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Bob The Magic Custodian
Summary: Everyone knows that when you give your assets to someone else, they always keep them safe. If this is true for individuals, it is certainly true for businesses. Custodians always tell the truth and manage funds properly. They won't have any interest in taking the assets as an exchange operator would. Auditors tell the truth and can't be misled. That's because organizations that are regulated are incapable of lying and don't make mistakes. First, some background. Here is a summary of how custodians make us more secure: Previously, we might give Alice our crypto assets to hold. There were risks:
Alice might take the assets and disappear.
Alice might spend the assets and pretend that she still has them (fractional model).
Alice might store the assets insecurely and they'll get stolen.
Alice might give the assets to someone else by mistake or by force.
Alice might lose access to the assets.
But "no worries", Alice has a custodian named Bob. Bob is dressed in a nice suit. He knows some politicians. And he drives a Porsche. "So you have nothing to worry about!". And look at all the benefits we get:
Alice can't take the assets and disappear (unless she asks Bob or never gives them to Bob).
Alice can't spend the assets and pretend that she still has them. (Unless she didn't give them to Bob or asks him for them.)
Alice can't store the assets insecurely so they get stolen. (After all - she doesn't have any control over the withdrawal process from any of Bob's systems, right?)
Alice can't give the assets to someone else by mistake or by force. (Bob will stop her, right Bob?)
Alice can't lose access to the funds. (She'll always be present, sane, and remember all secrets, right?)
See - all problems are solved! All we have to worry about now is:
Bob might take the assets and disappear.
Bob might spend the assets and pretend that he still has them (fractional model).
Bob might store the assets insecurely and they'll get stolen.
Bob might give the assets to someone else by mistake or by force.
Bob might lose access to the assets.
It's pretty simple. Before we had to trust Alice. Now we only have to trust Alice, Bob, and all the ways in which they communicate. Just think of how much more secure we are! "On top of that", Bob assures us, "we're using a special wallet structure". Bob shows Alice a diagram. "We've broken the balance up and store it in lots of smaller wallets. That way", he assures her, "a thief can't take it all at once". And he points to a historic case where a large sum was taken "because it was stored in a single wallet... how stupid". "Very early on, we used to have all the crypto in one wallet", he said, "and then one Christmas a hacker came and took it all. We call him the Grinch. Now we individually wrap each crypto and stick it under a binary search tree. The Grinch has never been back since." "As well", Bob continues, "even if someone were to get in, we've got insurance. It covers all thefts and even coercion, collusion, and misplaced keys - only subject to the policy terms and conditions." And with that, he pulls out a phone-book sized contract and slams it on the desk with a thud. "Yep", he continues, "we're paying top dollar for one of the best policies in the country!" "Can I read it?' Alice asks. "Sure," Bob says, "just as soon as our legal team is done with it. They're almost through the first chapter." He pauses, then continues. "And can you believe that sales guy Mike? He has the same year Porsche as me. I mean, what are the odds?" "Do you use multi-sig?", Alice asks. "Absolutely!" Bob replies. "All our engineers are fully trained in multi-sig. Whenever we want to set up a new wallet, we generate 2 separate keys in an air-gapped process and store them in this proprietary system here. Look, it even requires the biometric signature from one of our team members to initiate any withdrawal." He demonstrates by pressing his thumb into the display. "We use a third-party cloud validation API to match the thumbprint and authorize each withdrawal. The keys are also backed up daily to an off-site third-party." "Wow that's really impressive," Alice says, "but what if we need access for a withdrawal outside of office hours?" "Well that's no issue", Bob says, "just send us an email, call, or text message and we always have someone on staff to help out. Just another part of our strong commitment to all our customers!" "What about Proof of Reserve?", Alice asks. "Of course", Bob replies, "though rather than publish any blockchain addresses or signed transaction, for privacy we just do a SHA256 refactoring of the inverse hash modulus for each UTXO nonce and combine the smart contract coefficient consensus in our hyperledger lightning node. But it's really simple to use." He pushes a button and a large green checkmark appears on a screen. "See - the algorithm ran through and reserves are proven." "Wow", Alice says, "you really know your stuff! And that is easy to use! What about fiat balances?" "Yeah, we have an auditor too", Bob replies, "Been using him for a long time so we have quite a strong relationship going! We have special books we give him every year and he's very efficient! Checks the fiat, crypto, and everything all at once!" "We used to have a nice offline multi-sig setup we've been using without issue for the past 5 years, but I think we'll move all our funds over to your facility," Alice says. "Awesome", Bob replies, "Thanks so much! This is perfect timing too - my Porsche got a dent on it this morning. We have the paperwork right over here." "Great!", Alice replies. And with that, Alice gets out her pen and Bob gets the contract. "Don't worry", he says, "you can take your crypto-assets back anytime you like - just subject to our cancellation policy. Our annual management fees are also super low and we don't adjust them often". How many holes have to exist for your funds to get stolen? Just one. Why are we taking a powerful offline multi-sig setup, widely used globally in hundreds of different/lacking regulatory environments with 0 breaches to date, and circumventing it by a demonstrably weak third party layer? And paying a great expense to do so? If you go through the list of breaches in the past 2 years to highly credible organizations, you go through the list of major corporate frauds (only the ones we know about), you go through the list of all the times platforms have lost funds, you go through the list of times and ways that people have lost their crypto from identity theft, hot wallet exploits, extortion, etc... and then you go through this custodian with a fine-tooth comb and truly believe they have value to add far beyond what you could, sticking your funds in a wallet (or set of wallets) they control exclusively is the absolute worst possible way to take advantage of that security. The best way to add security for crypto-assets is to make a stronger multi-sig. With one custodian, what you are doing is giving them your cryptocurrency and hoping they're honest, competent, and flawlessly secure. It's no different than storing it on a really secure exchange. Maybe the insurance will cover you. Didn't work for Bitpay in 2015. Didn't work for Yapizon in 2017. Insurance has never paid a claim in the entire history of cryptocurrency. But maybe you'll get lucky. Maybe your exact scenario will buck the trend and be what they're willing to cover. After the large deductible and hopefully without a long and expensive court battle. And you want to advertise this increase in risk, the lapse of judgement, an accident waiting to happen, as though it's some kind of benefit to customers ("Free institutional-grade storage for your digital assets.")? And then some people are writing to the OSC that custodians should be mandatory for all funds on every exchange platform? That this somehow will make Canadians as a whole more secure or better protected compared with standard air-gapped multi-sig? On what planet? Most of the problems in Canada stemmed from one thing - a lack of transparency. If Canadians had known what a joke Quadriga was - it wouldn't have grown to lose $400m from hard-working Canadians from coast to coast to coast. And Gerald Cotten would be in jail, not wherever he is now (at best, rotting peacefully). EZ-BTC and mister Dave Smilie would have been a tiny little scam to his friends, not a multi-million dollar fraud. Einstein would have got their act together or been shut down BEFORE losing millions and millions more in people's funds generously donated to criminals. MapleChange wouldn't have even been a thing. And maybe we'd know a little more about CoinTradeNewNote - like how much was lost in there. Almost all of the major losses with cryptocurrency exchanges involve deception with unbacked funds. So it's great to see transparency reports from BitBuy and ShakePay where someone independently verified the backing. The only thing we don't have is:
ANY CERTAINTY BALANCES WEREN'T EXCLUDED. Quadriga's largest account was $70m. 80% of funds are in 20% of accounts (Pareto principle). All it takes is excluding a few really large accounts - and nobody's the wiser. A fractional platform can easily pass any audit this way.
ANY VISIBILITY WHATSOEVER INTO THE CUSTODIANS. BitBuy put out their report before moving all the funds to their custodian and ShakePay apparently can't even tell us who the custodian is. That's pretty important considering that basically all of the funds are now stored there.
ANY IDEA ABOUT THE OTHER EXCHANGES. In order for this to be effective, it has to be the norm. It needs to be "unusual" not to know. If obscurity is the norm, then it's super easy for people like Gerald Cotten and Dave Smilie to blend right in.
It's not complicated to validate cryptocurrency assets. They need to exist, they need to be spendable, and they need to cover the total balances. There are plenty of credible people and firms across the country that have the capacity to reasonably perform this validation. Having more frequent checks by different, independent, parties who publish transparent reports is far more valuable than an annual check by a single "more credible/official" party who does the exact same basic checks and may or may not publish anything. Here's an example set of requirements that could be mandated:
First report within 1 month of launching, another within 3 months, and further reports at minimum every 6 months thereafter.
No auditor can be repeated within a 12 month period.
All reports must be public, identifying the auditor and the full methodology used.
All auditors must be independent of the firm being audited with no conflict of interest.
Reports must include the percentage of each asset backed, and how it's backed.
The auditor publishes a hash list, which lists a hash of each customer's information and balances that were included. Hash is one-way encryption so privacy is fully preserved. Every customer can use this to have 100% confidence they were included.
If we want more extensive requirements on audits, these should scale upward based on the total assets at risk on the platform, and whether the platform has loaned their assets out.
There are ways to structure audits such that neither crypto assets nor customer information are ever put at risk, and both can still be properly validated and publicly verifiable. There are also ways to structure audits such that they are completely reasonable for small platforms and don't inhibit innovation in any way. By making the process as reasonable as possible, we can completely eliminate any reason/excuse that an honest platform would have for not being audited. That is arguable far more important than any incremental improvement we might get from mandating "the best of the best" accountants. Right now we have nothing mandated and tons of Canadians using offshore exchanges with no oversight whatsoever. Transparency does not prove crypto assets are safe. CoinTradeNewNote, Flexcoin ($600k), and Canadian Bitcoins ($100k) are examples where crypto-assets were breached from platforms in Canada. All of them were online wallets and used no multi-sig as far as any records show. This is consistent with what we see globally - air-gapped multi-sig wallets have an impeccable record, while other schemes tend to suffer breach after breach. We don't actually know how much CoinTrader lost because there was no visibility. Rather than publishing details of what happened, the co-founder of CoinTrader silently moved on to found another platform - the "most trusted way to buy and sell crypto" - a site that has no information whatsoever (that I could find) on the storage practices and a FAQ advising that “[t]rading cryptocurrency is completely safe” and that having your own wallet is “entirely up to you! You can certainly keep cryptocurrency, or fiat, or both, on the app.” Doesn't sound like much was learned here, which is really sad to see. It's not that complicated or unreasonable to set up a proper hardware wallet. Multi-sig can be learned in a single course. Something the equivalent complexity of a driver's license test could prevent all the cold storage exploits we've seen to date - even globally. Platform operators have a key advantage in detecting and preventing fraud - they know their customers far better than any custodian ever would. The best job that custodians can do is to find high integrity individuals and train them to form even better wallet signatories. Rather than mandating that all platforms expose themselves to arbitrary third party risks, regulations should center around ensuring that all signatories are background-checked, properly trained, and using proper procedures. We also need to make sure that signatories are empowered with rights and responsibilities to reject and report fraud. They need to know that they can safely challenge and delay a transaction - even if it turns out they made a mistake. We need to have an environment where mistakes are brought to the surface and dealt with. Not one where firms and people feel the need to hide what happened. In addition to a knowledge-based test, an auditor can privately interview each signatory to make sure they're not in coercive situations, and we should make sure they can freely and anonymously report any issues without threat of retaliation. A proper multi-sig has each signature held by a separate person and is governed by policies and mutual decisions instead of a hierarchy. It includes at least one redundant signature. For best results, 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. History has demonstrated over and over again the risk of hot wallets even to highly credible organizations. Nonetheless, many platforms have hot wallets for convenience. While such losses are generally compensated by platforms without issue (for example Poloniex, Bitstamp, Bitfinex, Gatecoin, Coincheck, Bithumb, Zaif, CoinBene, Binance, Bitrue, Bitpoint, Upbit, VinDAX, and now KuCoin), the public tends to focus more on cases that didn't end well. Regardless of what systems are employed, there is always some level of risk. For that reason, most members of the public would prefer to see third party insurance. Rather than trying to convince third party profit-seekers to provide comprehensive insurance and then relying on an expensive and slow legal system to enforce against whatever legal loopholes they manage to find each and every time something goes wrong, insurance could be run through multiple exchange operators and regulators, with the shared interest of having a reputable industry, keeping costs down, and taking care of Canadians. For example, a 4 of 7 multi-sig insurance fund held between 5 independent exchange operators and 2 regulatory bodies. All Canadian exchanges could pay premiums at a set rate based on their needed coverage, with a higher price paid for hot wallet coverage (anything not an air-gapped multi-sig cold wallet). Such a model would be much cheaper to manage, offer better coverage, and be much more reliable to payout when needed. The kind of coverage you could have under this model is unheard of. You could even create something like the CDIC to protect Canadians who get their trading accounts hacked if they can sufficiently prove the loss is legitimate. In cases of fraud, gross negligence, or insolvency, the fund can be used to pay affected users directly (utilizing the last transparent balance report in the worst case), something which private insurance would never touch. While it's recommended to have official policies for coverage, a model where members vote would fully cover edge cases. (Could be similar to the Supreme Court where justices vote based on case law.) Such a model could fully protect all Canadians across all platforms. You can have a fiat coverage governed by legal agreements, and crypto-asset coverage governed by both multi-sig and legal agreements. It could be practical, affordable, and inclusive. Now, we are at a crossroads. We can happily give up our freedom, our innovation, and our money. We can pay hefty expenses to auditors, lawyers, and regulators year after year (and make no mistake - this cost will grow to many millions or even billions as the industry grows - and it will be borne by all Canadians on every platform because platforms are not going to eat up these costs at a loss). We can make it nearly impossible for any new platform to enter the marketplace, forcing Canadians to use the same stagnant platforms year after year. We can centralize and consolidate the entire industry into 2 or 3 big players and have everyone else fail (possibly to heavy losses of users of those platforms). And when a flawed security model doesn't work and gets breached, we can make it even more complicated with even more people in suits making big money doing the job that blockchain was supposed to do in the first place. We can build a system which is so intertwined and dependent on big government, traditional finance, and central bankers that it's future depends entirely on that of the fiat system, of fractional banking, and of government bail-outs. If we choose this path, as history has shown us over and over again, we can not go back, save for revolution. Our children and grandchildren will still be paying the consequences of what we decided today. Or, we can find solutions that work. We can maintain an open and innovative environment while making the adjustments we need to make to fully protect Canadian investors and cryptocurrency users, giving easy and affordable access to cryptocurrency for all Canadians on the platform of their choice, and creating an environment in which entrepreneurs and problem solvers can bring those solutions forward easily. None of the above precludes innovation in any way, or adds any unreasonable cost - and these three policies would demonstrably eliminate or resolve all 109 historic cases as studied here - that's every single case researched so far going back to 2011. It includes every loss that was studied so far not just in Canada but globally as well. Unfortunately, finding answers is the least challenging part. Far more challenging is to get platform operators and regulators to agree on anything. My last post got no response whatsoever, and while the OSC has told me they're happy for industry feedback, I believe my opinion alone is fairly meaningless. This takes the whole community working together to solve. So please let me know your thoughts. Please take the time to upvote and share this with people. Please - let's get this solved and not leave it up to other people to do. Facts/background/sources (skip if you like):
The inspiration for the paragraph about splitting wallets was an actual quote from a Canadian company providing custodial services in response to the OSC consultation paper: "We believe that it will be in the in best interests of investors to prohibit pooled crypto assets or ‘floats’. Most Platforms pool assets, citing reasons of practicality and expense. The recent hack of the world’s largest Platform – Binance – demonstrates the vulnerability of participants’ assets when such concessions are made. In this instance, the Platform’s entire hot wallet of Bitcoins, worth over $40 million, was stolen, facilitated in part by the pooling of client crypto assets." "the maintenance of participants (and Platform) crypto assets across multiple wallets distributes the related risk and responsibility of security - reducing the amount of insurance coverage required and making insurance coverage more readily obtainable". For the record, their reply also said nothing whatsoever about multi-sig or offline storage.
In addition to the fact that the $40m hack represented only one "hot wallet" of Binance, and they actually had the vast majority of assets in other wallets (including mostly cold wallets), multiple real cases have clearly demonstrated that risk is still present with multiple wallets. Bitfinex, VinDAX, Bithumb, Altsbit, BitPoint, Cryptopia, and just recently KuCoin all had multiple wallets breached all at the same time, and may represent a significantly larger impact on customers than the Binance breach which was fully covered by Binance. To represent that simply having multiple separate wallets under the same security scheme is a comprehensive way to reduce risk is just not true.
Private insurance has historically never covered a single loss in the cryptocurrency space (at least, not one that I was able to find), and there are notable cases where massive losses were not covered by insurance. Bitpay in 2015 and Yapizon in 2017 both had insurance policies that didn't pay out during the breach, even after a lengthly court process. The same insurance that ShakePay is presently using (and announced to much fanfare) was describe by their CEO himself as covering “physical theft of the media where the private keys are held,” which is something that has never historically happened. As was said with regard to the same policy in 2018 - “I don’t find it surprising that Lloyd’s is in this space,” said Johnson, adding that to his mind the challenge for everybody is figuring out how to structure these policies so that they are actually protective. “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
The most profitable policy for a private insurance company is one with the most expensive premiums that they never have to pay a claim on. They have no inherent incentive to take care of people who lost funds. It's "cheaper" to take the reputational hit and fight the claim in court. The more money at stake, the more the insurance provider is incentivized to avoid payout. They're not going to insure the assets unless they have reasonable certainty to make a profit by doing so, and they're not going to pay out a massive sum unless it's legally forced. Private insurance is always structured to be maximally profitable to the insurance provider.
The circumvention of multi-sig was a key factor in the massive Bitfinex hack of over $60m of bitcoin, which today still sits being slowly used and is worth over $3b. While Bitfinex used a qualified custodian Bitgo, which was and still is active and one of the industry leaders of custodians, and they set up 2 of 3 multi-sig wallets, the entire system was routed through Bitfinex, such that Bitfinex customers could initiate the withdrawals in a "hot" fashion. This feature was also a hit with the hacker. The multi-sig was fully circumvented.
Bitpay in 2015 was another example of a breach that stole 5,000 bitcoins. This happened not through the exploit of any system in Bitpay, but because the CEO of a company they worked with got their computer hacked and the hackers were able to request multiple bitcoin purchases, which Bitpay honoured because they came from the customer's computer legitimately. Impersonation is a very common tactic used by fraudsters, and methods get more extreme all the time.
A notable case in Canada was the Canadian Bitcoins exploit. Funds were stored on a server in a Rogers Data Center, and the attendee was successfully convinced to reboot the server "in safe mode" with a simple phone call, thus bypassing the extensive security and enabling the theft.
The very nature of custodians circumvents multi-sig. This is because custodians are not just having to secure the assets against some sort of physical breach but against any form of social engineering, modification of orders, fraudulent withdrawal attempts, etc... If the security practices of signatories in a multi-sig arrangement are such that the breach risk of one signatory is 1 in 100, the requirement of 3 independent signatures makes the risk of theft 1 in 1,000,000. Since hackers tend to exploit the weakest link, a comparable custodian has to make the entry and exit points of their platform 10,000 times more secure than one of those signatories to provide equivalent protection. And if the signatories beef up their security by only 10x, the risk is now 1 in 1,000,000,000. The custodian has to be 1,000,000 times more secure. The larger and more complex a system is, the more potential vulnerabilities exist in it, and the fewer people can understand how the system works when performing upgrades. Even if a system is completely secure today, one has to also consider how that system might evolve over time or work with different members.
By contrast, offline multi-signature solutions have an extremely solid record, and in the entire history of cryptocurrency exchange incidents which I've studied (listed here), there has only been one incident (796 exchange in 2015) involving an offline multi-signature wallet. It happened because the customer's bitcoin address was modified by hackers, and the amount that was stolen ($230k) was immediately covered by the exchange operators. Basically, the platform operators were tricked into sending a legitimate withdrawal request to the wrong address because hackers exploited their platform to change that address. Such an issue would not be prevented in any way by the use of a custodian, as that custodian has no oversight whatsoever to the exchange platform. It's practical for all exchange operators to test large withdrawal transactions as a general policy, regardless of what model is used, and general best practice is to diagnose and fix such an exploit as soon as it occurs.
False promises on the backing of funds played a huge role in the downfall of Quadriga, and it's been exposed over and over again (MyCoin, PlusToken, Bitsane, Bitmarket, EZBTC, IDAX). Even today, customers have extremely limited certainty on whether their funds in exchanges are actually being backed or how they're being backed. While this issue is not unique to cryptocurrency exchanges, the complexity of the technology and the lack of any regulation or standards makes problems more widespread, and there is no "central bank" to come to the rescue as in the 2008 financial crisis or during the great depression when "9,000 banks failed".
In addition to fraudulent operations, the industry is full of cases where operators have suffered breaches and not reported them. Most recently, Einstein was the largest case in Canada, where ongoing breaches and fraud were perpetrated against the platform for multiple years and nobody found out until the platform collapsed completely. While fraud and breaches suck to deal with, they suck even more when not dealt with. Lack of visibility played a role in the largest downfalls of Mt. Gox, Cryptsy, and Bitgrail. In some cases, platforms are alleged to have suffered a hack and keep operating without admitting it at all, such as CoinBene.
It surprises some to learn that a cryptographic solution has already existed since 2013, and gained widespread support in 2014 after Mt. Gox. Proof of Reserves is a full cryptographic proof that allows any customer using an exchange to have complete certainty that their crypto-assets are fully backed by the platform in real-time. This is accomplished by proving that assets exist on the blockchain, are spendable, and fully cover customer deposits. It does not prove safety of assets or backing of fiat assets.
If we didn't care about privacy at all, a platform could publish their wallet addresses, sign a partial transaction, and put the full list of customer information and balances out publicly. Customers can each check that they are on the list, that the balances are accurate, that the total adds up, and that it's backed and spendable on the blockchain. Platforms who exclude any customer take a risk because that customer can easily check and see they were excluded. So together with all customers checking, this forms a full proof of backing of all crypto assets.
However, obviously customers care about their private information being published. Therefore, a hash of the information can be provided instead. Hash is one-way encryption. The hash allows the customer to validate inclusion (by hashing their own known information), while anyone looking at the list of hashes cannot determine the private information of any other user. All other parts of the scheme remain fully intact. A model like this is in use on the exchange CoinFloor in the UK.
A Merkle tree can provide even greater privacy. Instead of a list of balances, the balances are arranged into a binary tree. A customer starts from their node, and works their way to the top of the tree. For example, they know they have 5 BTC, they plus 1 other customer hold 7 BTC, they plus 2-3 other customers hold 17 BTC, etc... until they reach the root where all the BTC are represented. Thus, there is no way to find the balances of other individual customers aside from one unidentified customer in this case.
Proposals such as this had the backing of leaders in the community including Nic Carter, Greg Maxwell, and Zak Wilcox. Substantial and significant effort started back in 2013, with massive popularity in 2014. But what became of that effort? Very little. Exchange operators continue to refuse to give visibility. Despite the fact this information can often be obtained through trivial blockchain analysis, no Canadian platform has ever provided any wallet addresses publicly. As described by the CEO of Newton "For us to implement some kind of realtime Proof of Reserves solution, which I'm not opposed to, it would have to ... Preserve our users' privacy, as well as our own. Some kind of zero-knowledge proof". Kraken describes here in more detail why they haven't implemented such a scheme. According to professor Eli Ben-Sasson, when he spoke with exchanges, none were interested in implementing Proof of Reserves.
And yet, Kraken's places their reasoning on a page called "Proof of Reserves". More recently, both BitBuy and ShakePay have released reports titled "Proof of Reserves and Security Audit". Both reports contain disclaimers against being audits. Both reports trust the customer list provided by the platform, leaving the open possibility that multiple large accounts could have been excluded from the process. Proof of Reserves is a blockchain validation where customers see the wallets on the blockchain. The report from Kraken is 5 years old, but they leave it described as though it was just done a few weeks ago. And look at what they expect customers to do for validation. When firms represent something being "Proof of Reserve" when it's not, this is like a farmer growing fruit with pesticides and selling it in a farmers market as organic produce - except that these are people's hard-earned life savings at risk here. Platforms are misrepresenting the level of visibility in place and deceiving the public by their misuse of this term. They haven't proven anything.
Fraud isn't a problem that is unique to cryptocurrency. Fraud happens all the time. Enron, WorldCom, Nortel, Bear Stearns, Wells Fargo, Moser Baer, Wirecard, Bre-X, and Nicola are just some of the cases where frauds became large enough to become a big deal (and there are so many countless others). These all happened on 100% reversible assets despite regulations being in place. In many of these cases, the problems happened due to the over-complexity of the financial instruments. For example, Enron had "complex financial statements [which] were confusing to shareholders and analysts", creating "off-balance-sheet vehicles, complex financing structures, and deals so bewildering that few people could understand them". In cryptocurrency, we are often combining complex financial products with complex technologies and verification processes. We are naïve if we think problems like this won't happen. It is awkward and uncomfortable for many people to admit that they don't know how something works. If we want "money of the people" to work, the solutions have to be simple enough that "the people" can understand them, not so confusing that financial professionals and technology experts struggle to use or understand them.
For those who question the extent to which an organization can fool their way into a security consultancy role, HB Gary should be a great example to look at. Prior to trying to out anonymous, HB Gary was being actively hired by multiple US government agencies and others in the private sector (with glowing testimonials). The published articles and hosted professional security conferences. One should also look at this list of data breaches from the past 2 years. Many of them are large corporations, government entities, and technology companies. These are the ones we know about. Undoubtedly, there are many more that we do not know about. If HB Gary hadn't been "outted" by anonymous, would we have known they were insecure? If the same breach had happened outside of the public spotlight, would it even have been reported? Or would HB Gary have just deleted the Twitter posts, brought their site back up, done a couple patches, and kept on operating as though nothing had happened?
In the case of Quadriga, the facts are clear. Despite past experience with platforms such as MapleChange in Canada and others around the world, no guidance or even the most basic of a framework was put in place by regulators. By not clarifying any sort of legal framework, regulators enabled a situation where a platform could be run by former criminal Mike Dhanini/Omar Patryn, and where funds could be held fully unchecked by one person. At the same time, the lack of regulation deterred legitimate entities from running competing platforms and Quadriga was granted a money services business license for multiple years of operation, which gave the firm the appearance of legitimacy. Regulators did little to protect Canadians despite Quadriga failing to file taxes from 2016 onward. The entire administrative team had resigned and this was public knowledge. Many people had suspicions of what was going on, including Ryan Mueller, who forwarded complaints to the authorities. These were ignored, giving Gerald Cotten the opportunity to escape without justice.
There are multiple issues with the SOC II model including the prohibitive cost (you have to find a third party accounting firm and the prices are not even listed publicly on any sites), the requirement of operating for a year (impossible for new platforms), and lack of any public visibility (SOC II are private reports that aren't shared outside the people in suits).
Securities frameworks are expensive. Sarbanes-Oxley is estimated to cost $5.1 million USD/yr for the average Fortune 500 company in the United States. Since "Fortune 500" represents the top 500 companies, that means well over $2.55 billion USD (~$3.4 billion CAD) is going to people in suits. Isn't the problem of trust and verification the exact problem that the blockchain is supposed to solve?
To use Quadriga as justification for why custodians or SOC II or other advanced schemes are needed for platforms is rather silly, when any framework or visibility at all, or even the most basic of storage policies, would have prevented the whole thing. It's just an embarrassment.
We are now seeing regulators take strong action. CoinSquare in Canada with multi-million dollar fines. BitMex from the US, criminal charges and arrests. OkEx, with full disregard of withdrawals and no communication. Who's next?
We have a unique window today where we can solve these problems, and not permanently destroy innovation with unreasonable expectations, but we need to act quickly. This is a unique historic time that will never come again.
How To End The Cryptocurrency Exchange "Wild West" Without Crippling Innovation
In case you haven't noticed the consultation paper, staff notice, and report on Quadriga, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.
Many of you have limited time to read the full proposal, so here are the highlights:
Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.
Regular Transparent Audits
Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.
Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
Background and Justifications
Cold Storage Custody/Management After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems: • Funds stored online or in a smart contract, • Access controlled by one person or one system, • 51% attacks (rare), • Funds sent to the wrong address (also rare), or • Some combination of the above. For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program. The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms. • 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective. • The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated. The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II. On The Subject of Third Party Custodians Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems. However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies. There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both. On The Subject Of Insurance ShakePay has taken the first steps into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC. However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example, the insurance agent refused because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange in South Korea, their insurance claim was denied, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.” ShakePay's insurance was only reported to cover their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance. In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework. A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians. On The Subject of Fractional Reserve There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds. There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past. Proof of Reserves/Transparency/Accountability Canadians need to have visibility into the backing on an ongoing basis. The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users. Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit. The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided. Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense. Hot Wallet Management The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets. However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process. A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage. Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
Current Draft Proposal
(1) Proper multi-signature cold wallet storage. (a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet. (b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time). (c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. (d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds. (e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers. (2) Regular and transparent solvency audits. (a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row. (b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored. (c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process. (d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify. (e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible. (3) Protections for hot wallets and transactions. (a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets. (b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy. (c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage. (d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange. (e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.
Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized. The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges. The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.
This is a compilation of everything suspicious I found with Quadriga. Please let me know if there’s anything incorrect or missing Early History (2013-2017)
QuadrigaCX started in 2013 and made history by being the first crypto exchange to register with FINTRAC and accept gold bullion deposits. By 2015, Quadriga became Canada’s largest crypto exchange. So far, so good.
In March 2015, Quadriga attempted to go public and a month later, announced its intention to install Bitcoin ATMs across Canada. Both these plans were eventually aborted.
Even though Quadriga never listed, it started selling its shares over-the-counter. In Sep 2015, Quadriga stopped publishing audits. In March 2016, Quadriga was banned from selling shares after the BCSC issued a cease trade order (CTO) for not submitting an audit.
Around the same time, 3 of Quadriga’s 5 directors (Anthony Milewski, Lovie Horner, Bill Filtness) and CFO (Natasha Tsai) all resigned. Sometime in 2016, Director and Co-founder Michael Patryn resigned. This left Gerald Cotten ("Gerry") as the only remaining director.
Evidence shows that Michael Patryn has used several aliases (including Omar Dhanani) and is a convicted identity thief
Quadriga has changed its business address several times. It started as a Vancouver-based exchange, with its addresses changing from Commercial Dr, Nelson St, and Homer St. Eventually, the address moved to Toronto. None of these were physical office addresses, but instead a mail forwarding address.
The Terms of Service on Quadriga’s website have always suspiciously stated that:
All account fundings are considered to be purchases of QuadrigaCX Bucks. These are units that are used for the purposes of purchasing Bitcoin or other cryptocurrencies. QuadrigaCX Bucks are NOT Canadian Dollars. Any notation of $, CAD, or USD refers to an equivalent unit in QuadrigaCX Bucks, which exist for the sole purpose of buying and selling Bitcoin and other cryptocurrencies. QuadrigaCX is NOT a financial institution, bank, credit union, trust, or deposit business. We DO NOT take Deposits. We exist solely for the purposes of buying and selling cryptocurrencies.
Banking troubles throughout 2018
In late Dec 2017, Jose Reyes (CEO of Billerfy and Costodian Inc, Quadriga’s payment processor) moved over a million dollars from Quadriga’s account and into his own personal CIBC account
Shortly after, CIBC froze these funds and tried reaching out to Gerry, who refused to speak with them
All throughout 2018, Quadriga’s fiat withdrawal times took 2-3 months to complete. Quadriga kept citing the CIBC freeze as the reason. What’s very suspicious is how Quadriga constantly lied to customers with promises such as “the withdrawal backlog will be cleared in 1 week” or “your funds have been processed” when in fact they were months away from doing so.
Period leading up to Gerry’s death
On Nov 27, Gerry filed his will just 12 days before his death. He left a plane, two houses, and $100,000 for the care of his two Chihuahuas.
Gerry had a plan for all his personal affairs in the event of his death but he had no contingency plan for $180M CAD of crypto in cold storage that only he had the private keys to?
India is a suspicious place to travel, considering Gerry had a medical condition and considering how easy it is to get a death certificate there
After a severe bear market, most crypto businesses have been struggling and laying off staff. It’s odd that Gerry, who has no history of philanthropy, chooses to donate money. Especially when his exchange is having so many banking troubles.
The organization that built the orphanage states on their website that they take care of all construction. There was zero need for Gerry to go to India
A reddit post shows that the orphanage exists, although it’s a mystery where the image came from
Bitcoin fell 50% in Nov – the worst monthly decline in 7 years. Gerry’s death occurred shortly after
Gerry’s death and announcement
On Dec 9, Gerry died in India “due to complications of Crohn’s disease.” However, there is a low probability that Crohn’s disease is fatal, especially at the young age of 30
Just a couple days later, a reddit post indicated someone bought 300 BTC on Quadriga at a 25% premium and moved the funds out of the exchange
It took Quadriga over a month to announce Gerry’s death on Jan 14th.
Over the following 2 weeks, Quadriga continued to assure customers that “our hot wallets are being filled and withdrawals are going slower but will complete.”
On Jan 28th, Quadriga takes down their website. Initially they said “an upgrade is being performed,” then the message changed to “site maintenance” before being changed to “Quadriga has filed for creditor protection” on Jan 31st.
In the media, Gerry stated several times that Quadriga uses multi-sig cold storage. This is where 2/3 or 3/5 people can be used to authorize a transaction. Clearly no multisig was used if only Gerry had the private keys.
Formal Active Investigations
A preliminary court hearing was held on Feb 5, 2019 where the Canadian Apex Court appointed Ernst and Young (EY) as Monitor to further investigate into the matter. EY has stated that its an extraordinary challenge to decipher Quadriga's finances, as the company has no accounting records (and did not systematically track incoming and outgoing payments) nor a bank account in its name.
The Better Business Bureau (BBB), which gives Quadriga an F-rating, launched an investigation in Dec 2018
Quadriga has substantial personal information on its customers, including SIN, driver's license, and banking details. Given Quadriga's murky history, customers may have their identity at risk and should setup up credit report and identity theft alerts with either Equifax or TransUnion.
Buying Ether in Canada, my experience with different exchanges
Hello, I'm writing about my experiences buying ethereum in Canada, essentially converting CAD to ETH. The goal is to help beginners that are interested in getting started but don't know where to actually buy ether. There's a lot of info out there but most of it seems to be centered around USD, which doesn't always translate for CAD and our banking system. I'm by no means an expert but I figured someone might find this information helpful. I've verified and used the following sites, so I'll be writing about them:
If you just want the gist of it, a super-quick summary of what I found:
Coinbase: great if you just want to try things out. Fast to get ether, fast to verify, high fees.
QuadrigaCX: great if you're looking to get more seriously into cryptocurrency. Most deposit options, lower fees.
Kraken: great if you have a ton of money you want to transfer into cryptocurrency or if you want to play around with trading. Low fees, slow CAD deposit because wire transfer.
Coinsquare: Fees aren't bad, low volume though.
With every one of these sites, there's usually some form of verification. This involves taking a picture of some piece of government ID (usually passport or drivers license), as well as some sort of proof of address such as a utlity bill. Some sites require you to take a selfie with some of that documentation or holding a handwritten sign. It seemed sketchy to me at first, but every place does it. Coinbase This was the first place I tried. Their only payment methods I could find are Visa and MasterCard, of which they charge a 3.75% convenience. With reward cards you might get 1%-2% back, but this is a fairly high fee. The bright side is it's just about instantaneous. One thing I noticed is that their sell price is about ~$5 higher than a few exchanges. For example, as I write this, it's $119.23 on coinbase. On kraken it's 113.99 for a market order. There is a weekly $200 limit on the amount to buy. A 30 day countdown started after I spent $500 to increase the limit. I can't find what the new limit amount will be once that countdown reaches 0 though. So far, I've been with them for over a month and I've bought $600 worth of ether. The first time I bought it only took a minute to get sent to my private address. The second time it took ~40 minutes for it to actually get sent to my private ether address, but this was due to some issues they were having, probably just a fluke. I've bought two more times since then and both times it was instant. To summarize Pros:
Fast to verify, took a couple minutes, seemed to be completely automated
Almost instantly sent funds via Visa/Mastercard
Instantly got the ether I bought
Probably the easiest to use
Generally $5 over Kraken prices
High fees at 3.75%. Might be able to brought lower with a good rewards card
Low $200 weekly limit
QuadrigaCX Hoping to get lower fees, this was the second place I tried. They accept a lot more payments with a variety of fees, I'll list them out:
Electronic Funds Transfer
Min $250, Max $10,000
5 Business Days
Min $500, Max $5,000
Next Business Day
2% + $5
Min $50, Max $2,000
Instant (but may be held 24 hours by security)
1.5% (min. $5)
Min $100,000, Max $500,000
2-4 Business Days
Min $500, Max $500,000
Electronic Funds Transfer replaced their "direct bank transfer" option, and while I think it's great since I think every bank supports it, it unfortunately has a rather high fee at 5%. I don't really see why you would use this though, if you can use Interac Online, it's faster. If you need the higher daily limit, a bank wire would be cheaper too. Interac e-Transfer I'd go with this if your bank doesn't support Interac Online and if you don't mind the 2% fee. If you're doing a large amount, the Bank Wire would be a better choice, depending on how much your bank charges you. Interac Online seems like the best choice for less than $2000. Unfortunately even though my bank card says "Interac" on it, and the bank is listed as supported, I can't use it for Interac Online because the card is both a debit and visa card. I've read that RBC and BMO are the only banks that support this, so it may be worth signing up with them. Bank Wire ended up being what I used (EDIT: back then the minimum for a wire transfer was $500). I wanted to deposit a larger sum, so just paying my bank for the cost of the transfer ended up being worthwhile (about 0.5% fee). The downside is I had to go in person to a branch to send a wire transfer and it's only really worthwhile for larger transfers. Crypto Capital seems like a 3rd party that you can wire to and then transfer that to QuadrigaCX. I don't see the appeal in using this to fund an account since you can just wire to QuadrigaCX directly. I sent the wire transfer a few days ago, and it seems like it will take 3-5 business days for it to complete. I'll update this post if the money somehow just disappears. Wire transfer came through today, no problems :) Once you do get CAD on QuadrigaCX, the fees to buy Ether are 0.5%. Combined with my wire transfer cost, I expect to only have paid a total of 1% in fees. To summarize Pros:
Fast to verify, I was able to verify the same day I made my account
Lots of variety in funding choices
Lower fees compared to coinbase
High daily fund limits
Not as many deposit options if they don't support your bank
0.5% per completed trade is a little high compared to other exchanges
Some transfer options have higher fees than coinbase for low amounts
Some transfer options can take up to 5 days
Kraken The latest site I've tried, they have multiple tiers of verification. You can't deposit CAD until you reach tier 3 verification, which can take up to 48 hours. Tier 1 and tier 2 were verified within the hour but tier 3 was still not verified 3 days later. When I submitted a support ticket, they were very quick to respond the next day and told me I needed to submit a Confirmation ID. Their site listed the Confirmation ID for a few countries and some criteria but it didn't seem like Canada applied to any of the criteria. Regardless, I submitted the Confirmation ID and was verified with tier 3 that same day. The only way to deposit CAD with Kraken is through wire transfer and it seems like there's some unlisted fees based on what their banks charge them to receive a wire transfer (as well as any intermediary bank). I have not done this so I cannot tell what the costs would be. Once you do have CAD on their exchange, their fees are better than QuadrigaCX with a MakeTaker rate at 0.16%/0.26%. I have sent ether to Kraken just for playing around with trading and I've had no problems. To summarize Pros:
Low trading fees
Potentially lower CAD->ETH fee than QuadrigaCX, depending on if there are wire transfer hidden costs. Lower trading fee helps
High fund limits
Only one way to deposit CAD and it's slow
Unclear what the wire transfer costs are
Little confusing verification process for tier3
Min $100, Max $2,000
Instant (withheld for 3 days)
Min $100, Max $3,000
1-3 days (withheld 0-7 days)
Min $20, Max $500
Min $1000, Max $9,000
0-2 days (withheld 0-5 days)
Min $100, Max $1,000
0-2 days (withheld 0-5 days)
Min $10,000, Max $300,000
0-1 day (withheld 0-2 days)
They have this concept of withholding funds, where you basically have to keep the money on the account. You can trade with it as much as you want, but you won't be able to withdraw until after the withholding time. Pros:
Lowish trading fees
Some options are fast to fund
Reasonable fund limits
The direct way to go from CAD->ETH has higher trading fees. Have to go CAD->BTC and then BTC->ETH.
Horrible interface. Until they fix their site, some stuff is broken (unless it works in other browsers?), or if you know how to edit html. Wow! They really fixed their site and it looks great now! Only thing that bothers me is in the advanced section, it lists the CAD/BTC price in terms of bitcoin. So instead of saying $3400/bitcoin, it says 0.00029378BTC
Fairly high withdraw fees (unfortunately I can't find them listed on their site, and I can't find it listed anywhere, but some people have reported it being far too high)
Alternatives There are of course other sites to get ether, and there's always the option of getting bitcoin and exchanging it through an exchange like Kraken or Poloniex for ether. There are bitcoin ATMs scattered around as well, but I can't comment on any fees involved or how close they match exchange prices. Other sites I checked out:
Local Bitcoins - It looks like I'd have to find another user to trade with and prices seem far higher than the exchanges.
Poloniex - Doesn't look like you can deposit CAD.
Gemini - Don't see a way to deposit CAD. Also sent verification 2 days ago and have not been verified.
Bitfinex - Can't wire transfer USD out at this moment and I don't see a way to deposit CAD.
Coinswitch - Can't deposit CAD.
GDAX - Can't deposit CAD.
CEX.IO - Price quotes are signficantly higher than other exchanges, and it looks like it only does USD. Right now, their site says you can buy 1 ETH as $289.25 USD, compare that to GDAX which has them trading at $259.98 USD. You can sell on it too, but again, the price isn't favorable, sell on it for $250 USD vs selling on GDAX for $260 USD.
QuickBT - Only small amounts of ETH, and fees seem to range between 5-9% depending on how much you buy. Only supports interac online and flexepin.
Alt Coins The main sites for getting CAD into the cryptocurrency space like QuadrigaCX, Coinbase, Kraken, and Coinsquare don't have a lot of altcoins. Fortunately once you have ether you can send it to another exchange and trade that for altcoins. These are my favourite ones:
Bittrex - You can't buy ETH with CAD directly, but it has a lot of other cryptocurrencies. I used this until Binance came out. They closed accounts for people unverified or from some countries, so I'd be wary about using it.
Binance - You also can't buy ETH with CAD directly on this one, but it's my favourite for getting into other cryptocurrency coins. Fees are also lower than bittrex if you hold their BNB coin and they add new coins much faster. Referral | Non-Referral
Kucoin - Registration on Binance/Bittrex has been up and down lately and I've had success using this exchange. They seem to add coins even faster than Binance, but the site is a little bit slower and less polished. Still functional and good to pickup a few alts that you can't get elsewhere. Referral | Non-referral
Funnily enough, this whole experience has made me appreciate the flexibility cryptocurrency like ether has and served as a reminder to how slow and cumbersome transactions become once the banking system is involved. EDIT: received wire transfer through QuadrigaCX, made account with coinsquare. EDIT2: added coinsquare section EDIT3: updated QuadrigaCX and coinsquare section, updated alternatives list EDIT4: Added e-transfer for QuadrigaCX! EDIT5: Cleaned up alt coins section.
Want to relay my recent experience to help other canucks entering the cryptocurrency scene. I wanted to invest 100K in both main coins and some alt coins. Depositing that amount can’t be done using ETF/bank-transfeetc. – the only reasonably quick way is to wire funds. For wires, most exchanges have a percentage based deposit fee – something that makes absolutely no sense to me. Whether you wire 1K or 1MM, the amount of work for the exchange is identical, so it should be a flat fee. Deciding on an exchange is more complicated than that though: each one has their own rules for minimums/maximums, trading fees, supported coins, holding periods, and withdrawal fees. They also can vary greatly on the amount of time verification takes. One thing to note is that pretty much all exchanges don’t charge a fee for inbound crypto transfers. 2 months ago I signed up for 10 exchanges (Coinbase/GDAX, Binance, Coinsquare, Kraken, ezBTC, QuadrigaCX, Bitfinex, Gemeni, Bittrex, Poloniex) and was verified on 7 of them (I’m still in queue for Gemeni, Bittrex, and Poloniex). Verification times gave me what I thought was a decent indicator of the level and quality of support I would receive. Of these exchanges, some have what I believe to be relatively high trading fees (Gemeni .25%, Bittrex, .25%, ezBTC .30%, QuadrigaCX .50%) vs lower maketaker fees (GDAX 0/.3%, Binance .1/.1%, Gitfinex .1/.2%, Coinsquare .1/.2%, Kraken .16/.26%). Still others have high percentage based wire fees. And finally, there’s a big disparity between withdrawal fees: free on some exchanes, vs fixed rate based on the coin for others, vs Coinsquare’s insane fixed 0.0025 BTC regardless of what coin or the amount being withdrawn. So here are some observations on the exchanges. Please note that the below is not a reflection on any of the people who work at the exchanges. I’m sure they are working as hard as they can and are doing their best. It’s just my experience. It’s also not financial advice. Also, I’m only human so feel free to offer corrections or better advice. Coinsquare: amazingly fast verification time, and for very large deposits seems to likely be the best option as they will let you speak to a human being by phone and will waive the deposit fee (I didn’t know this until later though). I excluded them because of their high 0.5% percentage based deposit fee and their crazy high withdrawal fee. They also only have support for 6 coins. QuadrigaCX: I had a terrible initial experience with QuadrigaCX’s support, so I immediately excluded them. They have high trading fees and there are many complaints of support tickets being ignored or having extremely lengthy wait times. They have a crazy high 1% percentage based CAD wire fee, but offer free USD wires. Note that they only support wires for large amounts. GDAX/Coinbase: Loads of good reviews, but only has support for 4 coins. Seems like they also don’t have a fee for crypto withdrawals. You also can’t seem to wire CAD or USD funds directly to GDAX. I think you may have to wire USD funds to Coinbase and then transfer them over to GDAX (for free). Kraken: I created an account but the verification page just appeared blank for me. After a few days, their support team got back to me telling me that they had a bug and that I needed to create a new account using a different email address and try again. That worked. I decided to use them as they seemed like the best all-around alternative. I was impressed with their support response (they gave me an answer that worked and responded in days as opposed to weeks), they offer a no-fee inbound CAD wire, support 16 coins, and have low (though not free) crypto withdrawal fees. They have also been around a while and have a good reputation (They were picked to handle MtGox claims). Wiring funds to them was a hair-raising experience though. You basically need to send your funds to an unknown bank in Tokyo, Japan. Kraken also has two slightly different sets of wire instructions: one that is on their website, and the other that their support folks send out. Only one of them mentions that you should tell your bank not to use an intermediary that will convert your currency. If you do things properly, and are lucky, you end up only paying ~$40 in fees. But chances are, you don’t, and end up paying 4%! (see https://www.reddit.com/BitcoinCA/comments/7rd6k8/fees_when_sending_to_krakencom/). You also have no idea how much the fees will be until the money finally shows up in your account. That’s tremendously unsettling. Luckily my bank branch manager was familiar with crypto currency wires and helped me do things properly. But, the wire took over 2 weeks to show up (Jan 18th), and Kraken support is so overloaded that they didn’t’ respond, despite me escalating my support ticket several times. I eventually had to resort to a reddit post to get a response to my support ticket. I gave support my wire receipt and answered lots of additional questions to help them try to “locate” it. Perhaps the worst part of my entire experience was that while my wire was being located, the entire crypto market tanked by 50%...and no one would respond to my support ticket…I felt helpless. A Kraken support rep a few days ago said that they are handing >50K new user registrations per day and have >20K new support tickets per day. I feel they should turn off new user registrations until they are capable of servicing existing customers. This is what their competitors have done. I found it disheartening to learn that the only way to get a response to my support ticket was to complain via social media --- many others have found the same. While I was waiting for my wire to appear Kraken had a >48h outage. Prior to the outage, the site was almost unusable as you’d receive constant 50x errors (I found this out prior to wiring my funds). After the outage, I find that their site is still barely usable. Pages take 10-15 seconds to load and when they do load many times they display errors so you have to continually retry until things work. At the end of the day though, they did come through for me: my wire arrived safely. So with my funds in Kraken, I tried to use them to purchase crypto. But no matter what I tried, none of the CAD dollar trading pairs would appear. I logged out and back in a few times and 15 minutes later, it suddenly started appearing. With the flakiness in Kraken’s platform, I had no choice but to transfer everything to a more stable and faster exchange: Binance: These guys have their shit in order. Super simple site navigation once you get used to it, fast verification times, blazingly fast website and trading engine, more than 50 coins supported, etc. But, they don’t support fiat – you must use one of the other exchanges to buy crypto with fiat and then transfer in your crypto. Gotta say it again: everything is super fast. Not just the page loads, but also trading, email confirmations, and withdrawals. Trading takes a bit of getting used to as you aren’t really buying or selling crypto…you are instead “trading” one crypto coin for another. Depending on the coin you want to purchase, you might have to trade your coin for BNB (binance’s own coin) and then trade BNB for the coin you desire. Be Your Own Bank: One final word of advice. Binance is awesome, but don’t trust anyone as despite everyone’s best intentions: no matter how secure a platform is, it can and will be hacked. As soon as you have done your shopping, transfer your coins off to your own wallet. This is why withdrawal fees are important. You might be asking: in hindsight, if I had to do it all over again, what would I do differently? To wire CAD funds I would try to use Coinsquare if it’s a big amount (after re-reading other people’s recent reviews). For USD wires, I might try using Gemeni, but I still haven’t been verified by them and have been waiting for almost 2 months. Before using either I would re-test how long it takes for a support ticket to be responded to. If you do wire funds, don't wire an exact round amount like "10,000.00", instead I would wire "10,070.45" so that it's easier to locate if things go wrong. Once the account has been funded I wouldn’t hesitate to transfer everything to another exchange if I wasn’t happy with the platform, the number of coin offerings, or quality of service I was receiving: you can always come back when things improve. Things change so quickly so not sure how helpful this will be…just wished I had known some of the above before starting.
Shining some light on RCN's recent growth and it's future
Hi, I found a coin that not many people talk about here so I would like to get some thoughts. It's getting more exposure on 4chan but there has been maybe 2 threads about it here. Since the price increased of 30% today I felt that I should give some more information. This is a copy and paste of some information that is circulated around 4chan about this coin. Market cap= 67 Million. What problem it solves: A global peer-to-peer credit network based on co-signed smart contracts. With RCN you aren't limited to just borrowing crypto (btc,eth etc) you can borrow any currency in the world. (USD,CAD,YEN) The RCN team has over 15 developers and genius advisors such as Sergio Lerner the cofounder of rootstock. Key investors= Bilionaire Tim Draper; The guy that found skype in 2005 and sold his share for 1 billion USD recently, the guy that bought 30,000 bitcoin from the us goverment during the silk road closure. Bilioniare Lu Guanqiu ceo of the company Fenbushi Capital;Once called “China’s Elon Musk” for buying out an American hybrid-electric car company, Lu Guanqiu is the founder of Wanxiang Group, one of China’s largest automotive parts manufacturers. ^ These guys do not fuck around google there history. This coin was added on bittrex A WEEK AFTER being released. Name one coin recently that was added to bitterx instnatly? This coin is serious... do you think these billionaires would invest in this coin if it wasn't going to literally 50x? Follow the smart money /biz/ It literally is around ICO price. The ICO pre-sale had NO BONUSES. Do some googling please. But even if there were, what does Tim Draper have to gain from making 10% on 10 Million? When you're in the billions you're only concerned with making 100s of millions. Thats why they invest in ICO and HOLD. Maybe he'll dump some when its 3-400M market cap, probably not till its nearing a billion (est. Q1 2019) or more. In developing countries such as in South America, it has been reported that up to 65% of the population are Unbanked and may have no access to Credit Facilities through traditional banking. Ripio intends to solve these problem by providing these users with an alternative Credit Facility. The Ripio Credit Network works to connect borrowers, lenders, and other network agents all over the world, allowing each one of them to manage the credit in their local currencies, as long as they have Internet access. In developing countries such as in South America, it has been reported that up to 65% of the population are Unbanked and may have no access to Credit Facilities through traditional banking. Ripio intends to solve these problem by providing these users with an alternative Credit Facility. The Ripio Credit Network works to connect borrowers, lenders, and other network agents all over the world, allowing each one of them to manage the credit in their local currencies, as long as they have Internet access. How does it work? The Network will consist of a Borrower, Lender, Wallet Provider, and Credit Exchange. All of which will be connected through a Smart Contract. The flow of money is as below: Borrower <- Wallet Provider <- Smart Contract <- Credit Exchange <- Lender To illustrate: Let’s say Juan in Argentina wants to borrow $5,000. Lin, who is halfway around the world in Shanghai is willing to loan him the $5,000 + 10% Interest. Once the terms are agreed, Lin sends the money through the Credit Exchange in Fiat. The Credit Exchange uses that Fiat to purchase RCN Tokens to send it over to Juan’s Wallet Provider through a Smart Contract. Juan receives the RCN Tokens and converts it back to Fiat. When it is time to repay the loan, Juan returns $5,500 through the same Channel, by using RCN Tokens as a medium. The borrower receives Fiat after converting the RCN Tokens. All loans work on a Fiat basis between borrower and lender, by simply using RCN Tokens as a medium of exchange. What does this mean and how can we benefit from it? There are 2 main ways to benefit from the Ripio Credit Network ecosystem: If you are a lender, you can lend in Fiat and earn interest in Fiat. If you are a RCN token holder, you will become a liquidity provider to facilitate the P2P loans, and earn through the increase in value of RCN Tokens. What value does the RCN token holders have and why should the price increase? All RCN token holders will become liquidity providers. For any loan to go through, RCN tokens will need to be purchased from the Market to facilitate the transfers. The higher the number of transactions, the higher the demand for RCN, and thus the higher the Price of RCN tokens. Investment Proposition • The ONLY source of RCN Tokens at the moment are held by the public, as the Company’s tokens are locked for 1 year. • Ripio has an actual working product with 100k users, all 100k of whom will be migrated to the RCN Exchange next week! - http://rcn.exchange/ • Ripio themselves will be the first big lender, which means that they will go to the market and acquire the RCN tokens, generating demand. • As new credit exchanges and lenders join to the network there will be even more demand for the RCN token. • Top A-grade institutional investor such as Pantera Capital, Fenbushi (Vitalik Buterin's Fund), Tim Draper, Digital Currency Group, Medici Ventures, Huiyin Blockchain Ventures has invested in the company What exchanges have listed RCN? • Bittrex (despite extremely strict with listing recently) • Binance • Huobi Pro • More to follow.. My personal opinion: Being from a developing country myself, it is easy to underestimate the number of Unbanked people who have no access to Credit Facilities. Like it or not, Credit is an essential part of expansion and development in an Economy. As for the Company, what makes Ripio stand out is the creation of a true Utility for their token, whereby all parties in the ecosystem are incentivized to use it and will benefit from it’s increase in Price. As Vitalik Buterin would say, the Crypto-Economics of their Model is spot on. This is my personal opinion. As always, do your own research and feel free to leave any comments or questions. TLDR; • RCN Tokens are used as “gas” to facilitate P2P loans • RCN Tokens have to be bought from the open market • Ripio themselves will act as lenders and purchase RCN Tokens from market • RCN Exchange launching next week. 100k users migrating • The higher the number of transactions, the higher the demand, the higher the price of RCN Tokens For an in-depth review, you can read their whitepaper, which is available at https://ripiocredit.network/ The market for alternate finance gained popularity in recent years. A finding by Transparency Market Research suggests that “the opportunity in the global peer-to-peer market will be worth $897.85 billion by the year 2024, from $26.16 billion in 2015. The market is anticipated to rise at a whopping CAGR [Compound Annual Growth Rate] of 48.2% between 2016 and 2024.” While Research and Markets estimates the global P2P lending market to grow at a CAGR of 53.06% during the five year period between 2016 and 2020. Morgan Stanley in a report in 2015 predicted that such marketplace lending would command $150 billion to $490 billion globally by 2020. http://www.nasdaq.com/article/the-rise-of-peertopeer-p2p-lending-cm685513 Ripio's value is not based on a coin gimmick, the tech behind RCN is nothing special. Ripio's value comes from the fact that it has proven people going into an industry that is sure to rise and they will start making money in the near future, not 2-3 years from now, but NEXT year. By april their roadmap will be complete. So, what do you guys think?
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