e-Oracle is a United Kingdom marketing platform for the Fintech community (the “Company”) and classified as a developer and publisher of marketing technology, news and information and therefore believes it is exempt from registration with any regulatory body.
The Company delivers a marketing technology platform for users to access startup technology use cases, research, analysis, and convenience tools which are sent to subscribing members via email, mobile app, telegram, website membership and all other electronic means. There is no customization, review or consultation of the member’s personal financial objectives, situation or need. The member is free to act or not to act on the information provided. All information is provided uniformly to the member base without modification or consideration of any personal situation or need.
We provide a marketing platform for startup use cases primarily in the Blockchain and Digital Banking sectors and other technology sector use cases. The platform provides research, commentary and education for world financial and technology markets which may include but are not limited to: equities, options, ETF (exchange traded funds), currencies including cryptocurrency and crowd funding.
To further clarify our position as a Publisher, please note the following:
Due to the variety of factors that affect trade performance, the company does not always post all performance and all results. From time to time, we will review specific performance data of our Platform Use Cases.
We have the following policies in place regarding the discussion of our Platform Use Case performance and the information, research, and customers:
The Company works to ensure that members fully understand both performance and use disclaimers. We have a commitment to a “plain language” representation of our disclaimers where all training sessions, recordings, newsletter alerts, emails, website posts, and subscriptions include our detailed disclosure of risk and the use of our products solely at the member’s discretion. An example of a disclaimer from our presentations: Persons who choose to purchase a subscription and subscribe to our information research and platform use cases services also accepts additional disclaimers and risk disclosure at the time of purchase.
As stated throughout this document, the Company is not a broker, dealer, advisor, fiduciary or registered/licensed financial entity. We are a producer and publisher of blockchain, startup and financial technology information, education and research. Our members are free to use the information we provide to place trades or swaps of any asset or currency in any form for themselves with whichever broker or exchange they choose. We do, however, review various brokers exchanges and blockchain technologies and products, and provide “products and services of choice” which are firms that are compliant, under regulatory control, and offer services beneficial to members such as enhanced customer service and additional training to name a few.
Brokers and Exchanges of Choice are not affiliated with the Company, we do not have an agreement, partnership, arrangement or any type of legal association with any of these firms. A “broker or exchange of choice” is simply listed to provide our members services and customized programming that may not be available through all brokers. We also provide our members a list of considerations they should review before they select a brokerage firm which includes but is not limited to:
The Company makes services available from third party providers. When a service is made available, the Company ensures the customer understands they are entering an agreement with a separate and distinct company that will provide them the service they desire. We require our customers to sign and accept an understanding that they are accessing a service from a third party. Despite these actions, when a third party defaults or fails to provide their service, the customer seeks to hold e-Oracle responsible. e-Oracle is not responsible for third party service providers. We make them available because there is a customer demand, we do our best to perform proper due diligence and explain all associated risks. Further, we ensure our customers accept these risks before moving forward. It is important for users of services provided by third parties to understand that they become a customer of the third party and that does not have any part to that relationship. If a customer is uncomfortable with assuming this responsibility, they should not use the third-party service.
The Company now provides members access to virtual currency or “crypto” education webinars, research, patents and alerts. Guidance regarding the cryptocurrency / virtual currency environment is not yet fully determined. The market is emerging, and regulatory guidance is in the process of being developed, changed, and further refined. The Company is committed to understanding the rapidly changing regulatory environment and desires to ensure all services are within regulatory guidelines. The Company will change, modify, or eliminate a service if it is deemed to be outside regulatory guidance. The following risks should be considered before purchasing, trading or holding virtual currencies:
Unique Features of Virtual Currencies. Virtual currencies are not legal tender in the United States and many people question whether they have intrinsic value. The price of many virtual currencies is based on the agreement of the parties to a transaction. The risks associated with the unique features of virtual currencies should be explained and understood.
Price Volatility. The price of a virtual currency is based on the perceived value of the virtual currency and subject to changes in sentiment, which make these products highly volatile. Certain virtual currencies have experienced daily price volatility of more than 20%. The risks associated with the extreme price volatility of virtual currencies and the possibility of rapid and substantial price movements, which could result in significant losses, should be explained.
Valuation and Liquidity. Virtual currencies can be traded through privately negotiated transactions and through numerous virtual currency exchanges and intermediaries around the world. The lack of a centralized pricing source poses a variety of valuation challenges. In addition, the dispersed liquidity may pose challenges for market participants trying to exit a position, particularly during periods of stress. NFA generally expects the policies and procedures for valuing virtual currency products implemented by CPOs and CTAs to take into account their access to liquidity and the volatility of these markets. The valuation and liquidity risks and the procedures used for valuing virtual currencies and the related risks should be explained.
Cybersecurity. The cybersecurity risks of virtual currencies and related “wallets” or spot exchanges include hacking vulnerabilities and a risk that publicly distributed ledgers may not be immutable. A cybersecurity event could result in a substantial, immediate, and irreversible loss for market participants that trade virtual currencies. Even a minor cybersecurity event in a virtual currency is likely to result in downward price pressure on that product and potentially other virtual currencies. The cybersecurity risks associated with engaging in virtual currency transactions should be explained.
Opaque Spot Market. Virtual currency balances are generally maintained as an address on the blockchain and are accessed through private keys, which may be held by a market participant or a custodian. Although virtual currency transactions are typically publicly available on a blockchain or distributed ledger, the public address does not identify the controller, owner or holder of the private key. Unlike bank and brokerage accounts, virtual currency exchanges and custodians that hold virtual currencies do not always identify the owner. The opaque underlying or spot market poses asset verification challenges for market participants, regulators and auditors and gives rise to an increased risk of manipulation and fraud, including the potential for Ponzi schemes, bucket shops and pump and dump schemes. The risks associated with the opaque nature of the underlying or spot virtual currency market should be explained.
Virtual Currency Exchanges, Intermediaries and Custodians. Virtual currency exchanges, as well as other intermediaries, custodians and vendors used to facilitate virtual currency transactions, are relatively new and largely unregulated in both the United States and many foreign jurisdictions. Virtual currency exchanges generally purchase virtual currencies for their own account on the public ledger and allocate positions to customers through internal bookkeeping entries while maintaining exclusive control of the private keys. Under this structure, virtual currency exchanges collect large amounts of customer funds for the purpose of buying and holding virtual currencies on behalf of their customers. The opaque underlying spot market and lack of regulatory oversight creates a risk that a virtual currency exchange may not hold sufficient virtual currencies and funds to satisfy its obligations and that such deficiency may not be easily identified or discovered. In addition, many virtual currency exchanges have experienced significant outages, downtime and transaction processing delays and may have a higher level of operational risk than regulated futures or securities exchanges. If virtual currencies are traded or held through an exchange, intermediary or custodian, then the risks associated with engaging in these transactions should be explained.
Regulatory Landscape. Virtual currencies currently face an uncertain regulatory landscape in the United States and many foreign jurisdictions. In the United States, virtual currencies are not subject to federal regulatory oversight but may be regulated by one or more state regulatory bodies. In addition, many virtual currency derivatives are regulated by the CFTC, and the SEC has cautioned that many initial coin offerings are likely to fall within the definition of a security and subject to U.S. securities laws. One or more jurisdictions may, in the future, adopt laws, regulations or directives that affect virtual currency networks and their users. Such laws, regulations or directives may impact the price of virtual currencies and their acceptance by users, merchants and service providers. The risks associated with the current regulatory landscape for virtual currencies should be explained.
Technology. The relatively new and rapidly evolving technology underlying virtual currencies introduces unique risks. For example, a unique private key is required to access, use or transfer a virtual currency on a blockchain or distributed ledger. The loss, theft or destruction of a private key may result in an irreversible loss. The ability to participate in forks could also have implications for investors. For example, a market participant holding a virtual currency position through a virtual currency exchange may be adversely impacted if the exchange does not allow its customers to participate in a fork that creates a new product. The risks posed by this nascent technology should be explained.
Transaction Fees. Many virtual currencies allow market participants to offer miners (i.e., parties that process transactions and record them on a blockchain or distributed ledger) a fee. While not mandatory, a fee is generally necessary to ensure that a transaction is promptly recorded on a blockchain or distributed ledger. The amounts of these fees are subject to market forces and it is possible that the fees could increase substantially during a period of stress. In addition, virtual currency exchanges, wallet providers and other custodians may charge high fees relative to custodians in many other financial markets. The impact of these transaction fees on performance should be explained.
The Company offers an optional bonus plan to members who would like to actively sell our services to others. Compliance and governance over the actions of the Independent Distributor is critical to our operations, reputation, and overall customer satisfaction.
Our Distributors are governed by an extensive policy & procedures manual: Policies & Procedures
Violations of policy are taken very seriously and could result in the termination of a Distributor Agreement. With today’s instantaneous access to information, the ability for us to police and scrutinize each post, tweet, video, or comment regarding our services is challenging. We are continually deploying additional technologies to assist in automating web searches for compliance infractions. In many cases, we find that individuals and users of our services only have a common understanding of terms and not the impact and meaning certain words have in the regulatory environment. Use of the words, “advice, automatic, opportunity, etc.” seem harmless to those who are speaking in plain terms. Therefore, we have a commitment to compliance education of our Distributors to ensure their awareness and implications of using such words when discussing our products and services. We are continually adding additional courses, personnel and expanding our discussions of the regulatory environment.
The effective date of this Products & Services Regulatory Compliance is June 1, 2021.