The period leading up to June 30 saw the usual raft of end of financial year updates, special offers and reminders from equipment suppliers, business service providers, accountants, tax specialists and even the ATO itself.
Crypto is certainly getting a lot of attention in Australia at the moment.
Third, the CPA published an op ed on the need for more clarity in crypto asset accounting. Not just in Australia, but across the world of International Financial Reporting Standards.
None of this should be surprising, as governments, regulators, tax authorities, professional bodies and institutional investors are still struggling to comprehend this new asset class, and the technology that underpins it.
Do crypto and digital assets represent currency, commodity, real estate, software license, network membership, utility access, payment mechanism, store of value, financial security, or unique property rights? Depending on the design, use case and origination of a token and its economic properties, the answer could be “yes” in each case – albeit not all at the same time.
In my consulting work with Brave New Coin, I get to speak to clients on a daily basis about their own crypto activities – be they exchanges, asset managers, accountants, tax authorities, regulators or investors. A lot of the discussion involves education – helping them to make sense of the technology and its potential. Some of the time they are simply asking our advice about how to address a particular issue, or they need a recommendation for a custodian or broker. A few share the regulatory challenges they face, and seek our perspective in how to navigate them. Others need more technical help, in building software solutions, or with on-chain analysis and wallet tracking (even though “free” block explorers already do a pretty good job in that regard). While many simply need a source of market data and indices for price discovery and NAV calculations, or a process to capture and track the crypto equivalents of corporate actions.
If anyone wonders how we are doing to make the reporting of crypto holdings as simple as equities or fixed income assets, my own experiences suggest we have a way to go. Legacy accounting and portfolio tools struggle with crypto: for example, can they calculate to 8 decimal places? how do they deal with an air drop? and how do they distinguish between Ether and Ethan Minerals (both use ETH as their ticker symbols), or Cardano and Adacel Technologies (both use ADA). And if I am an accountant, auditor, financial planner or adviser, how can I make sure I understand my clients’ portfolio of crypto investments, if I don’t have the appropriate tools?
Next week: Goya – allegories and reportage for the modern age
Blockchain Australia, the national industry body, recently organised the first National Australian Blockchain Week – a mix of on-line and in-person events, hosted in Sydney and Melbourne. Overall, it was an impressive line up of speakers and topics, featuring key local figures and presenting some intriguing announcements from politicians, regulators and practitioners alike.
The recurring themes were: Regulation, Tax and Innovation.
Despite past pronouncements about adopting a light-touch regulatory regime when it comes to Blockchain technology, the absence of definite regulation risks stifling innovation and/or driving projects overseas to more receptive jurisdictions. (Irony of the week #1: contrast this with the early and positive regulatory engagement with Digital Currency Exchanges (DCE) and other market participants in Australia, not to mention previous progress in removing the absurd GST treatment on the purchase and sale of cryptocurrencies).
Now, the industry is (once again) asking policy makers: to clarify the law as it relates to decentralised protocols, digital assets and utility tokens; to streamline the confusing and over-complex tax system as it applies to DeFi: and to define a specific regulatory boundary (rather like the UK’s FCA perimeter) within which crypto assets need to be regulated. Sadly, the latter is extremely hard to acheive thanks to the very broad definition of “financial product” within the Australian Corporations Act.
Throughout the four days, there were several highlights: Senator Bragg’s keynote speech on driving the policy agenda to bring clarity to regulators and markets alike; a progress report on the National Blockchain Roadmap; tax and legal updates from Joni Pirovich and Michael Bacina; a showcase of local Blockchain start-up projects (more on that next week); and a couple of enterprise presentations on the ASX’s DLT replacement for CHESS and the Blockchain-based insurance project between the R3 consortium and Grow Super. But apart from a couple of other Blockchain-in-business sessions, there was a noticeable absence of corporates, major banks, traditional financial services and institutional investors.
There was a lot of commentary around the fact that many Blockchain businesses and crypto projects still find it challenging to access regular banking facilities in Australia (Irony of the week #2: Westpac’s windfall from the recent Coinbase IPO). There was also a lot of discussion about the need for investor education before crypto and digital assets can go “mainstream” – which I find surprising when plenty of people seem to be finding their way without any help from traditional financial advisors, and yet no-one is required to educate themselves before their money is put into compulsory superannuation or real estate assets. Even where crypto assets are being included in retail investor products, the allocation is very modest and is being transacted offshore (see Raiz’s 5% allocation via the US-based Gemini Trust). Why not use one of the several established and well-run exchanges, crypto funds and OTC providers here in Australia?
Regarding the potential offshore brain drain, much was made of the work that Singapore is doing to attract Blockchain and crypto businesses. But I think the focus on Singapore risks overstating the situation there, and overlooks what is actually happening (and could happen) in Australia. For example, while Singapore may have more favourable tax arrangements for new Blockchain projects, I understand that ordinary retail investors don’t have access to crypto funds (not even ETPs). The Singaporean issuance of digital assets via tokenisation has to be done via an SPV structure. And while many ICOs have been issued from Singapore, they could not be marketed to local investors. At least Australia has a robust DCE sector, e.g. Independent Reserve, BTC Markets, and Bit Trade (now part of Kraken); early on we saw some very successful retail products such as CoinJar; and the local industry continues to nurture innovative decentralisation projects – we just need to sort out those “policy settings”, and give more encouragement to local entrpreneuers and innovation. (Irony of the week #3 – when former ALP politician and self-styled crypto OG, Sam Dastyari, was asked if the private equity fund he works for was investing in Blockchain or crypto, there was a deafening silence…)
Finally, one of the main benefits of Blockchain Week has been to entice people out of hibernation, and to attend in-person events after months of lock-downs and restricted movement. It felt good to be back.
Taking its cue from some of the economic effects of the current pandemic, the latest Startupbootcamp Melbourne FinTech virtual demo day adopted the theme of financial health and well-being. When reduced working hours and layoffs revealed that many that people did not have enough savings to last 6 weeks, let alone 6 months, lock-down and furlough have not only put a strain on public finances, they have also revealed the need for better education on personal finance and wealth management. Meanwhile, increased regulation and compliance obligations (especially in the areas of data privacy, cyber security and KYC) are adding huge operational costs for companies and financial institutions. And despite the restrictions and disruptions of lock-down, the latest cohort of startups in the Melbourne FinTech bootcamp managed to deliver some engaging presentations.
Datacy allows people to collect, manage and sell their online data easily and transparently, and gives businesses instant access to high quality and bespoke consumer datasets. They stress that the data used in their application is legally and ethically sourced. Their process is also designed to eliminate gaps and risks inherent in many current solutions, which are often manual, fragmented and unethical. At its heart is a Chrome or Firefox browser extension. Individual consumers can generate passive income from data sales, based on user-defined permissions. Businesses can create target data sets using various parameters. Datacy charges companies to access the end-user data, and also takes a 15% commission on every transaction via the plugin – some of which is distributed to end-users, but it wasn’t clear how that works. For example, is it distributed in equal proportions to everyone, or is it weighted by the “value” (however defined or calculated) of an individual’s data?
Harpocrates Solutions provides a simplified data privacy via a “compliance compliance as a service” model. Seeing itself as part of the “Trust Economy”, Harpocrates is making privacy implementations easier. It achieves this by monitoring and observing daily regulatory updates, and capturing the relevant changes. It then uses AI to manage a central repository, and to create and maintain tailored rules sets.
Mark Labs helps asset managers and institutional investors integrate environmental and social considerations into their portfolios. With increased investor interest in sustainability, portfolio managers are adopting ESG criteria in to their decision-making, and Mark Labs helps them in “optimising the impact” of their investments. There are currently an estimated $40 trillion of sustainable assets under management, but ESG portfolio management is data intensive, complex and still emerging both as an analytical skill and as a practical portfolio methodology. Mark Labs helps investors to curate, analyze and communicate data on their portfolio companies, drawing on multiple database sources, and aligning to UN Sustainable Development Goals. The founders estimate that there are $114 trillion of assets under management “at risk” if generational transfer and investor mandates shift towards more ESG criteria.
MassUp is a digital white label solution for the property and casualty insurance industry (P&C), designed to sell small item insurance at the consumer point-of-sale (POS). Describing their platform as a “plug and sell” solution, the founders noted that 70% of portable items are not covered by insurance policies, and many homes and/or contents are either uninsured or under-insured. MassUp is intended to simplify the process (“easy, accessible, online”), and will be launching in Australia under the Sorgenfrey brand in Q2 2021. For example, a product known as “The Flat Insurance” will cover items in and out of your home for a single monthly premium. As MassUp appears to be a tech solution, rather than a policy issuer, underwriter or re-insurer, I couldn’t see how they can achieve competitive policy rates both at scale and with simplicity (especially the claims process). Also, as we know, vendors love to “upsell” insurance on tech appliances, but many such policies have been seen to be redundant when considering existing statutory consumer rights and product warranties. On the other hand, short-term insurance policies (e.g., when I’m traveling, or on holiday, or renting out my home on AirBnB) are increasingly of interest to some consumers.
Ontrack provides B2B white label digital retirement planning solutions for financial institutions to help their customers in a more personalised way. There is a general consumer reluctance to pay for financial advice, but retirement planning is deemed too complicated. Taking an “holistic” approach, the founders claim to have developed a “best in class simulation engine” – founded on expected retirement spending priorities (rather than trying to predict the cost of living in 20 years’ time). Drawing on their industry experience, the founders stated that a key challenge for many financial planning providers is getting members comfortable with your service. I would also add that reducing complexity with cost-effective products is also key – and financial education forms a big part of the solution.
In Australia, the past 10 years has seen a major exit from the financial planning and wealth management industry – both at the individual adviser level (higher professional qualification requirements, increased compliance costs, and the end of trailing sales commissions in favour of “fee for advice”); and at the institutional level (3 of the big 4 banks have essentially withdrawn from offering financial planning and wealth management services). At the same time, there have been a number of new players – including many non-bank or non-financial institution providers – offering so-called robo-advice and “advice at scale”, mainly designed to reduce costs. In addition, the statutory superannuation regime keeps being tweaked so it is increasingly difficult to plan for the future, with the constant tax and other changes. Superannuation (a key success story of the Keating government) is just one of the “pillars” of personal finance in retirement: the others are the Commonwealth government aged pension (means-tested), personal wealth management (e.g., investments outside of superannuation); and retirement housing (with the expectation of more people opting to remain in their own homes). I would also include earnings from part-time employment while in “retirement”, as people work longer into older age (either from choice or necessity) – how that aligns with the aged pension and/or self-funded retirement is another part of the constantly-shifting tax and social security regime.
This product describes itself as a customer data platform that powers stored value, and was described as a “Safe harbour” solution (I’m not quite sure that’s what the founders meant in this context?). According to the pitch, consumers gain a fair and equitable outcome (consumer discounts), while retailers get targeted audiences. The team have created a vertically integrated gift card platform (working with MasterCard, Apple Pay and GooglePay), and launched JamJar, a cashback solution.
Similar to Harpocrates (above), RegRadar is a regulatory screening platform that helps companies “to set routes and avoid crashes”. The tool monitors regulatory changes (initially in the financial, food and healthcare sectors) and uses a pro-active process to developing a regulatory screening strategy, backed by analysis and a decision-support tool.
Having worked in legal, regulatory and compliance publishing for many years myself, I appreciate the challenge companies face when trying to keep up with the latest regulations, especially where they may be subject to multiple regulatory bodies within and across multiple jurisdictions. However, improved technology such as smart decision-support tools for building and maintaining rules-based business systems has helped enormously. In addition, most legislation is now online, so it can be searched more easily and monitored via automated alerts. Plus services such as Westlaw and Lexis-Nexis can also help companies track what is currently “good” or “bad” law by tracking court decisions, law reports and legislative updates.
Late last year, I had the privilege to be one of the judges for the PitchX competition for start-ups. The overall winner was Sola, a new investment platform to fund solar power using a virtual power plant structure to bring together investors and producers, who might not otherwise have access to the financial and production benefits of this renewable energy resource.
I had the opportunity to catch up with Alan Hunter, Founding Team member of Sola while he was in Melbourne earlier this month. He was busy in the middle of a series of investor meetings and finalising arrangements for their energy retailing licensing.
Prior to Sola, Alan had established a fleet company that leased cars to Uber drivers. Recognising that some immigrants lacked relevant qualifications for advertised jobs, but lacked the finance to buy a car, the business joined the dots and enabled many people with a driver’s license to secure employment. It told him a lot about about helping those less fortunate by building a business designed to remove inequalities and lower barriers to entry.
With that experience, an interest in renewable energy, and a desire to help consumers reduce their power bills Sola was launched. Starting out as CEC-approved Solar Retailer, Sola offers consumers a subscription service to electricity (at a cheaper rate than users pay today).
Sola is now planning to offer the same subscription service with a solar system, for a cheaper monthly payment. It is able to achieve this though the development of an innovative investment and infrastructure platform, that will serve three main types of clients:
1. Home-owners who want to install solar energy, reduce their own power bills, and even generate additional benefits as rebates or credits from feed-in tariffs
2. Retail investors, who may not have access to solar energy (renters, apartment residents, or those in dwellings ill-placed for panels)
3. Wholesale investors and self-managed superannuation funds looking for an alternative fixed income asset
In short, Sola underwrites the cost of panel installation on consumers’ homes. In return, Sola acquires 100% of the energy generated, and the customer subscribes to Sola for their monthly usage. Consumers become subscription members of Sola’s network, via the latter’s retailer license.
For retail investors, Sola will present them with an opportunity to access fractional ownership of a virtual power plant, for as little as $100. These investors then receive a dividend from the energy sales generated by the network.
For wholesale investors, and for a larger stake, they will be part of a closed end capped fund, which will generate a dividend from the energy sales. Sola has an energy off-take entitlement over the panels, and over time, panels which are replaced may still be sold into secondary markets, such as in developing countries, if they have a remaining useful life.
Some of the benefits of this structure include a more equitable arrangement for access to, ownership, and distribution of solar energy assets. It also removes the need for unsecured lending to finance panels and systems which may soon become obsolete. Plus, it enables people who might not have direct access to solar panels to benefit from this asset.
The complex issue of Federal and State rebates came up in our discussion. According to Alan, the former are useful in supporting the roll-out of Sola’s virtual power plant model, and in accessing the carbon credit marketplace via the Small-scale Technology Certificates (STC). Whereas, State rebates are better for end-users, who can engage Sola direct to install their panels, and then join the Sola retail network.
Then there is the issue of inverters, and batteries. It’s generally the former that are rendered obsolete before the panels, but the costs mean that customers tend to end up replacing the whole system. And the latter will not become economic until purchase costs reduce, and feed-in tariffs are phased out.
Finally, Alan wanted to make sure he got this point across – Sola will shortly be launching campaigns in seven locations, to sign-up 180-230 homes, in areas impacted by bush fires. The aim is to give participants a 35-40% saving on their energy bills, as well as establishing the first phase of the virtual power plant network.