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1/ @blockstack is not the only #RegA+ to have been qualified. The @YouNow Reg A+ offering also has been qualified but it is much different. The offering is to distribute #Prop tokens as rewards in its video app and for developing the network / apps on the network.
2/ Like Blockstack, YouNow has taken the position that the distribution of the tokens does not require a BitLicense in New York. The offering is available to NY residents. Reisdents of Arizona, Nebraska, North Dakota and Texas are exluded.
3/ Like Blockstack, YouNow believes that the network may become so decentralized that the Props tokens will no longer be securities.
4/ YouNow believes that validators in its network may need to register as broker-dealers, transfer agents, or clearing agencies. In each of those cases, the arguments for registration are weaker than against registration.
5/ Like Blockstack, YouNow recognizes that it may trigger 12(g) because the tokens could be considered equity securities. Also, YouNow is not exempt from it as a Reg A+ issuer because it will not use a transfer agent.
6/ Like Blockcstack, YouNow warns that it could be considered an investment company based on the fact that it holds its own tokens, which are securities, in treasury. There are at least 3 good arguments for why YouNow should not be an investment company.
7/ Like Blockstack, YouNow warns that it could violate Regulation M, which prohibits issuers from buying and selling their securities at the same time to prevent price manipulation.
8/ I would not expect floodgates to open as a result of both of these qualifications but we should now expect good quality offerings to be qualified.
