Recently, the SEC published a proposed new regulation (the “Proposed Rule”) to amend the definition of an “exchange” for purposes of the Securities Exchange Act.1 Any person whose conduct meets the Proposed Rule’s new definition would be required to register as an exchange or apply for an exemption by registering as an Alternative Trading System (ATS).2 According to the Proposed Rule, the redefinition is intended to bring under SEC regulation certain traders in the Government Securities market. However, many observers have noted that the impact of the redefinition is over-broad in terms of its stated intent as it would extend the requirement to register as an Exchange or ATS to many business models previously outside its scope. The new definition is broad enough to cover both centralized and decentralized crypto exchanges3 . Simply put, the Proposed Rule extends the exchange registration requirement to any person or group that makes available a “Communications Protocol System” to conduct trades. Given the tension between the SEC and the crypto industry, it is no surprise that crypto exchanges and other players view this move with extraordinary skepticism. Some commentators have described the relationship as a game of cat and mouse. In light of many public statements regarding crypto and crypto exchanges by SEC representatives and the wide array of legal challenges facing the industry, concern regarding this Proposed Rule is merited and invites the question, “what laws and regulations currently apply to crypto exchanges?” Crypto-Exchanges & Securities Law There is no special body of law or regulations that govern crypto exchanges. However, provisions of existing regulatory regimes may apply to their activity. Determining which rules apply requires a look into the specific activity carried out by a crypto exchange. This effort should involve, at a minimum, a deep dive into at least the following inquiries regarding the transactions completed and the tokens, coins, or other assets sold on the crypto exchange: • Are they securities? Narrowing our focus to securities regulation, crypto exchanges must grapple with compliance involving two broad registration requirements. Broker-Dealer Registration Any person “engaged in the business of effecting transactions in securities for the account of others” or in the “business of buying and selling securities for his own account” is required to register as a broker or dealer, respectively, and to join an SRO (i.e., FINRA).5 In determining whether a person is “acting as a broker,” the SEC would look to whether the person regularly participates in securities transactions “at key points in the chain of distribution.”6 Activities that indicate a person may be acting as a “broker” include: (1) solicitation of investors to purchase securities; (2) involvement in negotiations between the issuer and investors; and (3) receipt of transaction based compensation.7 Transaction based compensation is the “hallmark” of broker-dealer activity.8 The SEC interprets brokerage activity broadly. For example, it deems many people who act as investment “finders” for issuers to engage in brokerage activity.9 Exchange or ATS Registration Online sites for trading in securities are generally required to register as broker-dealers and apply for authorization to operate an ATS. Persons that operate an ATS are exempt from the rule that only “exchanges” can provide facilities or a market place for trading in securities. Exchanges are defined by the Securities Exchange Act as “a market place or facilities for bringing together purchasers and sellers of securities or for otherwise performing with respect to securities the functions commonly performed by a stock exchange as that term is generally understood.”10 Exchange Act Rule 3b-16, which governs the ATS exemption from exchange registration further defines an “exchange” as any person or group that (1) brings together orders for securities of multiple buyers and sellers; and (2) uses established, non-discretionary methods (whether by providing a trading facility or by setting rules) under which such orders interact with each other, and the buyers and sellers entering such orders agree to the terms of a trade. An “order” is defined as a “firm indication of a willingness to buy or sell a security … including any bid or offer quotation, market order, limit order, or other priced order.”11 Systems not meeting this two-part test are not “exchanges” under the current definition.12 Do the Current Broker-Dealer and Exchange or ATS Registration Requirements Apply to a Crypto Exchange? Some companies operating crypto exchanges have maintained that they are not covered by the current definition of “exchange” and that they are not otherwise required to register as a broker-dealer. Several public comment letters to the Proposed Rule illustrate this.13 Their stated reasons include the following: o The tokens or other digital assets sold by the exchange are not “securities.” The SEC and the Courts have not conclusively weighed in on many of the above arguments specifically in connection with crypto exchanges. The Proposed Rule recognizes that at least some “Communications Protocol Systems” do not fall within the definition of exchange.14 However, several publications and statements of SEC personnel appear hostile to these arguments in connection with crypto exchanges. For instance, a 2017 investigate report addressing secondary market trading of unregistered “DAO” tokens noted that the DAO token was a security and that the platforms on which it traded should register as an exchange or a broker-dealer and ATS because they appeared to fit the definition of an exchange. In 2018, the SEC issued a statement on digital assets and trading, confirming its view that Exchange Act Rule 3b-16 contains a functional test and clarifying, “[n]otwithstanding how an entity may characterize itself or the particular activities or technology used to bring together buyers and sellers, a functional approach (taking into account the relevant facts and circumstances) will be applied when assessing whether a system constitutes an exchange.” Significantly, by referring to the definition of “exchange” in the ATS rules as a “functional test,” the SEC signaled that it will not take a formalistic view of trading systems designed to avoid being literally captured within the definition.15 Although the SEC has “granted no-action letter to operators of passive communications systems that assist in transactions but do not play a role in effecting transactions in securities,” it is noteworthy that these letters appear to have addressed systems used between, or to communicate with, registered broker-dealers.16 Additionally, SEC Chair, Gary Gensler, observed in last year that Coinbase lacked a license to operate as an exchange “even though they have dozens of tokens that might be securities.”17 He also opined that “with 50 of 100 tokens” there is only a remote probability that any given platform has zero tokens that are securities.18 Some assets are obviously securities, such as those that are attached to equity ownership or profits interests. Others may provide access to only a good or service (i.e., a utility token) or represent only a tradeable good. Determinatively, Bitcoin and Ethereum have been deemed to not constitute securities. Whether a cryptocurrency, token, or other digital assets is a security is determined by applying the analytic framework known as the Howey test.19 Many tokens traded on exchanges—even those labeled or thought of as “utility” tokens—qualify as “investment contract” securities. The SEC has offered a framework for analyzing whether digital assets are “investment contracts” based on the Howey test.20 Typically, if a token is intended to furnish access to a network that is not decentralized or fully functional and a purchaser of the token would expect the asset’s value to increase based on future efforts of a developer or operator, the token will be deemed a security. Consequently, even before considering the impact of the Proposed Rule, crypto exchanges should seriously consider taking action to register as a broker-dealer and as an ATS. To recap, this is because many crypto exchanges likely sell coins or tokens that are securities and because of the broad and functional views taken by the SEC in connection with the definitions of “exchange” and “broker.” Virtually any action as an intermediary in a securities transaction can lead to liability exposure for having violated the broker-dealer registration requirement. Although industry proponents may have plausible legal arguments that they are not a broker-dealer and that their trading system don’t meet the definition of an exchange, defending an enforcement action could be financially devastating for a crypto exchange. Further, participant or statutory underwriter liability could attach to the sale of unregistered securities by or on an exchange (this could depend on the proximity of the exchange and secondary trading to an issuer or an issuance) and could result in liability for violations of Section 5 of the Securities Act.21 The Proposed Rule’s Redefinition of Exchange & Impact The Proposed Rule would redefine exchange (and extend the registration requirement) to include any organization or group of persons that, by way of any “Communication Protocol Systems,” “brings together buyers and seller using trading interest … under which buyers and sellers can interact and agree to terms of the trade.” In addition, “trading interest,” in addition to “an order” is redefined to mean “any non-firm indication of a willingness to buy or sell a security that identifies at least the security and either quantity, direction (buy or sell), or price.”22 Several comments on the Proposed Rule from market participants have observed that it would have a devastating impact—both for the industry and holders of digital assets. They further comment that the Proposed Rule suffers from procedural defects as applied to the digital assets industry and does not comply with the Administrative Procedures Act.23 Others have opined that the SEC is without statutory authority to redefine exchange as broadly as proposed in the new rule. Among the challenges noted by industry participants is the difficulty of registering ATS platforms that trade in digital assets with the SEC and FINRA.24 Further, because of their decentralized nature, at least some decentralized crypto exchanges implemented by “Communications Protocol Systems” may not have any realistic possibility of registering as an ATS. As a result of these and other issues, crypto industry participants have voiced grave concerns and have signaled their willingness to defend future enforcement actions. Whether the SEC will proceed with the Proposed Rule as written or make modifications to accommodate the digitals assets industry remains to be seen. The public comment period on the Proposed Rule closed April 18, 2022, but the SEC recently reopened it until June 13, 2022. One thing is certain: the story on crypto exchanges and registrations has not been finally written. [1] Amendments Regarding the Definition of “Exchange” and “Alternative Trading Systems (ATSs) that Trade U.S. Treasury and Agency Securities, National Market System (NMS) Stocks, and Other Securities, 87 FR 15496, SEC Release No. 34-94062 (proposed March 18, 2022) (to be codified at 17 C.F.R. pts 232, 240, 242, and 249). Available at SEC: Proposed Rule. [2]Registering as an ATS is significantly less burdensome than registering as an exchange. [3] This term is used broadly here to mean any platform or facility for secondary exchanging of digital assets. [4] Commodities regulation is not addressed in this blog. [5] See Sections 3(a)(4)(A) and 3(a)(5)(A) of the Securities Exchange Act. [6] See SEC v StratoComm Corp., 2 F.Supp.3d 240, 253 (N.D.N.Y. 2014), aff’d 652 Fed.Appx. 35 (2d Cir. 2016) (citing Mass. Fin. Servs., Inc. v. Sec. Investor Prot. Corp., 411 F.Supp. 411, 415 (D.Mass.1976) aff’d, 545 F.2d 754 (1st Cir.1976)). [7] See Id. (citing SEC v. Gagnon, No. 10–cv–11891, 2012 WL 994892, at *11 (E.D.Mich. March 22, 2012); SEC v. Hansen, No. 83 Civ. 3692, 1984 WL 2413, at *10 (S.D.N.Y. Apr. 6, 1984)). [8] See SEC No-Action Letter, Brumberg, Mackey & Wall, P.L.C. (May 17, 2010). Available at: Letter: 5.17.2010 [9] See SEC Division of Trading and Markets, “Guide to Broker-Dealer Registration” (April 2018). [10] Section 3(a)(1), Securities Exchange Act. [11] Rule 3b-16(a), Securities Exchange Act. [12] Supra, note 1. [13] See the following Comment Letters in response to the Proposed Rule: Blockchain Association (April 18, 2022), available at: Blockchain Association Letter; Digital Asset Legal and Regulatory Alliance, Global Blockchain Convergence, Global Digital Asset and Cryptocurrency Association (April 14, 2022), available at: Digital Asset Legal and Regulatory Alliance Letter Digital Asset Legal and Regulatory Alliance Letter; Paul Grewal, Chief Legal Officer of Coinbase (April 18, 2022), available at: P. Grewal Letter (stating, “Coinbase does currently trade or facilitate trading in digital assets that are securities.”); LeXpunK (April 18, 2022), available at: LeXPunK Letter. [14] See Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DAO (Exchange Act Rel No. 81207) (July 25, 2017). [15] Id. [16] See SEC No-Action Letter (March 3, 2020) and Incoming Letter (March 4, 2020), Neptune Networks, Ltd., available at: Neptune Networks Ltd. and Incoming Letter [17] See Decrypt.co/news, Sep 14, 2021, SEC Chair: Coinbase Lists ‘Dozens of Tokens That Might Be Securities’ – Decrypt. [18] See Decrypt.co/news, Aug 3, 2021,SEC’s Gensler: Crypto Market Filled with Unregistered Securities, Prices ‘Open to Manipulation’ – Decrypt [19] SEC v. W. J. Howey Co., 328 U.S. 293 (1946). [20] See U.S Securities & Exchange Commission, Framework for “Investment Contract” Analysis of Digital Assets (April 3, 2019). [21] See SEC v. Chinese Consol. Benevolent Ass’n, Inc., 120 F.2d 738, 741 (2d Cir. 1941); Ackerberg v. Johnson, 892 F.2d 1328, 1336 (8th Cir. 1989). [22] Supra, note 1, SEC: Proposed Rule, pgs. 526 – 527. [23] See Comment Letter, Global Digital Asset & Cryptocurrency Association (April 18, 2022), available at: GDA & Crypto Association Letter. [24] Id. 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Seven of the world’s richest crypto founders have lost a combined $114 billion since November as digital-asset values crumble. Via https://duchonsigns.wordpress.com/2022/06/30/crypto-billionaire-fortunes-vanish-as-quickly-as-they-were-made%ef%bf%bc/ Gain an inside look at a variety of hardware offerings from digital signage companies such as displays, media players, enclosures and more. When you are purchasing expensive equipment, you need every advantage under your belt, and this guide is one more tool to help you make an informed choice. In this guide, you will find the answers to questions such as:
ABOUT THE SPONSOR DigitalSignageToday.com is the #1 site for news and information about digital signage technology. Our audience includes retailers, restaurants, financial institutions and more.Visit Company Showcase » Via https://duchonsigns.wordpress.com/2022/06/30/digital-signage-hardware-comparison-guide-2/ Catalina, Volta bringing EV charging stations with displays outside storesIbase launches single-board computer for automation, gamingBroadsign teams with Cartology to upgrade Woolworth’s retail media networkSNA Displays, Big Outdoor upgrade LED displays at Pacific City shopping centerDigital signage display market to grow by $2.90BDelphi Display Systems powers digital menu boards at Soulfull CaféLG Business Solutions releases short-throw laser projector RESOURCESManagement & Science University Utilizes CAYIN Digital Signage for Informative DisplayMid Valley Megamall looks to CAYIN Digital Signage for Seamless Content PublicationCheras Rehabilitation Hospital Upgrades Broadcasting System with CAYIN Digital SignageTapping into the Metaverse with LED DisplaysFanless High-Performance Media Player Powers Supermarket Stores TOP PICKSTop Digital Signage Software Providers for 2022Interactive Customer Experience (ICX) SummitDigital Signage Hardware Comparison Guide2022 Kiosk Marketplace Census Report Via https://duchonsigns.wordpress.com/2022/06/30/signage-industry-news-upadates/ Finding the right software provider is one of the most important decisions you’ll make when deploying digital signage in your business. Jan. 14, 2022 Finding the right software could be one of the most important decisions companies make as they prepare to roll out a digital signage platform. However, there are many factors to consider when choosing the ideal software. Initially, companies must decide how they want to use digital signage. What is their end-goal for deployment? That will help users select the best product and vendor to fit their needs. The best digital signage software should be able to juggle a lot of different functions, such as touch screens, internet of things, beacons, speech, and Web triggers, among others. If the software can handle all of these elements, chances are it will have no problem handling a demanding workload. The software must not only deliver clear, concise content, but have the ability to deliver it in real time. It’s also important to choose a software package with analytics features. That way, users can measure the effectiveness of their digital signage deployment. Below are some of the top digital signage software providers in the market… IntuifaceIntuiface is a no-code platform dedicated to the creation, deployment, and analysis of interactive digital experiences that connect people to place. Over 1,300 agencies, integrators, and enterprises across 70-plus countries are engaging audiences in-venue, on the web, and on personal mobile devices using interactive options such as touch, gestures, sensors, voice, computer vision, the Internet of Things, and more. It is an ISO 27001 Certified platform that can be used by most industries — including retail, hospitality, real estate, tourism, education — and for any intent — from digital signs to self-service kiosks and assisted selling. What makes Intuiface unique is:
Vertical Markets Served Top Clients Visix, Inc.Visix, Inc. offers a suite of digital signage software, content designs and meeting room signs for organizations wanting to engage, excite, and inform their audiences. Visix’s products work separately or together, are competitively priced and scalable, and have interactivity and data integration features for a unified, enterprise signage solution. Visix’s service and support teams consistently rank high in customer satisfaction for fast, professional responses and solutions. Vertical Markets Served
Vistar MediaVistar Media is an end-to-end programmatic ecosystem for digital out-of-home. Vistar Media’s demand-side platform and supply-side platform help buyers and sellers transact on DOOH inventory, while applying data insights to improve media performance. Vistar’s SaaS solutions (the ad server and Cortex for device and content management) deliver enterprise-grade solutions for monetizing and operating digital signage networks at any scale. Founded in 2012, Vistar Media is headquartered in New York City and has offices across the United States, Canada, EMEA and APAC. Vistar’s mission is to transform the OOH industry through programmatic technology, and enhance every transaction in the physical world with data-informed targeting, automation and measurement. Vertical Markets Served Top Clients CAYIN Technology Co., LTDAmidst the age of information revolution, a new medium has emerged — Digital Signage. In 2004, a group of passionate dreamers and engineers combined their faith and creativity to open more possibilities for the digital signage industry, and thus CAYIN Technology was born. Marked with an ambitious drive, CAYIN Technology dived into the world of precision marketing and multimedia information announcement. Looking to domestic and international technological advancements and combining the newest technology with multimedia players to develop comprehensive digital signage solutions, including diversified media players, content management servers, and advanced management software for monitoring and generating reports. CAYIN Technology has 17 years of experience in developing digital signage solutions, supports clients in more than 90 countries and has connected more than 1,000 brands and institutions with digital signage. Vertical Markets Served Top Clients Learn more about CAYIN Technology Omnivex CorporationOmnivex connects people and data. The Omnivex digital signage software enables users to collect, process, and deliver targeted information across your entire organization on any screen. It connects people with real-time visual information where and when they need it. Omnivex helps you achieve real business goals — increase and accelerate revenues, reduce delivery costs, improve customer loyalty, build brand equity and enhance employee engagement and productivity. Omnivex digital signage software enables you to:
Vertical Markets Served Top Clients Learn more about Omnivex Corporation Coates GroupCoates Group is an innovative technologies producer. Coates delivers end-to-end merchandising solutions through its extensive product range, covering everything from its powerful CMS software, Switchboard, to its digital hardware and signage. Switchboard content management system is a web-based, data-driven, scalable platform built for medium to large QSR brands and retail environments. It’s a key component in Coates’ digital merchandising solution designed to create, distribute, and display digital media to generate customer engagement. Switchboard uses real time data and analytics to orchestrate a customer journey by showing the right product, to the right customer, at the right time, while increasing revenue. Vertical Markets Served Top Clients SpinetiXSpinetiX inspires businesses to unlock the potential of their story. The SpinetiX team believes in the power of digital signage as a dynamic new storytelling platform to engage with people. For more than 15 years, they have been innovating to deliver cutting-edge technology that helps customers shine. SpinetiX delivers the most flexible and end-to-end signage solution on the market that answers to any deployment scenario: cloud-based, on-premise, or hybrid. SpinetiX ARYA is the cloud digital signage application designed as a one-stop content creation and distribution platform for end-customers or integrators. Elementi, on the other hand, is a simple, yet powerful signage software for rich data-driven content, easily integrated with 3rd party technology, that answers the needs of on-premise scenarios. In a hybrid scenario, both Elementi and SpinetiX ARYA can be used together for a best-of-both-worlds experience. Vertical Markets Served Top Clients Xibo SignageXibo is a reliable, cost effective digital signage solution that adapts to your business needs. Transform your digital signage designs simply and quickly to provide an engaging experience. Xibo powers digital signage networks worldwide through their open-source, web-based content management system, available with a choice of Android, Windows, webOS, Tizen and Linux players. With Xibo’s in the Cloud hosting solution, they manage everything needed to get your CMS running so that you can focus on content. You get the same great Xibo solution, with full support from the people who made the software. Vertical Markets Served Top Clients UserfulUserful’s software platform delivers IT teams unparalleled end-to-end control over corporate signage deployments. Unlike competitors, Userful provides infrastructure management without requiring proprietary hardware. Userful servers can be run in either a public cloud, or a private cloud configuration, while end-points (uClients) are software defined apps, available for LG WebOS displays, or any display with certified off-the-shelf uClient adapters. It offers unique workflow flexibility to display any content, from local network streams, HDMI inputs to 8k video files for large video walls, or use applications like Emerald Signage, a fully integrated Content Management System (CMS), and other 3rd party CMS integrations. Furthermore as a software-defined AV-over-IP platform, Userful can also be used in other application areas such as control rooms and meeting rooms, enabling Enterprise IT to standardize and do more with a single platform. Vertical Markets Served Top Clients UCViewUCView combines a simple user interface with flexible features and an extensive library of easy to use widgets and templates. Their software allows you to deliver your digital signage message to any TV or display simply and professionally. Individually control each screen or control as groups from cloud or locally stored CMS. UCView also comes complete with its own integrated IPTV platform, allowing you to entertain as well as inform your audience. UCView offers the necessary tools and functionality to efficiently design, distribute, and monitor digital signage content. The solution offers built-in content integration with over 120 apps that support all popular media formats. Users can design full-featured layouts using drag-and-drop functionality, as well as rotate, resize and crop sections. The Live TV feature and HDMI capture card allows users to connect a cable or satellite for capturing HD video content. Vertical Markets Served Top Clients eyefactive GmbHWhat WordPress is for websites, eyefactive’s app platform is for interactive software on professional touchscreens: Create engaging interactive signage software solutions on any large-scale multitouch display, table, kiosk terminal or videowall. Combine and customize ready-to-use multitouch apps easily and integrate your own content, layouts and designs, with a minimum of time and cost, without any programming involved. Provide amazing interactive experiences for point of sale, information and entertainment – as well as collaborative teamwork and innovative communication in corporate environments. Compared to simple html point and click applications, all apps are based on eyefactive’s multiple awarded software technology to provide true multi-touch and multi-user experiences, with a smooth and ultra-fast performance on any touchscreen system. Vertical Markets Served Top Clients Learn more about eyefactive GmbH Find more Digital Signage Software providers in our Digital Signage Supplier Directory. Via https://duchonsigns.wordpress.com/2022/06/30/top-digital-signage-software-providers-for-2022-5/ With its venue’s modern architecture, unique setting, and high-tech offer, Barcelona International Convention Center is known for offering first-class services that can fulfil the requirements of any kind of event. Digital signage is no exception, and the SpinetiX Complete Digital Signage Solution forms a key element of the Convention Center’s service offer. ABOUT THE SPONSOR At SpinetiX, we inspire businesses to unlock the potential of their story. We believe in the power of digital signage as a dynamic new storytelling platform to engage with people. For more than 10 years, we have been constantly innovating to deliver cutting-edge technology that helps our customers shine.Visit Company Showcase » GET YOUR FREE COPY Have an account? Login Now
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What is a Payday Loan from Direct Lenders?The expression “payday loan” applies to the loan offered by lenders in the form of a cash loan from a direct lender over which no third party has control. The procedure for requesting and approving the loan is the same as for traditional payday loans. The borrower fills out the application and then sends it back and then waits until the payday lender to take an immediate decision about whether or not to accept the loan. If the bank is able to approve you and you’re approved, you’ll be able to get your money back the next day when you’ve finished your work. Also, you won’t need to wait long to repay the small credit loan provided by direct lenders. The company that loaned you the money will deduct the money from your account as soon as you get your next paycheck. It’s quick, easy and simple, and easy to connect online! How Do Direct Lender Payday Loans Work?Ipass’ Direct lenders who provide payday loans are similar to conventional loans. Fill out the online application form then submit it and then wait for lenders to respond. If the lender agrees to your loan application, be sure you take the time to go through the loan’s terms thoroughly. You can accept the loan online in the event that you understand the conditions of the loan agreement, which include the interest rate as well as any additional charges. After that, you will be able to withdraw the money out of your account on the following business day. What are the advantages of using a payday lender that is direct?Direct lending companies will loan to anyone who has a credit score. It is important to avail of the advantages that direct loans offer. An easy online application. It’s not required to travel across the city to fill out an application at the shop. Bring your laptop, iPad, or mobile phone, and then complete the online application to receive the cash. There’s no need to send documents by fax. It’s much simpler to manage documents by this method. It’s the best alternative for people who do not have the time or energy to collect documents and then submit them to loan institutions. Our reliable lenders can provide the most hassle-free Teletrack loans. If the application is approved, the decision is taken upon approval, a decision is made immediately. Would you prefer a quick answer to your loan request when you apply online? The lender will take a quick decision once you have accepted the terms. The loan will not last for weeks since there will be no formal credit inquiry. There will be no rejection or denial. See also Top 10 Logistics Companies in India! Credit isn’t the best, but it’s certainly not fantastic. Poor credit. It isn’t always possible to get perfect credit. Those who have bad credit may be able to obtain cash to keep their families afloat. The gentle credit check is created to help those with bad credit and who are dissatisfied with their financial situation. It’s not a real credit test. It is not necessary to be able to pay your bills over an extended period of time by taking out the help of a short-term loan. One month can be sufficient to pay back the loan and keep from being in debt. Guaranteed Payday Loan without Third-Party ParticipationIf you fill out the form, it will be directed via one of our reliable lending partners who will be able to respond to your loan request in a matter of hours. Cash advances are accessible in all states, which includes Texas, Tennessee, Illinois, California, Ohio, Kentucky, Florida, and Pennsylvania, and are secured by data taken from your account at a bank. This is why it is essential to ensure that there are no other parties involved during the loan approval process. The financial transactions we offer are protected because of encryption technology. It’s a means of turning data into passwords that can’t be used by an unauthorized third party. We’re committed to protecting your privacy as well as data security. We’ve decided not to make use of a third-party processor to manage your loan. Direct lenders are not required to approve Payday LoansPeople in need of cash can be fooled by the idea of “no rejection of payday loans.” Prior to deciding whether to approve a loan request, direct lenders have to evaluate the creditworthiness of the person applying. Many people believe that there is no verification process in direct lending payday loans. As per Orville Bennett, founder of Ipass.net, loan firms conduct a simple credit assessment to determine your ability to repay payday loans. Learn more on credit checks before asking for direct lender payday loans. It is important to understand Direct lenders enjoy a substantial acceptance rate. This means you will be able to repay your debts without any rejections, including the rejections from payday loans within one working day. What else should you know before submitting an application for a Poor Credit Payday loan from a Direct Loan?Make sure you have all the required information prior to applying for bad credit payday loans on the web. If the loan you’re offered includes a variety of fees it is advisable to think twice about getting the loan. There are alternative lending options. Verify that the loan is trustworthy. If you’re in search of low-interest loans or loans, certain lenders might be able to scam you. They could offer speedy payday loans, but they could also charge extra charges. We suggest that you dig through all the information to ensure that you’re satisfied with the loan. See also How to Reduce Software Development Cycle Time! What are the conditions to get the loan offered by Direct Lenders?In order to apply to get secured payday loans from direct payday lending companies, applicants must meet the requirements for approval. Two of them are “must-haves,” while three are “must-be.” It is important to ensure whether you’re meeting these criteria:
Many people who take payday loans online fulfill the requirements for eligibility. Don’t worry about your credit score’s credibility. What is the best way to obtain the Advance Loan from an online lender to pay off payday loans?The process of applying for direct payday loans supplied by direct lenders for payday loans is simple and rapid. You only need to fill in a few fields. All you have to do is fill in one form. To apply for payday loans, the document will be sent to the lender network that is authorized by us. These are the steps you must follow if you need help obtaining an advance loan from a reliable payday lender:
After a review of your loan request, Inquire that our lending partners take a swift decision on the loan’s acceptance after you’ve reviewed your loan request. Following that, you’ll receive an offer to lend. If you’re permitted to accept the loan it is essential that you go through the terms and conditions of the loan to know your rights and obligations. If you are in agreement with the loan terms you can make an online agreement. The money will be available on the next business day, if not earlier. Be aware of deadlines. Cash will be available within the same day if you complete your application before the deadline. If you make your application late, the funds will be deposited into the applicant’s checking account the next business day. There is no requirement to wait in line to pay back the loan. After the following installment is due the lender will accept the loan. What’s your motivation for needing Quick Money in a Hurry?Do you require cash to cover unanticipated bills for utilities? We’re the lender that can satisfy your needs within the shortest time frame that is possible. Acceptance of payday loans is now simpler than it’s ever been. Nowadays, you can obtain a cash loan through a reliable direct lender. It is not necessary to solicit the assistance of a third party! Direct payday loans article and permission to publish here provided by Merry at travel-zoom.eu. Originally written for Supply Chain Game Changer and published on June 21, 2022.Share this:Via https://duchonsigns.wordpress.com/2022/06/30/ipass-direct-payday-loans-from-reputable-lenders/ Firms Announce New Crypto Initiatives; Data Published on Crypto and NFT Use By Robert A. Musiala Jr. and Veronica Reynolds Late last week, a major U.S. cryptocurrency custodian announced “a groundbreaking, industry-first custody exchange network giving institutions direct access to most trading pairs across prominent exchanges.” According to a press release, the cryptocurrency custodian has fully integrated with one major U.S. crypto exchange and has commitments to integrate with four other exchanges. The press release notes that the new network will enable various benefits, including separation between qualified custody and a crypto exchange, increased access to liquidity, reduced counterparty risk, and reduced hot wallet hacking risk. In another recent development, a major U.S. financial services firm announced that it is working with various NFT marketplaces to enable purchases of NFTs using traditional credit card payments. According to the announcement, a recent survey found that roughly half of respondents sought the ability “to pay with crypto for everyday purchases or [use] a credit or debit card to buy an NFT.” Also this week, a major global asset management firm announced a partnership with the blockchain arm of a fund distribution platform. According to a press release, the goal of the partnership is to incorporate the asset services of the asset management firm within the blockchain ecosystem, with the hope that the collaboration will help unlock “transactional efficiencies and enhanced transparency as well as operational agility that makes investment solutions available to a broader investor base.” Finally, this week two survey results were published that provide insight into digital asset investor sentiment. The first found that 71 percent of the world’s wealthiest people – 46 percent of whom reported wealth of at least $30 million – have invested in digital assets. However, the survey indicates that the concentration of digital assets within investor portfolios is small, with only 14 percent allocated to “alternative investments,” which includes cryptocurrency as well as other, riskier assets. A second survey, conducted on Twitter, found that 64 percent of respondents reported they buy NFTs primarily to “make money,” with far fewer respondents reporting they do so to participate in the community and “flex” (14.7 percent), “collect digital art” (12.4 percent), or “access games and tools” (8.6 percent). For more information, please refer to the following links:
Nonprofit Coin Center Files Lawsuit Challenging Crypto Provision of Tax Code Last week, Coin Center, a nonprofit research and advocacy center focused on cryptocurrency public policy issues, filed a lawsuit against the United States Treasury, the Internal Revenue Service, the United States and related individuals, asserting that a recent amendment to the tax code was unconstitutional on its face. The amendment, known as the 6050I provision, was part of the Infrastructure Investment and Jobs Act passed last summer, and it will require individuals and businesses that receive $10,000 or more in cryptocurrency to report to the government the name, date of birth and Social Security number of the person who sent those funds. Coin Center’s complaint alleges that this requirement violates the Constitution in two ways: First, it violates the Fourth Amendment and the right of privacy by forcing people to collect sensitive information about others with whom they conduct direct transactions, and second, it violates the First Amendment by forcing politically active organizations to create and report lists of their donors’ names and identifying information. The complaint also names additional co-plaintiffs who, Coin Center asserts, receive the kinds of payments that would trigger the amended law and thereby be turned into “unwitting warrantless surveillance agents for the federal government.” For more information, please refer to the following links: OpenSea and Chainlink Announce Network Transitions Leading NFT marketplace OpenSea recently announced its transition to a new open-source protocol in an attempt to lower transaction costs. According to the company’s announcement, OpenSea estimates that the switch could significantly lower transaction costs, or “gas” costs, by “about 35% based on last year’s data.” The company estimates the new protocol will save users $460 million in the next year. Sellers on the marketplace will have to pay a one-time fee per collection to sell their NFTs on the new protocol. In another network transition, decentralized oracle network Chainlink recently announced it had integrated its price information into Moonbeam, a new smart contract parachain on the Polkadot network protocol. According to reports, Chainlink noted that this venture will allow users who build within the platform to access price information compiled and aggregated from various exchanges, allowing decentralized finance developers to bring better price accuracy to their decentralized applications. For more information, please refer to the following links:
SEC Investigates Stablecoins, Crypto Exchanges; DOJ Seizes Dark Market According to reports, the U.S. Securities and Exchange Commission (SEC) is investigating whether the developer of a well-known blockchain network and decentralized finance application violated U.S. law in how it marketed its algorithmic stablecoin and token. The SEC is reportedly looking to determine whether investor protection laws were broken in connection with the marketing of the coins, which effectively lost all their value recently. A related report indicates that the SEC has also launched a broader inquiry into whether cryptocurrency exchanges have sufficient protections against insider trading on their platforms. According to a press release from the U.S. Department of Justice (DOJ), an illicit marketplace consisting of a series of websites selling personal information, including Social Security numbers and dates of birth, on the dark web has been seized by the DOJ and other U.S. and foreign law enforcement agencies. The administrators of the marketplace reportedly required buyers to use “digital payment methods, such as bitcoin” and employed various other techniques to maintain their anonymity and avoid detection of their activities for years. The DOJ’s Office of the Inspector General recently issued its Audit of the United States Marshals Service’s Management of Seized Cryptocurrency. The stated objective of the audit was to evaluate the U.S. Marshals Service’s management of seized cryptocurrency, covering the period from fiscal years 2017 through 2021. Among other findings, the audit report states that the Marshals Service lacks important operating procedures and controls and faces challenges in the management and tracking of seized cryptocurrency. The audit report provides multiple recommendations to address these deficiencies. For more information, please refer to the following links:
Report Analyzes UST Collapse, Australia Reports Losses to Crypto Scams A recently published Chainalysis report examined the collapse of TerraUSD (UST), which was once one of the largest stablecoins by market capitalization. UST is an algorithmic stablecoin, which means that it is backed by an on-chain algorithm that facilitates a change in supply and demand between the stablecoin and one or more cryptocurrencies. In the case of UST, it is backed by TerraLUNA (LUNA). Analyzing the collapse, the report first points to two traders breaking the “peg” on May 7, which led to investor panic and many holders beginning to sell off or withdraw. To repair this, Terraform Labs and other supporters purchased $2 billion UST. According to the report, this was a short-lived solution, as the continued sell-off drained those funds and LUNA became hyperinflated. As a result, both tokens crashed. In response to the recent cryptocurrency market crash, a crypto fund and a crypto lending company have reportedly taken some steps toward potential bankruptcy. A major Dubai-based crypto fund has been liquidated by crypto lending firms and is currently in the process of repaying lenders and other counterparties. Similarly, a major crypto lending firm has hired business-restructuring lawyers, according to reports. According to a recent report from the Australian Competition and Consumer Commission, as a result of cryptocurrency scams, Australians lost more than 205 Australian dollars in the first four months of 2022, a 166 percent increase from the same months in 2021. The report notes that 75 percent of those losses came in the form of investment-related scams. For more information, please refer to the following links:
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Via https://duchonsigns.wordpress.com/2022/06/30/financial-firms-and-crypto-networks-launch-initiatives-nonprofit-challenges-crypto-tax-provision-crypto-enforcement-continues-ust-analysis-published/ Subscribe Here!Email Address SUBSCRIBE TO SUPPLY CHAIN GAME CHANGER Anyone who has worked in Supply Chain knows that problems will arise anytime, anywhere and anyhow. These problems will require quick reaction, expediting, firefighting, long hours and sleepless nights. Certainly the disruptions caused by the pandemic have made reactive Supply Chain operation the norm in virtually every industry and every geography. How much of this reactivity could have been, or can be, avoided through the implementation of more robust Supply Chain strategies? After all wouldn’t you prefer to work in a more strategic and less frantic organization? Everyone Running Around With Their Heads Cut OffEven before the pandemic occurred, it was standard practice in most companies to have a Supply Chain team that had to react in real time to unforeseen circumstances. Late deliveries, supplier quality problems, equipment downtime, resource shortages, defective materials, missing inventory, manufacturing capacity and quality issues, demand fluctuations, natural or man made disasters, and more all have the impact of stopping production and shipments. And when these problems occur, the Supply Chain team is called to action. They must understand the problem and find immediate, if not interim, solutions. The heat is on. Adrenaline is flowing. All other work stops. And the attention from the CEO on down is intense, which is a dramatic understatement. I’ve lived through these nightmare scenarios many times, as a high-priced expediter. Unfortunately, through exhaustive experiences in resolving part shortages, my team and I became so good at this firefighting that the CEO would call us in to any situation to get things fixed fast, even though it wasn’t our “day job”. Expediting is a very tough job. And the people who do it are truly heroes who don’t always get the credit and recognition that they deserve for getting a company back on its feet. Still they get the job done and move on. The Reactive Supply Chain has historically been accepted as a standard reality and responsibility that just has to be dealt with as circumstances demand. Now throw a global pandemic in the mix. Starting at the end of 2019 and continuing for many years after, the Coronavirus pandemic has exposed the fragility of Supply Chains everywhere. It is hard to name a single product, industry, company, or element of a Supply Chain that has not been disrupted. See also What is 5G? And What Does it Mean for Supply Chain? (Infographic) Whereas in the past Supply Chain reactivity was a sporadic activity, in the wake of the pandemic Supply Chain reactivity became the dominant, if not the all consuming, activity for everyone everywhere. Strategies were cast aside. Every action was focussed on dealing with the hour to hour and day to day catastrophes and fires and putting them out as quickly as possible, and then moving on to the next problem. It is understandable that this would be the short term focus. The pandemic demanded a reactive response and focus. But the question is wouldn’t a more robust and proactive Supply Chain reduce the severity and incidence of problems? So many times I’ve heard people say that they are too busy fighting fires to do the work to improve processes so that they could spend less time fighting fires. The result is that they continue to spend all their time fighting fires. Obviously this type of thinking results in the self-perpetuation of reactive scenarios, over and over and over again. The Proactive Supply ChainIf you could make Supply Chains more robust this would clearly mitigate, thought not likely eliminate, the number of reactive situations which occur. You would be able to spend your time on more strategic initiatives, more intellectual endeavours, development and competitive differentiation. The fundamental trick to create the more robust, proactive Supply Chain, is to have the leadership that will allocate the time and resources to pursue these proactive activities. Without that leadership and vision, organizations will continue to be sucked into the morass of expediting and fire fighting. With that leadership and sponsorship organizations will get to spend the time on a slew of activities that will strengthen their Supply Chains in advance of the next impending disaster. Some of the steps that can be taken to create more robust and proactive Supply Chains include:
See also Digital Procurement Ecosystem Creation in 8 Minutes! Implementing several of these actions will reduce the incidence and duration of Supply Chain disruptions. Implementing the full complement of these actions will dramatically elevate a company’s Supply Chain performance relative to all competition as they will have fewer incidents, will resolve them more quickly, will further strengthen their business, and will move onward more rapidly. Now this does not mean that there will be no incidents. Take the global pandemic, for example. The level of disruption was so extensive that even the best (eg. just in time) Supply Chains faltered. But the goal is not really to eliminate Supply Chain failures. Something disruptive will always happen. The goal is to reduce these events and their impact, reduce the time to resolution, and increase the speed of recovery. ConclusionThere will always be disruptions in Supply Chain. There will always need to be an ability to react to and resolve those disruptions. But those disruptions are costly. They do not contribute to morale or customer satisfaction or profitability. So it is important to be able to dramatically mitigate both the occurrence of those incidents as well as the time to resolution. For that reason it is necessary to create more robust, Proactive Supply Chains. The companies that take those proactive steps will not only survive better than Reactive Supply Chain companies, but they will be the companies that will prevail. Supply Chain’s Moment of Truth has arrived and we need to take the path of proactivity. Via https://duchonsigns.wordpress.com/2022/06/30/the-reactive-vs-proactive-supply-chain-which-will-prevail/ |
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