikely to succeed.
Dark Wallet's success is more likely, because it theoretically could be used interchangably with the existing protocol. Since money flows over bitcoin and there are no colored coins representing larger values, a Dark Wallet coin is worth the same as a bitcoin. Should people start to use Dark Wallet, I predict that the Dark Wallet protocol becomes implemented by all major providers within a year of that. Should that happen, Dark Wallet will eventually become the default protocol, since traditional bitcoin has no advantages over Dark Wallet (who doesn't want to protect their privacy?) We could see it integrated into the reference client, just as the reference client uses new change addresses now to protect privacy. Ironically, the only use the non-Dark Wallet protocol would have then is for transparency purposes like proofs of reserve and huge bank transfers, so that straight bitcoin suddenly goes from the evil anonymous currency to the transparency enforcer.
Pay attention to Dark Wallet. Because it is not an altcoin, and because it is so interchangable with straight bitcoin, it could eventually become the standard protocol should people start using it.

The difference between good news and actual products

I wonder if some of the discrepency between actual prices and the amount of good news that seemingly appears is because much of the good news is not actually what it seems. I was surprised to discover this morning, for example, that 1-800-flowers isn't actually accepting bitcoins. They only announced that they will be doing so later in the year, which adds them to a string of companies which stated they would be accepting bitcoins but turned out that only a small segment of the business was doing so, or that these companies' bitcoin acceptance wasn't live yet.
It's also worth considering that many press releases have no real product behind them. Circle, which issued a release in mid-May, said that they were going to allow people to buy bitcoins with a credit card for no charge. Two months later, we have yet to hear a single person who has been accepted into their beta testing program.
Therefore, I propose that one reason that good news has little effect on the markets is that it isn't actually good news. Perhaps the big time investors who actually make a difference see through the press releases more easily than the people on reddit do.

Why go bearish so early?

Some people questioned why I would have a negative outlook on bitcoins several weeks before we can confirm that this bubble cycle failed to launch. After all, the expected time that this bubble would peak isn't close to arriving yet.
Over the past year, market movements have tended to occur about 10 days before the majority of people on reddit believed that they would happen. You can see this correlation in the crashes and rises last November pretty clearly. I've predicted that things aren't turning out the way many people believed, and that such an outcome would likely produce a downturn (but not kill bitcoins). Because things happen often happen before everyone believes they will, I would imagine that the fallout would occur before the expected timeframe of this bubble elapses.

On the New York regulations

Much has been made about how Benjamin Lawsky's proposed regulations will have a significant impact if they are released in a few weeks. I predict no impact at all.
First, any regulations that are released are not going to be final; they still need to be discussed and approved. Therefore, companies will not be able to act upon them without fear of the rules changing before they are finalized months from now. Second, these regulations were to have been completed several weeks ago, and are still outstanding. As people in /bitcoinmarkets say, it's always coming "in two weeks." Finally, even if these regulations were finalized two weeks from now, there aren't any companies ready to pounce on them. Other regulations like money transmitting licenses, and simply not having the software ready, are greater hindrances at this point to these companies.
Lawsky's regulations are important, but the timeframe in which they will have an effect is going to be drawn out well into the future. When they are finally approved, there probably wouldn't be much splash, since the splash always is made on the initial announcement. Their approval will set the stage for growth, but not until they are finalized and the companies are ready to go.

Litecoins are like bitcoins of the altcoin world

It occurred to me recently that people separate cryptocurrencies into two areas: bitcoins and everything else (altcoins). In some ways, altcoins can be separated into litecoins and everything else.
In these contexts, bitcoins and litecoins share many characteristics. Both were the first, and most widely used, in their fields. Both use proven algorithms and provide a barebones framework, rather than attempting to experiment with extra features like anonymity or using 6 algorithms. Both serve as a reserve currency against which other cryptocurrencies are measured. Both have established uses that people need to hold them for to conduct real commerce. And both can be traded directly for dollars.
This is why I do not believe that litecoins are going away. The idea of "silver and gold" is not a misdirection; the simple fact that litecoins are worth less than bitcoins has made them valuable in a number of instances where eight decimal places of bitcoins is not granular enough. Just as bitcoins' most important attribute is their network effect, litecoins have a smaller, but similar network effect. Convincing people to switch out litecoins for Darkcoins or whatever flavor of the day comes up next will be just as difficult as it would be to convince people to drop bitcoins in favor of some other currency.

Uses for the sockpuppet accounts

It's worth paying attention to flairs in /bitcoinmarkets for unusual activity. One thing those sockpuppet accounts could be used for is to influence the bulls-to-bears ratio. In yesterday's comment, I referred to the "weighted bulls to bears ratio," which is a better metric that minimizes the effects of such accounts.

Other

submitted by quintin3265 to BitcoinThoughts [link] [comments]

The New York State Attorney General lives in Alternate Reality !

Dear Friends,
Legal Parallel Universe is the first thing that came to my mind when I read this final legal reply.
Pierre says it in a different way:
According to Defendants-Respondents’ response to Plaintiffs-Petitioners’ Cross-Motion for Limited Discovery, they should be entitled to live in a legal world where virtually no one has standing to challenge a regulation involving new technology or new markets, and where no plaintiff ever has grounds to seek limited discovery.
Now that all the documents are filed there shouldn’t be any more delays and as you can read in the rest of Pierre’s brief (which is located: http://www.article78againstnydfs.com/docs/Index-101880-15/17-ReplyMemoLimitedDiscovery/01-ReplyMemoLimitedDiscovery.pdf) we are requesting experts.
Ben Lawsky is a Lawyer and a politician. He is a good one but he is not an economist. Nothing in Benjamin Lawsky background predispose him to lead the NYDFS. It was just the best illustration of cronyism within the New York and Wall Street democratic establishment. His testimony is to explain why he ignored Professor Williams’ comments.
During the hearings on the proposed regulation, Mark T. Williams’s written testimony establishes that Bitcoin should be treated as a commodity, and not as a currency, yet Defendants-Respondents did not address Mark T. Williams’ position. Additionally, supposedly, the Defendants-Respondents conducted “extensive research at analysis” when they proposed the Regulation, yet the research and analysis has never been produced so it is unclear how Defendants-Respondents came to the conclusion that Bitcoin could be regulated by them.
As New Yorkers, we might understand that it’s bad politics to listen to Bostonians professors. We know that our Public University professors might not be the most distinguished but we will settle for one that is been quoted by the Attorney General.
We need to have a professor in economy and the state of New York has so many on their payroll, we are simply asking the judge to make CUNY professor available to us since his conclusions are being quoted by the Attorney General.
The citation to Mr. Krugman’s article was taken from the following passage in DFS’s opening brief: These terms—“medium of exchange” and “form of digitally stored value”—are commonly used to describe financial products and services. See, e.g., United States v. Faiella (observing that “money” in ordinary parlance means “something generally accepted as a medium of exchange, a measure of value, or a means of payment”); Paul Krugman, The Int’l Role of the Dollar: Theory and Prospect in Exchange Rate Theory & Practice 8.2 (John F. Bilson & Richard C. Marston eds., 1984) (noting that money generally “serves three functions: it is a medium of exchange, a unit of account, and a store of value”); see also United States v. E-Gold, Ltd. (holding that “a ‘money transmitting service’ includes not only a transmission of actual currency, but also a transmission of the value of that currency through some other medium of exchange”).
Legal scholars might call the Attorney General logic a Legal Parallel Universe. I personally would simply ask what medicine those attorney representing the state of New York are on.
Defendants-Respondents cannot have it both ways -- have the Court believe that Plaintiffs-Petitioners discovery motion should be thrown out just because of the absence of any merit to Plaintiffs-Petitioners’ case and argue Plaintiffs-Petitioners’ petition should be dismissed on an unresolved threshold issue. Either Defendants-Respondents should not have filed their Cross-Motion to Dismiss or limited discovery is necessary on the threshold issue as to the economic nature of Bitcoin.
Please share the date of October 10, 2017 with everyone interested in attending. It’s going to be historic!
All the documents of the lawsuit are on the website here: http://www.article78againstnydfs.com/raw.php
See you on the 10 ! (and don't forget Morpheus waiting for his trial from his jail cell.)
Theo Chino http://AbolishTheBitlicense.com https://www.meetup.com/Article-78-Against-NYDFS
submitted by theochino to Bitcoin [link] [comments]

Altisource Portfolio Solutions (S.A.) Long Thesis

Altisource Portfolio Solutions S.A.
This is gonna be a long one.
"You don't have to know how much a man weighs to know he is fat."
Background:
Altisource Portfolio solutions "Altisource" was spun off from Ocwen Financial in 2009. Ocwen financial is a mortgage servicer. Of all the mortgage servicers, Ocwen is the most cost efficient, best run, and best capitalized. As a mortgage servicer, Ocwen acquires mortgage servicing rights (MSRs). Owners of MSRs collect a small fee from every mortgage payment it is servicing. Ocwen may service a mortgage by handling day to day tasks of servicing a loan, process payments, keep track of principal and interest paid, manages escrow accounts, initiate foreclosure, modify loan payments for subprime and delinquent loans and so on.
The reason Altisource was spun off from Ocwen in 2009 is because Ocwen's Chairman Bill Erbey knew the software division of Ocwen was not being valued properly within the business. Altisource is now incorporated in Luxembourg for tax reasons but it basically does everything a United States company would do. It files with the SEC, gets audited and does almost all business in the United States.
Thesis:
What does Altisource do?
From the 2013 10k-
"Altisource®, together with its subsidiaries, is a premier marketplace and transaction solutions provider for the real estate, mortgage and consumer debt industries offering both distribution and content. We leverage proprietary business process, vendor and electronic payment management software and behavioral science based analytics to improve outcomes for marketplace participants."
If you figured out what they did from reading that, congratulations, because I couldn't. I own the company and I still do not know all of the services they provide. What I do know is that more than half of Altisource's revenue is derived from Ocwen. Ocwen uses Altiosurce's state of the art servicing technology to service their loans. Altisource's technology allows Ocwen to be such a low-cost servicer. Altisource only provides their technology to Ocwen and no other servicers.
http://oraclefromomaha.files.wordpress.com/2014/04/1.png
In the above link, you can see the ways Altisource generates revenue. The main thing to know here is that Altisource generates a huge portion of their revenue from Ocwen. When Ocwen makes less modifications on loans, they use Altisource's services less so Altisource makes less money. When Ocwen modifies more loans then Altisource makes more money because Ocwen uses their serivices more. It provides a hedge against parts of their business that may struggle in a recession like any other business. During the natural economic cycle if there is a recession and Ocwen is modifying more loans because more homeowners cannot make payments then Altisource is making more money than they would during good economic times because Ocwen uses their services more. The more MSRs Ocwen acquires, the more Altisource makes.
Ocwen's growth (basically a quick long thesis on Ocwen)
When a bank loans money to an individual to buy a house, a mortgage is originated and an MSR is created. The bank then keeps the mortgage on its books or sells the mortgage to another entity. Perhaps Fannie or Freddie. But what happens to the MSR? The MSR is then sold to a servicer such as Nationstar, Walter Investment Management Corp, or Ocwen. The reason the banks or originator of the mortgage sell the MSR is because they cannot service it properly and/or they would lose money in the process of trying to service it. Because of Dodd Frank, banks are trying to get MSRs off their books even faster because they cannot service them efficiently as previously mentioned and because they will have to hold 250% more capital against the MSRs. All banks are moving away from owning MSRs and non-bank servicing is becoming a larger industry, and Ocwen is leading the way. Due to the high supply of MSRs that are wanting to be sold by banks the MSRs can currently be bought at a 20-30% yield. Ocwen can buy the most MSRs because they are the best capitalized and they use the most conservative balance sheet. Ocwen being the lowest cost operator provides them with a huge competitive advantage when bidding for MSRs as well. Ocwen will continue to lead the non-bank servicers in buying MSRs. Ocwen currently has $464 billion of unpaid principle balance of loans they are servicing and another trillion dollars of subprime (Ocwen specializes in Subprime) UPB is expected to get into the hands of non bank servicers by 2018 (3-4 trillion in regular MSRs). Ocwen will get the most of that trillion dollars of UPB of any servicer because of their competitive advantages.
Another competitive advantage of Ocwen is their relationship Home Loan Servicing Solutions Ltd. HLSS was also created by Bill Erbey. HLSS provides the capital for Ocwen to service loans so Ocwen does not have to tie up their capital. In the future, HLSS will acquire more loans and allow Ocwen to sub-service them through a unique financing strategy. This strategy called the accretion model is a genius way to get capital for HLSS to afford a virtually unlimited amount of MSRs. HLSS pays a huge dividend and because of this dividend, HLSS trades above its tangible book value due to fixed income hungry investors who want a fat dividend. HLSS then issues more shares above tangible book value to then acquire more MSRs. Issuing shares above book value actually creates value for HLSS shareholders also instead of diluting value as many people would think issuing shares does. Those MSRs are then sub-serviced by Ocwen, who still uses Altisource's technology.
Ocwen is also getting into foreword and reverse mortgage origination so they can have a constant stream of MSRs.
Basically, Ocwen and HLSS are going to acquire more MSRs and Ocwen will be servicing more mortgages. More mortgages serviced by Ocwen = more revenue for altisource.
All MSR transactions have currently been stopped by a New York financial regulator but we will get to that issue later.
Share Repurchases
Up until a few months ago the laws of Luxembourg restricted the amount of shares that Altisource could repurchase. Altisource recently created a foreign subsidiary that does nothing called "MidCo" to hold all other parts of the business so there would legally be no restrictions on share repurchases. Until Altisource did this, they were repurchasing the maximum amount of shares that Luxembourg would allow.
Here is Altisource's entity structure to bypass Luxembourg share repurchase laws http://i.imgur.com/J6LPEc0.jpg
The highlighted dark blue entity will be the entity repurchasing unlimited shares because MidCo, its parent company is not in Luxembourg. How smart is that.
Altisource currently authorized the repurchase of up to 2.9 million shares. 2.9 million shares is 13% of their market cap. They could easily repurchase that amount. Altisource also just finalized a loan with BAC for $200 million to repurchase shares so the share repurchases will really start to kick into high gear with the new liquidity and cheaper price. Up until the sharp share price drop, Altisource was repurchasing for the past several months around $110. That shows the board and management think the company is undervalued at $110 and now it is at $84 and nothing fundamentally changed about the company.
Insider Purchases
During the past 6 months, 3 insiders have purchased at $102, $103, $106, and $120. Between 20% and 43% above current market prices. Bill Erbey also owns 30% of Altisource and 13% of Ocwen. His views are directly in line with other shareholders.
Bill Erbey and his Capital Allocation
Bill Erbey is the Chairman of Ocwen, Altisource Portfolio Solutions, Altisource Asset Management Corporation, Altisource Residential, and Home Loan Servicing Solutions. Bill has done a great job of creating shareholder value for Ocwen and Altisource shareholders. Bill has also greatly benefited from this because of his stakes in thise companies. Before the sharp share price drop due to outside forces, Bill compounded Ocwen's stock at 30% per year since 2002 WITHOUT including the Altisource spinoff which compounded itself since 2009 at almost 75% a year. Altisource then spunoff Altisource Residential and Altisource Asset Management. Every spinoff is a value creating machine. At one point AAMC had compounded 430% in a year and a half, although it was due to a stretched valuation. Bill is dedicated to doing whatever it takes to create shareholder value. He relocated to the Virgin Islands just to save Ocwen some money on taxes.
I once read a story about Bill in his Virgin Islands home and his electric bill for the air conditioning. Keep in mind, Mr. Erbey is a multi billionaire. Bill got his electric bill and saw his costs had skyrocketed due to his air conditioning. Bill then sat there after that baking and sweating in the heat in his home so he could save a couple thousand on his electricity bill. He will do anything to save a dollar.
Hubzu
Hubzu is owned by Altisource. Hubzu is currently an online marketplace to buy and sell foreclosed homes. Like Zillow and Trulia but for foreclosed homes. Hubzu takes foreclosed homes from Ocwen and lists them on their website Hubzu.com. Hubzu is trying to get into the non-distressed house listing like other real estate websites like Zillow and Trulia. This will grow Hubzu at an even faster rate. Altisource states Hubzu gets about 1 million unique new visitors per month. When you buy Altisource you are also buying the jewel of Hubzu. Bill Erbey claims that Hubzu makes "as much money in one quarter as Zillow does in 4 quarters" Zillow has a market capitalization of $5 billion. Zillow's market capitalization is definitely stretched but a spinoff would create a lot of shareholder value even if the market gave Hubzu a fraction of Zillow's valuation.
Why is the company undervalued?
All this greatness in one company so why is it so undervalued? Remember how Altisource's earning were pretty much directly tied to how well Ocwen does? A New York State Financial Department regulator named Benjamin Lawsky halted a $2.7 bilion ($39 billion in UPB) Wells Fargo MSR transfer to Ocwen. This also halted all of the other MSR transactions between banks and servicers. Benjamin Lawsky is probing into Ocwen and other servicers. He states that he wants to make sure Ocwen and other servicers have the capacity to service loans efficiently because they are "growing too fast". The relationships these 5 companies share though is somewhat sketchy. They have a lot of the same board members and they all work with each other and make money off each other. Ocwen is the best servicer of them all though. They provide more loan modifications than anyone else and they have the lowest re default rate.
A slide from an investor presentation shows how they compare to others http://i.imgur.com/YkIKD2O.png
Even if Lawsky did find that some servicers do not have the capacity to service loans then Ocwen would be the last one in question because it is easy to see they are doing the best for their consumer compared to anyone other servicer.
Benjamin Lawsky is doing this for his own political reasons. He wants his name on the news. He wants people to see his name. Perhaps he wants to run for governor or something. Why would he schedule an interview with CNBC about the probe into the mortgage servicers right after it is announced. Why would he send a letter to Altisource and at the same time send it to the press, therefore ruining Altisource's reputation without giving them a chance to respond. He is also really into regulating bitcoin in New York which is just another vehicle to get his name in the news.
There are very recent updates with the regulatory pressure and basically the probing is narrowed down to an issue with force placed insurance and Altisource. Ben Lawsky could not find anything else. He sent this letter on Aug. 4th to Ocwen. So this is what the probe is narrowed down to.
http://www.dfs.ny.gov/about/press2014/pr140804-ocwen-letter.pdf
Basically, if a homeowner is struggling to make payments and can't pay their insurance, Ocwen has the right to force place insurance into their payments so the mortgage owner does not incur massive losses if a catastrophe happens. Ocwen has to outsource whoever force places the insurance and the issue that Ben Lawsky was worried about was why Altisource was appointed to find someone to force place that insurance, why Altisource received commission for basically doing nothing, and why Bill Erbey did not consult with any of the Ocwen board before making this decision to allow Altisource to find an insurer.
Altisource will probably get a one time fine settlement and they will go on doing business as usual. I believe this because an almost identical situation happened with Assurant and the New York State Financial Department and they settled for $14 million. There is also an interview on CNBC with someone who talks to the CEO of Ocwen and they are sure that Ocwen and Altisource will just settle with a deal with Lawsky and that will be the end of it.
Interview:
http://video.cnbc.com/gallery/?video=3000298804
Risks Benjamin Lawsky actually finds something else that Altisource was doing wrong. Bill Erbey Dies. He is in his 60s and overweight.
Conclusion
In conclusion Altisource is extremely cheap. Remember that quote about not knowing how much a man weighs but knowing he is fat? That is the case with Altisource. Altisource is definitely undervalued but there are a range of possibilities of the valuation with Hubzu, regulatory matters, growth, etc.
submitted by nomcow to valueinvestorsclub [link] [comments]

Bitcoin price bullish thanks to BitLicense

The bitcoin price hasn’t moved much over the last 24 hours. It continues to trend relatively sideways, as trading volume continues to drop further. The movement illustrates cautiousness, but nonetheless, it looks like traders are simply waiting for a breakout towards either side. The upcoming waves will influence future trade positions.
The future of bitcoin however seems bullish, thanks to the recent update from Benjamin Lawsky’s office regarding BitLicense. The NYSE-Coinbase partnership last week gave us an over reactive spike towards 315. Now if the market is in the mood to play yet another hype-game on upcoming events, we are surely looking at a bull run towards long-term key resistance levels. 320 perhaps!
February 5th Bitcoin Trading Session
The BTC/USD opened at around 226 while continuing the prevailing sideways trend. During the day, the price seemed to be under a little influence of sellers, going downwards following little pushes. However, a big candle appeared out of nowhere after the 8th hour and price fell down around $10 within just four hours. It attempted a quick pullback in the name of correction and went on continuing the previous sideways trend - trading between a Bollinger band.
At press time, the BTC/USD is valued around 216.
What to Expect Today?
The BTC/USD has been sliding downwards since the start of the year. It has once tested 165 as its lowest bottom. By looking at the current scenario, it seems like the price is once again going to retest the same bottom in the upcoming days.
The technical indicators meanwhile are also indicating a rather stronger bearish bias in the market. As you see the 4H Bitfinex chart above, you’ll notice a near-perfect inverse Head-and-Shoulder forming; imperfect because the right shoulder looks quite weak at this point of time. This simply means the price is targeting some more downward movements, possibly to retest 200, maybe 165 at worst case.
To regain the lost bullish momentum, price would be focusing on breaking the neckline around 245 at this point in time. In the last few hours, the BTC/USD has already tested the 210 bottom successfully, and its arrow is now pointing upwards. A smooth correction however depends on the buying volume. Traders may long towards 245 at press time. But the extension of bullish momentum could only be confirmed once price breaks above the 320 upside risk. It’s a long shot.
A drop below 165 meanwhile signals a bearish breakout where price may even go as low as 100.
Conclusion (On Daily Charts)
Current Mood: Strongly Bearish Technical Indicators: Strong Sell (0 Buy 7 Sell 4 Neutral) Moving Averages: Strong Sell (0 Buy 12 Sell)
https://www.coinarch.com/Info/Blog?Page=2015/02/daily-bitcoin-price-analysis-5th-february/
submitted by Kimba_Coinarch to BitcoinMarkets [link] [comments]

Altisource Portfolio Solutions S.A.

Altisource Portfolio Solutions S.A.
This is gonna be a long one.
"You don't have to know how much a man weighs to know he is fat."
Background:
Altisource Portfolio solutions "Altisource" was spun off from Ocwen Financial in 2009. Ocwen financial is a mortgage servicer. Of all the mortgage servicers, Ocwen is the most cost efficient, best run, and best capitalized. As a mortgage servicer, Ocwen acquires mortgage servicing rights (MSRs). Owners of MSRs collect a small fee from every mortgage payment it is servicing. Ocwen may service a mortgage by handling day to day tasks of servicing a loan, process payments, keep track of principal and interest paid, manages escrow accounts, initiate foreclosure, modify loan payments for subprime and delinquent loans and so on.
The reason Altisource was spun off from Ocwen in 2009 is because Ocwen's Chairman Bill Erbey knew the software division of Ocwen was not being valued properly within the business. Altisource is now incorporated in Luxembourg for tax reasons but it basically does everything a United States company would do. It files with the SEC, gets audited and does almost all business in the United States.
Thesis:
What does Altisource do?
From the 2013 10k-
"Altisource®, together with its subsidiaries, is a premier marketplace and transaction solutions provider for the real estate, mortgage and consumer debt industries offering both distribution and content. We leverage proprietary business process, vendor and electronic payment management software and behavioral science based analytics to improve outcomes for marketplace participants."
If you figured out what they did from reading that, congratulations, because I couldn't. I own the company and I still do not know all of the services they provide. What I do know is that more than half of Altisource's revenue is derived from Ocwen. Ocwen uses Altiosurce's state of the art servicing technology to service their loans. Altisource's technology allows Ocwen to be such a low-cost servicer. Altisource only provides their technology to Ocwen and no other servicers.
http://oraclefromomaha.files.wordpress.com/2014/04/1.png
In the above link, you can see the ways Altisource generates revenue. The main thing to know here is that Altisource generates a huge portion of their revenue from Ocwen. When Ocwen makes less modifications on loans, they use Altisource's services less so Altisource makes less money. When Ocwen modifies more loans then Altisource makes more money because Ocwen uses their serivices more. It provides a hedge against parts of their business that may struggle in a recession like any other business. During the natural economic cycle if there is a recession and Ocwen is modifying more loans because more homeowners cannot make payments then Altisource is making more money than they would during good economic times because Ocwen uses their services more. The more MSRs Ocwen acquires, the more Altisource makes.
Ocwen's growth (basically a quick long thesis on Ocwen)
When a bank loans money to an individual to buy a house, a mortgage is originated and an MSR is created. The bank then keeps the mortgage on its books or sells the mortgage to another entity. Perhaps Fannie or Freddie. But what happens to the MSR? The MSR is then sold to a servicer such as Nationstar, Walter Investment Management Corp, or Ocwen. The reason the banks or originator of the mortgage sell the MSR is because they cannot service it properly and/or they would lose money in the process of trying to service it. Because of Dodd Frank, banks are trying to get MSRs off their books even faster because they cannot service them efficiently as previously mentioned and because they will have to hold 250% more capital against the MSRs. All banks are moving away from owning MSRs and non-bank servicing is becoming a larger industry, and Ocwen is leading the way. Due to the high supply of MSRs that are wanting to be sold by banks the MSRs can currently be bought at a 20-30% yield. Ocwen can buy the most MSRs because they are the best capitalized and they use the most conservative balance sheet. Ocwen being the lowest cost operator provides them with a huge competitive advantage when bidding for MSRs as well. Ocwen will continue to lead the non-bank servicers in buying MSRs. Ocwen currently has $464 billion of unpaid principle balance of loans they are servicing and another trillion dollars of subprime (Ocwen specializes in subprime) UPB is expected to get into the hands of non bank servicers by 2018 (3-4 trillion in UPB of regular MSRs). Ocwen will get the most of that trillion dollars of UPB of any servicer because of their competitive advantages.
Another competitive advantage of Ocwen is their relationship Home Loan Servicing Solutions Ltd. HLSS was also created by Bill Erbey. HLSS provides the capital for Ocwen to service loans so Ocwen does not have to tie up their capital. In the future, HLSS will acquire more loans and allow Ocwen to sub-service them through a unique financing strategy. This strategy called the accretion model is a genius way to get capital for HLSS to afford a virtually unlimited amount of MSRs. HLSS pays a huge dividend and because of this dividend, HLSS trades above its tangible book value due to fixed income hungry investors who want a fat dividend. HLSS then issues more shares above tangible book value to then acquire more MSRs. Issuing shares above book value actually creates value for HLSS shareholders also instead of diluting value as many people would think issuing shares does. Those MSRs are then sub-serviced by Ocwen, who still uses Altisource's technology.
Ocwen is also getting into foreword and reverse mortgage origination so they can have a constant stream of MSRs.
Basically, Ocwen and HLSS are going to acquire more MSRs and Ocwen will be servicing more mortgages. More mortgages serviced by Ocwen = more revenue for altisource.
All MSR transactions have currently been stopped by a New York financial regulator but we will get to that issue later.
Share Repurchases
Up until a few months ago the laws of Luxembourg restricted the amount of shares that Altisource could repurchase. Altisource recently created a foreign subsidiary that does nothing called "MidCo" to hold all other parts of the business so there would legally be no restrictions on share repurchases. Until Altisource did this, they were repurchasing the maximum amount of shares that Luxembourg would allow.
Here is Altisource's entity structure to bypass Luxembourg share repurchase laws http://i.imgur.com/J6LPEc0.jpg
The highlighted dark blue entity will be the entity repurchasing unlimited shares because MidCo, its parent company is not in Luxembourg. How smart is that.
Altisource currently authorized the repurchase of up to 2.9 million shares. 2.9 million shares is 13% of their market cap. They could easily repurchase that amount. Altisource also just finalized a loan with BAC for $200 million to repurchase shares so the share repurchases will really start to kick into high gear with the new liquidity and cheaper price. Up until the sharp share price drop, Altisource was repurchasing for the past several months around $110. That shows the board and management think the company is undervalued at $110 and now it is at $84 and nothing fundamentally changed about the company.
Insider Purchases
During the past 6 months, 3 insiders have purchased at $102, $103, $106, and $120. Between 20% and 43% above current market prices. Bill Erbey also owns 30% of Altisource and 13% of Ocwen. His views are directly in line with other shareholders.
Bill Erbey and his Capital Allocation
Bill Erbey is the Chairman of Ocwen, Altisource Portfolio Solutions, Altisource Asset Management Corporation, Altisource Residential, and Home Loan Servicing Solutions. Bill has done a great job of creating shareholder value for Ocwen and Altisource shareholders. Bill has also greatly benefited from this because of his stakes in thise companies. Before the sharp share price drop due to outside forces, Bill compounded Ocwen's stock at 30% per year since 2002 WITHOUT including the Altisource spinoff which compounded itself since 2009 at almost 75% a year. Altisource then spunoff Altisource Residential and Altisource Asset Management. Every spinoff is a value creating machine. At one point AAMC had compounded 430% in a year and a half, although it was due to a stretched valuation. Bill is dedicated to doing whatever it takes to create shareholder value. He relocated to the Virgin Islands just to save Ocwen some money on taxes.
I once read a story about Bill in his Virgin Islands home and his electric bill for the air conditioning. Keep in mind, Mr. Erbey is a multi billionaire. Bill got his electric bill and saw his costs had skyrocketed due to his air conditioning. Bill then sat there after that baking and sweating in the heat in his home so he could save a couple thousand on his electricity bill. He will do anything to save a dollar.
Hubzu
Hubzu is owned by Altisource. Hubzu is currently an online marketplace to buy and sell foreclosed homes. Like Zillow and Trulia but for foreclosed homes. Hubzu takes foreclosed homes from Ocwen and lists them on their website Hubzu.com. Hubzu is trying to get into the non-distressed house listing like other real estate websites like Zillow and Trulia. This will grow Hubzu at an even faster rate. Altisource states Hubzu gets about 1 million unique new visitors per month. When you buy Altisource you are also buying the jewel of Hubzu. Bill Erbey claims that Hubzu makes "as much money in one quarter as Zillow does in 4 quarters" Zillow has a market capitalization of $5 billion. Zillow's market capitalization is definitely stretched but a spinoff would create a lot of shareholder value even if the market gave Hubzu a fraction of Zillow's valuation.
Why is the company undervalued?
All this greatness in one company so why is it so undervalued? Remember how Altisource's earning were pretty much directly tied to how well Ocwen does? A New York State Financial Department regulator named Benjamin Lawsky halted a $2.7 bilion ($39 billion in UPB) Wells Fargo MSR transfer to Ocwen. This also halted all of the other MSR transactions between banks and servicers. Benjamin Lawsky is probing into Ocwen and other servicers. He states that he wants to make sure Ocwen and other servicers have the capacity to service loans efficiently because they are "growing too fast". The relationships these 5 companies share though is somewhat sketchy. They have a lot of the same board members and they all work with each other and make money off each other. Ocwen is the best servicer of them all though. They provide more loan modifications than anyone else and they have the lowest re default rate.
A slide from an investor presentation shows how they compare to others http://i.imgur.com/YkIKD2O.png
Even if Lawsky did find that some servicers do not have the capacity to service loans then Ocwen would be the last one in question because it is easy to see they are doing the best for their consumer compared to anyone other servicer.
Benjamin Lawsky is doing this for his own political reasons. He wants his name on the news. He wants people to see his name. Perhaps he wants to run for governor or something. Why would he schedule an interview with CNBC about the probe into the mortgage servicers right after it is announced. Why would he send a letter to Altisource and at the same time send it to the press, therefore ruining Altisource's reputation without giving them a chance to respond. He is also really into regulating bitcoin in New York which is just another vehicle to get his name in the news.
There are very recent updates with the regulatory pressure and basically the probing is narrowed down to an issue with force placed insurance and Altisource. Ben Lawsky could not find anything else. He sent this letter on Aug. 4th to Ocwen. So this is what the probe is narrowed down to.
http://www.dfs.ny.gov/about/press2014/pr140804-ocwen-letter.pdf
Basically, if a homeowner is struggling to make payments and can't pay their insurance, Ocwen has the right to force place insurance into their payments so the mortgage owner does not incur massive losses if a catastrophe happens. Ocwen has to outsource whoever force places the insurance and the issue that Ben Lawsky was worried about was why Altisource was appointed to find someone to force place that insurance, why Altisource received commission for basically doing nothing, and why Bill Erbey did not consult with any of the Ocwen board before making this decision to allow Altisource to find an insurer.
Altisource will probably get a one time fine settlement and they will go on doing business as usual. I believe this because an almost identical situation happened with Assurant and the New York State Financial Department and they settled for $14 million. There is also an interview on CNBC with someone who talks to the CEO of Ocwen and they are sure that Ocwen and Altisource will just settle with a deal with Lawsky and that will be the end of it.
Interview:
http://video.cnbc.com/gallery/?video=3000298804
Risks Benjamin Lawsky actually finds something else that Altisource was doing wrong. Bill Erbey Dies. He is in his 60s and overweight.
Conclusion
In conclusion Altisource is extremely cheap. Remember that quote about not knowing how much a man weighs but knowing he is fat? That is the case with Altisource. Altisource is definitely undervalued but there are a range of possibilities of the valuation with Hubzu, regulatory matters, growth, etc.
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Entidades Reguladoras Veem Valor No Bitcoin, E Investidores Se Apressam Em Concordar.

BY NATHANIEL POPPER
A moeda virtual bitcoin deu um grande passo em direção a sua popularização nesta segunda-feira quando as autoridades federais sinalizaram sua disposição de aceitá-la como uma alternativa de pagamento legítimo. Um número de funcionários federais disse em uma audiência no Senado que essas redes financeiras ofereceram benefícios reais para o sistema financeiro, assim como eles reconheceram que as novas formas de dinheiro digitais haviam fornecido caminhos para a lavagem de dinheiro e atividades ilegais.
"Há muitas oportunidades para as moedas digitais operarem dentro das leis e regulamentos existentes", disse Edward Lowery, um agente especial do Serviço Secreto, que é encarregado de proteger a integridade do dólar. Sinais de que o governo não iria se colocar no caminho do desenvolvimento do bitcoin, mesmo que ele venha reprimindo as redes criminosas que usam o dinheiro digital, alimentou uma forte recuperação no preço do cripto-moeda.
Na segunda-feira à noite, o valor de uma unidade de bitcoin explodiu ultrapassando 700 dólares em algumas trocas. Esse excepcional montante de bitcoins - que é criado por uma rede de usuários que resolvem problemas matemáticos complexos - agora vale mais de US $ 7 bilhões. A audiência do Senado nesta segunda-feira à tarde, foi uma indicação mais clara do desejo do governo de lidar com as consequências deste crescimento, e o reconhecimento de que o bitcoin e outras redes semelhantes podem se tornar peças mais duradouras e importantes do cenário financeiro.
Video: http://www.nytimes.com/video/business/100000002167289/bitcoin-has-real-world-investors.html
"A decisão de trazer a moeda virtual dentro do escopo do nosso quadro regulamentar deve ser visto por aqueles que respeitam e obedecem aos fundamentos básicos da lei como um desenvolvimento positivo para o setor", disse Jennifer Shasky Calvery, o diretor do Departamento de Execução de Crimes Financeiros do Tesouro. "Ele reconhece a inovação que moedas virtuais fornecem, e os benefícios que elas podem oferecer." Ms. Shasky Calvery e os outros funcionários na audiência disseram que ainda havia questões básicas a serem respondidas sobre moedas virtuais, incluindo se elas realmente podem ser consideradas moedas ou se são mais corretamente classificados como bens ou valores mobiliários. A distinção vai determinar quais agências regularam as redes e como elas serão tratadas sob a lei fiscal.
Ms. Shasky Calvery disse que a Receita Federal estava "trabalhando ativamente" em suas próprias regras para o bitcoin.
A audiência seguiu outras medidas menos visíveis tomadas pelos reguladores e legisladores para trazer o dinheiro digital ao mainstream monetário.
O principal regulador financeiro do Estado de Nova York, Benjamin M. Lawsky, disse na semana passada que ele iria realizar uma audiência para considerar a criação de um BitLicense para fornecer mais fiscalização para as transações. Mais cedo, a Comissão Federal Eleitoral expôs um aviso indicando que bitcoin pode ser legalmente aceitos como doações políticas.
O conselheiro geral da Fundação Bitcoin, uma organização sem fins lucrativos que defende a moeda, disse em seu depoimento na segunda-feira que ele estava recebendo uma resposta muito mais amigável do governo e do setor financeiro.
"Nós recentemente percebemos uma melhora acentuada no tom e ênfase tomada por ambos os funcionários do Estado e executivos de banco", disse o conselheiro-geral, Patrick Murck, disse.
Bitcoin tem experimentado uma ascensão notável desde que foi criado em 2009 por um programador anônimo ou coletivo conhecido como Satoshi Nakamoto. O dinheiro, que não está vinculado a qualquer moeda nacional, tem sido popular com tecnófilos que são céticos dos bancos centrais do mundo. Apenas uma quantidade finita de bitcoin será criada - 21 milhões de unidades. Os usuários alavancaram os preços pelas casas de câmbio pela Internet, apostando que a moeda será mais amplamente utilizada no futuro.
Há questões importantes sobre a sabedoria de usar o dinheiro digital como um investimento, uma vez que bitcoin não possui valor intrínseco e provou ser vulnerável a hackers. Muitos gestores de fundos têm recomendado aos investidores inexperientes para permanecerem longe.
Recentemente, porém, o bitcoin tem pegando fogo em todo o mundo, com trocas na China particularmente ativas. Um número crescente de investidores americanos proeminentes também compraram participações, incluindo Michael Novogratz, diretor da gigante Fortress Investment Group¹, assim como os gêmeos Winklevoss, Cameron e Tyler.
A participação cada vez mais generalizada do bitcoin deslocou a atenção para longe dos empreendimentos criminosos que usaram o dinheiro digital, mas era um foco na audiência do Senado.
No mês passado, o mercado on-line Silk Road, onde o Bitcoin é a principal forma de pagamento, foi fechado e seu fundador preso depois que as autoridades o acusaram de ser usado para comprar e vender drogas, armas e pornografia. O presidente da comissão do Senado, Thomas R. Carper, democrata de Delaware, disse que poucos dias depois da prisão, um site semelhante surgiu.
"Pode ser mais difícil de rastrear os criminosos que usam o Bitcoin", policiais disseram na audiência, "porque operam através das fronteiras internacionais e muitas vezes não usam instituições financeiras estabelecidas que reportem as transações”.
Mas Mythili Raman, um procurador-geral adjunto do Departamento de Justiça, também disse que, porque cada transação de bitcoin era gravada em um registro público, foi possível aos investigadores rastrear a movimentação de dinheiro entre contas.
"Não é, de fato, anônimo. Não está imune a investigação", disse Raman.
Todos os funcionários na audiência disseram que crimes tinham sido um problema durante os primeiros dias de cartões de crédito e sistemas de pagamento online como o PayPal, e não deve ser uma razão para limitar a inovação.
"É nosso dever, como aplicadores da lei de permanecermos vigilantes, reconhecendo que há muitos usuários legítimos desses serviços", disse Raman.
Os defensores do bitcoin que testemunharam na audiência disseram que o bitcoin pode trazer grandes mudanças para o sistema financeiro por cortar os intermediários necessários para movimentar o dinheiro em todo o mundo. "Estou aqui para testemunhar porque eu acredito que a moeda digital global representa uma das inovações técnicas e econômicas mais importantes do nosso tempo", disse Jeremy Allaire, presidente-executivo do Círculo Internet Financial, que está tentando promover uma utilização mais difundida da moeda.
Dado o apelo do bitcoin aos céticos do governo, muitos aficionados têm sido cautelosos com envolvimento de Washington. Mas os defensores na audiência disseram que a crescente cooperação com as entidades reguladoras poderiam lançar as bases para um maior crescimento.
"À medida que essa tecnologia se desloca de pioneiros para a aceitação popular, é fundamental em minha opinião, que os governos federais e estaduais estabeleçam políticas em torno da moeda digital", disse Allaire.
¹http://dealbook.on.nytimes.com/public/overview?symbol=FIG&inline=nyt-org
Traduzido por Sarah Alexandre
Uma versão desse artigo aparece na impressão de 19/11/2013, na página B1 da edição do NewYork com o título: “Regulators See Value in Bitcoin, And Investors Hasten to Agree” Texto original em: http://dealbook.nytimes.com/2013/11/18/regulators-see-value-in-bitcoin-and-investors-hasten-to-agree/?_r=0
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Top 10 Bitcoin Villains - Bitcoin.com #3 BitLicense Will Publish End of October, NYDFS Ben Lawsky Will Keynote Money2020 Early November Bitcoin flaws: Can fundamental problems be fixed? Benjamin Lawsky Keynote - Money 2020 - Nov 2, 2014 - #bitcoin #regulation Bitcoin could be viable money alternative in 5 years -Lawsky

Benjamin Lawsky: Bitcoin will be Strengthened by Collapse of MtGox . By Jerin Mathew. Updated March 4, 2014 08:21 GMT; New York's banking regulator has said the collapse of bitcoin exchange MtGox ... Benjamin Lawsky, superintendent of the NYDFS, had been talking with the bitcoin community through public hearings and a Reddit AmA. This week, he unveiled the NYFDFS proposed bitcoin regulations, which will be posted on July 23 for a 45-day window for public comment. Benjamin Lawsky: ‘I’m Doing No Work in the Digital Currency Space’ Articles; Guides. What Is Bitcoin? How To Buy, Sell And Transact With Bitcoin; What is Bitcoin Mining? What Is the Lightning Network? Conference; Events; Store; Follow. RSS Feed. Facebook. Twitter. Instagram. Telegram. Youtube. Linkedin . Regulation Benjamin Lawsky: ‘I’m Doing No Work in the Digital Currency Space ... As the BitLicense turns five, the issuing watchdog looks to lure blockchain startups to New York, while a major brokerage firm is pivoting to crypto. /r/btc was created to foster and support free and open Bitcoin discussion, Bitcoin news, and exclusive AMA (Ask Me Anything) interviews from top...

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Top 10 Bitcoin Villains - Bitcoin.com #3

Ripple adds Benjamin Lawsky to its Board to help get more Banks to use XRP - Huge Win for Ripple! ... Chicago Sun-Times Goes Bitcoin, Ebay Warms Up, and China is Still Hating - Duration: 2:27 ... Live Bitcoin Liquidation Watch: June 1 2020 IntroToCryptos 206 watching Live now Kayleigh McEnany explains what it will take to stop antifa - Duration: 7:26. 10 Benjamin Lawsky Bitcoin Future Quote: Bitcoin will remain, in my opinion, a relentless anomaly that refuses to go away - a black swan that cannot be ignored or extinguished. Bitcoin activist Theo Chino confronts infamous New York regulator Benjamin Lawsky about his even more infamous BitLicense...and gets video of it! How to buy your own ad on - or donate to - the ... POLITICO Pro reporters Zachary Warmbrodt and Kate Davidson delve into the fundamental flaws of Bitcoin, and what can be fixed, with New York State superintendent for financial services Benjamin ...

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