MQCC offers suggestions to US Congressional Research Service respecting: a Peer-to-Peer Finance Ontology in relation to: Marketplace Lending: Fintech in Consumer and Small-Business Lending

David W. Perkins 

Analyst in Macroeconomic Policy (Macroeconomic Policy Analyst)

Congressional Research Service

Washington, District Of Columbia

dperkins@crs.loc.gov

Dear Mr. Perkins,

Thank you for your updated CRS Report named: Marketplace Lending: Fintech in Consumer and Small-Business Lending.

Thank you for also recognizing that "peer-to-peer" lending terminology is often applied in a misleading manner. 

Two suggestions to you for your next version of your report, if you don't mind:

1 - Regarding your Footnote 1:

Two notes on terminology: The term peer-to-peer lending was widely used during the early development of the industry. Marketplace lending includes peer-to-peer lending but also refers to a wider range of lending activity. Peer-to peer lending involves selling loans to individual people [ NOT NECESSARILY CORRECT - the test is based upon who carries the primary burden of compliance, which is the "lender" not the "borrower; indeed, the term ("peer to peer lending") itself defines the primary process, namely, lending.  For example, a typical peer-to-peer transaction is not defined by the borrower, it is the classification of "lender" that matters. Individuals (or privately held corporations) who lend their own private equity funds have the least regulatory compliance requirements of all classes of "lenders". AN ONTOLOGY-CORRECT phrase would be: "Peer-to-Peer lending involves private individuals who use their own private equity capital to invest in secured or unsecured lending opportunities to applicants (individual and non-individual) who seek to borrow funds." ] and used to be a very prevalent business model in the industry. However, large institutional investors and hedge funds play an increasingly prominent role in funding marketplace loans, making the term peer misleading. 

2 - Regarding your Figure 1:

"Examples of Marketplace Lender Business Models" does not appear to be formed from ontologically sound, process-based assessment of the "actual or ostensible business activity". For example, "Direct Lending" is a term synonymous with "Peer-to-Peer" lending where the applicant interacts directly with the lender. Indirect Lending is typical of "pooled funds" (ie: institutional investors) who seek to enter into a lending transaction by the applicant does not interact directly with the lender.

Finally, "who am I?" and "why should you consider my suggestions?"

My name is Anoop Bungay and you will discover that your's truly developed the world's first Crypto-/Peer-to-Peer (P2P)/Private/Secret/Shadow financial system with both regulated and non-regulated components, continuously registered since May 9, 2008 (over a decade) to the USA NIST (National Institute of Standards and Technology) ANSI (American National Standards Institute) Risk-Based, Quality Management Systems standard: ISO 9001:2015 (and it's predecessor standards; ISO 9001:2008 and ISO 9001:2000). The Crypto-/Peer-to-Peer (P2P)/Private/Secret/Shadow financial network (found at www.privatelender.org) was brought "online" on April 9, 2005 and was built on seminal BlockChain principles first identified when developing the peer-to-peer finance ontology. Indeed, Privatelender.org - a Canada-based website - is the first application of "BlockChain-in-finance", based systems and technology as described in a proprietary dissertation entitled: Binary Digit Debt: A Peer-to-Peer Electronic Finance System. The binary digit debt instrument (generically referred to as 'electronic debt"/e-debt/crypto-debt) is marketed globally pursuant to the Madrid Protocol as a US Patent and Trademark registered brand, namely "BITMORTGAGE®". The BITMORTGAGE® brand of peer-to-peer binary digit debt instrument predates, by over 4 years, the introduction of a binary digit currency (payment) system; genericized in name as as "bitcoin". 

In order to maintain over a decade of continuous registration to the USA NIST/ANSI National Standards, many years of primary research was invested in order to build an acceptable, sound ontology in the field of peer-to-peer (Crypto-/Private/Secret/Shadow) finance. As of today, the MQCC (the organization which now administers the global Crypto-/Peer-to-Peer (P2P)/Private/Secret/Shadow system) is the only platform that:

• is successfully harmonized peer-to-peer to financial activities to the National and International standard of 119 countries.
• is built on the world's first internationally recognized, defense standard, military/law enforcement-grade, turn-key, plug 'n play (PnP), end-to-end (E2E) "secure, risk-based meta-operating system" built on artificial algorithmic intelligent (AAI™) BlockChain principles; designed to assure statutory, regulatory and process conformity of a regulated organization (regulatee) within any industry sector.

Should you be interested in learning more, please visit www.mqcc.org. While peer-to-peer lending was our original business, MQCC spends most of it's time marketing to Governments, Legislators, Regulators and Regulatees in order to educate and implement systems and technology related to matters of supervisory tech and conformity science; a new field of study borne out of the discovery of the application of "BlockChain-in-finance" - see www.conformity.org to learn about conformity science.

Thank you for the opportunity to share the two suggestions with you, Mr. Perkins,

Your's truly,

/s/

Anoop Bungay

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If you have questions, please contact me at your convenience. In order to prevent errors and omissions, email is the preferred choice of communication. 

Thank you for choosing MortgageQuote Canada Corp., 'Proud sponsor of the Canadian dream.'®

Sincerely yours,

A. K. (Anoop) Bungay
President 

MQCC™

The First Name in Global Blockchain Conformity Systems & Technology™

Developer of BlockChain Zero One™

Education * Conformity* Finance

communication-policy.mortgagequote.ca

www.mqcc.org

"Welcome to the Future of Commerce: MQCC™"

FSCO #12279 - RECA - FICOMBC

An ISO 9001:2015 Registered Company

NOTICE - DISCLAIMER: 

For privacy, intellectual property or educational reasons, the above message is a variation of the original message sent to the recipients. The reader is cautioned to understand that the contents of this page may have  information added, removed, modified or otherwise differ in content from the original submission.

2018 Disclosure to the Canadian Cyber Incident Response Center's (CCIRC); MQCC® Cybersecurity: CYBERLOCKCHAIN™ brand

 

2018 Disclosure to Public Safety Canada, legally incorporated as the Department of Public Safety and Emergency Preparedness

2018 Disclosure to the Canadian Cyber Incident Response Center's (CCIRC)

2018 Disclosure to Scott Jones

---------- Forwarded message ---------

From: Anoop Bungay <underwriting@mortgagequote.ca>

Date: Sat, Oct 13, 2018 at 5:07 PM

Subject: Query Memo to Mr. Scott Jones, Head of CCIRC - Cyberincident Notice - In Fwd: REDACTED REDACTED - Canadian "Defined Hacking Event" - Fiduciary Officer & Board Notice - Fwd: [TICKET#2602517686]Abuse reporting concern for abuse@ovh.net

To: <ps.cyberincident-cyberincident.sp@canada.ca>, <contact@cyber.gc.ca>

Cc: Underwriting Team <underwriting@mortgagequote.ca>

Scott Jones

Head, 

Canadian Cyber Incident Response Centre (CCIRC) 

contact@cyber.gc.ca

ps.cyberincident-cyberincident.sp@canada.ca, 

Dear Mr. Jones,

My name is Anoop Bungay, President of MQCC; developer of the world's first "blockchain-based, military/defense-grade, meta-operating system, continuously registered to ISO 9001:2015 since May 9, 2008". MQCC is recognized by your peers in Federal Government and provincial correspondents, as the global leader in this area of expertise.

The below email thread will be of keen interest to you and your team because an American based defense contractor REDACTED. The reason that you will be interested is because of the nature of business that MQCC is involved with (as described in the opening sentence of this email to you). On an additional note, beyond our current military/defense-grade system and technology, MQCC is the only company in Canada that has developed a G7- "Eight Element Standard" Cybersecurity system, registered to Canada's National Quality Management Standard CAN/ISO 9002:16 and the international equivalent to 119 countries, ISO 9001:2015.

You will appreciate that I am "hoping" that the offending party will implement corrective action as necessary but in the event that corrective action is not implemented, could you please advise if your department is the "best" department to help me or should I be reaching out to the RCMP?

Thank you in advance for your help.

Anoop Bungay

2018 Disclosure to RCMP Technical Investigative Services: MQCC® Cybersecurity: CYBERLOCKCHAIN™ brand

 

2018 Disclosure to RCMP Technical Investigative Services

---------- Forwarded message ---------

From: Anoop Bungay <anoop.bungay@mqcc.org>

Date: Fri, Oct 19, 2018 at 10:57 AM

Subject: Re: MSG Fwd from Contact@cyber.gc.caFwd: Memo to Mr. Scott Jones - Fwd: REDACTED - REDACTED - Canadian "Defined Hacking Event" - Fiduciary Officer & Board Notice - Fwd: [TICKET#2602517686]Abuse reporting concern for abuse@ovh.net [REQ-9955]

To: <Contact@cyber.gc.ca>, <Gurinder.Dhanoa@rcmp-grc.gc.ca>

Cc: Underwriting Team <underwriting@mortgagequote.ca>

Thankyou Team CCCS.

Gurinder DHANOA 

Secretariat e-Crime

RCMP Technical Investigative Services

Gurinder.Dhanoa@rcmp-grc.gc.ca

Officer Dhanoa,

My name is Anoop Bungay and I am developer - among many things - Inventor of the world's first Military/Defense Grade, NIST Framework Core-Standard, Integrated Policies & Procedures (IPP™) Cybersecurity Core Blockchain System (MQCC IPP™ Cyberlockchain™) & Engineered Privacy Blockchain algorithm.  Both you and your colleagues at CCCS recognize the NIST standard pursuant to Public Safety Canada's endorsement of the NIST Framework.

Part 1 - Introduction: 

Over the past 12 years (and longer) MQCC has developed and implemented systems and technology for use by Governments, Regulators and Regulatees, in order to prevent nonconformity in a regulated process (commercial or non-commercial). Namely, MQCC is developer of the world's first internationally recognized, turn-key, plug 'n play (PnP), end-to-end (E2E) "secure, risk-based meta-operating system" built on blockchain principles; designed to assure statutory, regulatory and process conformity of a regulated organization (regulatee) within any industry sector (of which MQCC IPP™ Cyberlockchain is a component module). As of 2018, MQCC celebrates over 15 years of successful litigation-tested, regulatory recognized, continual operation. MQCC is a one-of-a-kind organization and given that most of the systems and technology was developed in Canada, the implications on a global scale are non-trivial.

MQCC also developed the world's first application of "blockchain"-in-finance, through development of the world's first cryptofinancial (binary digits) financial asset/debt instrument; trademark brand the "BITMORTGAGE®"; the BITMORTGAGE® was created and "brought on-line" at least four (4) years before the world was introduced to "binary digit currency", generically named the "BITCOIN". Indeed, the correct "dictionary definition" of the term "blockchain" - a "composite unitary word" - is based upon ontological, linguistic and lexicographic principles, first identified by your's truly in the early 2000's.

MQCC is a private company, based in Calgary, Alberta (Where D/Chief Sat Parhar (Canadian Association of Chief's of Police (CACP) Electronic (e)-Crime Committee Co-Chair actually or ostensibly resides)); and because MQCC's primary target market customers are Government, Regulators and Regulatees, MQCC is not commonly known by the general public.

Part 2 - Problem

REDACTED

Part 3 - Evidence - Email Thread

REDACTED

Part 4 - Conclusion

REDACTED 

Pursuant to the NIST Framework Core Standard, we are at the Function 4 stage of the Cybersecurity Framework Core, namely "RESPOND". Given the foregoing and the below evidence, after over 7 months of security continuous monitoring and observation (Function 3: "DETECT"), MQCC is at a point where we simply need help because our friendly requests to cease and desist are not being respected. You can imagine the scope and depth of intellectual property that MQCC has developed over the past decade and longer. It would be a real shame if another party was able to successfully hack into the MQCC systems (not only for our self respect but a successful hack would render the MQCC Cyberlockchain™ as "useless".) Finally, with your office's help, MQCC will be able to move onto Function 4: "RESPOND", then Function 5: "RECOVER".

Thank you in advance, Officer Dhanoa,

Your's truly,

/s/

Anoop Bungay

On Fri, Oct 19, 2018 at 7:40 AM Contact <Contact@cyber.gc.ca> wrote:

Classification: UNCLASSIFIED

 

Anoop Bungay,

 

Thank you for contacting the Canadian Centre for Cyber Security. For the situation described below, we would strongly encourage you to contact the RCMP to assess your complaint. A point of contact you may wish to reach out to is Gurinder Dhanoa (Gurinder.Dhanoa@rcmp-

 

ca). General contact details for the RCMP are provided on their website: http://www.rcmp-grc.gc.ca/cont/index-eng.htm.

 

Regards,

 

Assessment & Coordination | Évaluation et coordination

Contact Centre and Information Services | Centre d’appel et services d’information

Edward Drake Building | L’édifice Edward-Drake

contact@cyber.gc.ca | 613-991-7654

MQCC responds and introduces itself to the UK Financial Conduct Authority (FCA) and International Members of the Global Financial Innovation Network GFIN

Global Financial Innovation Network (GFIN) - Answers to Questions and Introduction to MQCC™ Global Sandbox designed for International Legislators, Regulators and Regulatees (www.globalsandbox.org)



Pursuant to a public request for input from the Global Financial Innovation Network, GFIN, MQCC has both introduced itself and responded to the ten (10) questions posed by GFIN leadership and members.

What is the Global Financial Innovation Network?

The Financial Conduct Authority (FCA) has, in collaboration with 11 financial regulators and related organisations, on 7 August 2018 announced the creation of the Global Financial Innovation Network (GFIN), building on the FCA’s proposal earlier this year to create a ‘global sandbox’. Source: UK Financial Conduct Authority.

GFIN Consultation Paper - Ten Questions:

Q1: Do you agree with the proposed Mission Statement for the GFIN?

Yes

Q2: Do you agree with the three main proposed functions for the GFIN? 

Yes

Q3: What aspects/areas of regulation pose the biggest challenge when it comes to innovating? 

Achieving trusted levels of harmonization and integration of disparate, distributed regulations and business methods.

Q4: Do you see any reasons why this initiative may be counterproductive to the outcomes it is seeking to achieve? 

A regulatory-recognized Global Sandbox is already created (www.globalsandbox.org); the Global Sandbox operating system and development environment is over 10 years old and the system is continuously registered to ISO 9001 since May 9, 2008; the International Quality Management Systems standard and National Standard-equivalent of 119 countries including the following members of the FCA-inspired Global Financial Innovation Network GFIN (see below). The MQCC Global Sandbox is built on advanced artificial intelligent algorithms and the principles of "BlockChain". The MQCC Global Sandbox is a litigation-tested, mature system and recognized by regulatory bodies in over 119 countries. The MQCC Global Sandbox is built to accommodate the World Trade Organization Technical Barriers to Trade (WTO TBT), Organization for Economic Co-operation and Development "Common Reporting Standards" (CRS); Group of Seven (G-7) "Eight Element Standard" Cybersecurity system. Finally, the MQCC meta-operating system that powers the MQCC Global Sandbox is a military/defense grade system because MQCC meets the military/defense standards for USA, Canada and UK Ministries of Defense standard requirements for "higher-level quality standards for complex and critical items".  This is a non-exhaustive list of regulatory and standards integrations invented, developed and marketed by MQCC, for the benefit of legislators, regulators and regulatees. Please visit www.mqcc.org to learn more.

GFIN Member Countries whose National Bodies are members of the MQCC Systems Registration Standard setting body, the International Organization for Standardization (ISO).

United Arab Emirates

Abu Dhabi Global Market (ADGM)

Contact: Chris Kiew Smith

chris.kiewsmith@adgm.com

Dubai Financial Services Authority (DFSA)

Contact: Elisabeth Wallace

ewallace@dfsa.ae

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is ESMA.

Canada

Autorité des marchés financiers (AMF)

(Québec, Canada)

Contact: Lise-Estelle Brault, Senior Director Derivatives

lise-estelle.brault@lautorite.qc.ca

514 395 0337

Ontario Securities Commission (OSC, Canada)

Contact: Pat Chaukos

osclaunchpad@osc.gov.on.ca

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is SCC.

Australia

Australian Securities & Investments

Commission (ASIC)

Contact: Cuihua Cartwright

cuihua.cartwright@asic.gov.au

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is SA. 

Bahrain

Central Bank of Bahrain (CBB)

Contact: yasmeen@cbb.gov.bh

Bureau of Consumer Financial Protection

(BCFP, USA)

Contact: Paul Watkins

officeofinnovation@cfpb.gov

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is BSMD. 

United Kingdom

Financial Conduct Authority (FCA, UK)

Contact: Paul Worthington

paul.worthington@fca.org.uk

Guernsey Financial Services Commission (GFSC)

15

Global Financial Innovation Network (GFIN)

Contact: Steve Chandler

innovate@gfsc.gg

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is BSI.  

Hong Kong/China

Hong Kong Monetary Authority (HKMA)

Contact: Henry Chang

FinTech@hkma.gov.hk

Correspondent member to ISO.org, the MQCC Systems Registration Standard setting body is ITCHKSAR.

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is SAC.

Singapore

Monetary Authority of Singapore (MAS)

Contact: Sopnendu Mohanty

FinTech_Office@mas.gov.sg

National Representative to ISO.org, the MQCC Systems Registration Standard setting body is ESG.

World Bank

Consultative Group to Assist the Poor (CGAP)

Contact: Ivo Jenik

ijenik@worldbank.org

The World Bank abd ISO.org, the MQCC Systems Registration Standard setting body, have a partnership pursuant to a MOU signed in 2016.

Pursuant to your question #6.1, below, there may be an opportunity for GFIN to collaborate with MQCC. Visit www.globalsandbox.uk or www.globalsandbox.org to learn more.

Q5: Do you believe the issue of developing a best practice for regulators when assessing financial innovation should be a priority for the network? 

Yes and concurrently, the network should seek a way to implement concurrent sandboxes so that regulatees (licensees) may engage in innovation "sooner rather than later".

Q5.1 If not, what other priorities should the network first address? 

see Q5 answer.

Q6: Do you agree with the approach to involve global standard setting bodies as part of the GFIN? 

Yes.

Q6.1 How else would you like to see these organisations involved? 

Private-Public Partnership (PPP), for example, GFIN and its members might consider a licensing arrangement or collaboration with the MQCC Global Sandbox; a proven, trusted, mature system which is over 10 years old, continuously registered to ISO 9001 for over a decade and is designed for the purposes that the GFIN was created.

Q7: What kind of outcomes from the policy work and regulatory trials would your organisation benefit from? 

Any outcome from GFIN would be integrated into the MQCC system and this would help the MQCC customers accelerate market entry.

Q8: Would the cross-border trials be of interest to your organisation? 

Yes.

Q8.1 If so, could you provide any potential example use cases?   

MQCC has over 15 years of international expertise in developing systems for the finance industry and regulatory sector that also enables cross-border trials of financial applications so the body of knowledge is expansive for this question and answer document. Some information may be found at www.globalsandbox.org.

Q9: Do you agree with the proposed approach to managing the application process for cross-border trials? 

Yes.

Q10: [For regulators] Do you anticipate any challenges with the proposed approach to managing the application process, or conducting crossborder trials?

MQCC regulates private, non-regulated (free-trading) financial securities within its own network. The whole purpose of creating the MQCC global sandbox was to streamline the process of helping MQCC fintech, regtech, supervisory tech, customers (including government and regulatory bodies) to eliminate process challenges and make cross-border trials efficient and regulatory-harmonized.

Finally, for those of your members who are too busy to visit the MQCC Global Sandbox, here is some information from page 1 of the MQCC.org website:

Welcome to the Future of Commerce™

MQCC™  is Global Network Administrator of the First Application of Blockchain-in-Finance, first developed by Bungay International Inc., serving the global community since at least before April 9, 2005.

Developer of the world's first internationally recognized, turn-key, plug 'n play (PnP), end-to-end (E2E) "secure, risk-based meta-operating system" built on BlockChain principles; designed to assure statutory, regulatory and process conformity of a regulated organization (regulatee) within any industry sector. Celebrating over 15 years of successful litigation-tested, regulatory recognized, continual operation.

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As of May 9,  2018 - the MQCC BlockChain™ System Celebrates 10 Years of Continuous Registration to the International and National Standard for Quality Management of 119 Countries.

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Since 2006, the MQCC™is the world's first and only Canada-based, international organization that helps federal and non-federal, government and non-government organizations; regional, national and international regulators; regulatees and regulatory exempt organizations to improve general public trust and reduce regulated and non-regulated industry risk, through development and implementation of conformity systems based upon BlockChain¹, "proof-of-work" technology [BlockChain Zero One™] - registered to meet both the rigorous 'National Standard of Canada' for Quality Management Systems, published by the CSA Group (Canadian Standards Association) and USA equivalent: 'American National Standard'  (ANS) for Quality Management Systems published by ANSI (American National Standards Institute). The Standard is recognized and trusted by Canadians,  USA residents and consumers in over 119 countries including UK & AU.

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Confirmed by the equivalent National Standards Bodies of 119 countries: according to the Standards Council of Canada (SCC), a Canadian federal Crown corporation which reports to Canadian Parliament through the Minister of Innovation, Science and Economic Development Canada: Standards help to ensure BETTER, SAFER and MORE EFFICIENT methods and products, and are an essential element of technology, innovation and trade.

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In accordance with the Government of Canada’s Cabinet Directive on Regulatory Management (and its equivalent in 119 countries), the National Standard of Canada for Quality Management is adopted from world-class international standards, namely, the quality management system standard ISO 9001, published by the International Organization for Standardization (ISO) [based in Switzerland], of which Canada is a founding member.

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The MQCC™: Celebrating 12 Years of Pioneering Advances in Recognized Certification & the MQCC™, Defense (Military) Standard, Litigation-Tested, Regulatory-Recognized, Regulator Audited, BlockChain Conformity Management Standard™ (BCMS™) Brand of 

• BlockChain Conformity Management System
• Pan-Industry, Higher-Order Artificial Intelligence (AI)BlockChain, Regulatory Harmonized & Secure, Risk-based Organization Conformity meta-Operating Systems
• BlockChain Systems, Technology, Products and Services
• Financial Products  
• Financial Services 
• Conformity Science Standards 

Developer of the MQCC (R)evolution™; the next level generation of Risk-Based, Statutory, Regulatory & Process (SRP)™Organization Conformity Operating Systems (MQCC RB-SRP™-OCOS™), built on seminal BlockChain technology developed by Anoop Bungay, Founder of MQCC™in the early 2000's (visit www.bitmortgage.org to see the cursory-level white paper introduction).

The world's first, safest and most trusted BlockChain operating system. MQCC: the standard by which all BlockChain algorithms are measured.

Developer of the world's first pan-jurisdiction (national and international)  harmonized regulatory BlockChain protocol.

Developer of the world's safest cryptofinancial system.

 Registered to the National Standard of 119 Countries. 

   

Thank you for the opportunity to share this with GFIN. Pursuant to your question Q.6.1 (How else would you like to see these organisations involved?); instead of "reinventing the wheel", if GFIN and it's members are keen on licensing opportunities or PPP (Private-Public Partnership) integration opportunities, MQCC is here for you.

Your's Truly,

/s/

Anoop Bungay

Founder, President; MQCC

Calgary, Canada