1/14 Celsius repeatedly represented that it was better than a bank, frequently using the hashtag “#unbankyourself,” and that Celsius customers could gain “financial freedom” by joining Celsius. Celsius explained on its website that “P2P,” which

Pages 244-246
2/14 typically means peer-to-peer, instead signals financial freedom: "At Celsius, we believe P2P stands for Power to the People.” Likewise, in 2018, Mr. Mashinsky posted to Twitter that “P2P for
3/14 me means #Power2ThePeople,#Cryptocredit & #FinancialFreedom by the people for the people! #CelsiusNetwork.” Celsius posted to Twitter: We're providing a platform of curated services that have been abandoned by big banks — things like fair interest, zero fees & lightning
4/14 quick transactions. Our goal is to disrupt the financial industry & introduce financial freedom through crypto.
5/14 And on Celsius’s YouTube channel, the caption to a September 24, 2021 video stated, “Our mission: To put unparalleled economic freedom in the hands of the people. Join the revolution, join Celsius and unbank yourself!”
6/14 The internal Brand Guidelines encouraged Marketing personnel to include this theme in its public messages, including with language such as, [t]he financial industry has a history of hurting groups of people and thwarting their dreams of financial
7/14 independence with exclusionary or exploitative practices. But we’re not for a wealthy group of a few elites. We’re for democratized wealth for all. Celsius publicly described how it created “democratized wealth for all” through its business model
8/14 in a since-deleted blog post, stating that,[t]he Celsius business model is structured to do the exact opposite of what banks do — by giving 80% of total revenue back to our community each week in the form of earned interest.
9/14 We earn profits by lending coins to hedge funds, exchanges, and institutional traders, and by issuing asset- backed loans at an average of 9% interest.
10/14 Mr. Mashinsky publicly promoted the concepts of transparency, trust, and financial freedom in press interviews and in quotes he provided for industry publications. The Examiner reviewed more than 350 articles in which Mr. Mashinsky was quoted.
11/14 Selected quotations include the following:
We have seen time and time again that customers choose Celsius for yield and loans because they trust us, and our goal is to always act in their best interests and consistently deliver industry-leading transparency.
12/14 Celsius was built to act in the best interest of the community, and we have consistently delivered honest, transparent, and rewarding financial services.
13/14 Our relationships with our 230,000 community members are built on trust, because they count on us to act in their best interests . . .
14/14 we’re providing additional transparency into our business, which remains one of the industry's most reliable, secure and rewarding platforms for putting unparalleled economic freedom into the hands of the people.

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More from @otisa502

Feb 5
1/34 Celsius stressed security, stating on its website that “our top priority is keeping your assets secure” and citing “[t]op-tier Security & Cyber Defense leaders driving forward and protecting a mission-driven community." Celsius also emphasized the

Pages 246-253
2/34 “safety” of the Celsius platform as a low-risk place for customers to invest their crypto. Regarding security, Celsius’s website promoted its security certifications, “24/7 Security Operations Center,” a global team of cybersecurity experts, and
3/34 “industry-leading security infrastructure & asset protection.” During an October 2021 AMA, Celsius’s Chief Security Officer stated, “Our security slogan is ‘Keep safe, secure, and HODL’ ... That’s key for us and for you, of
Read 34 tweets
Feb 5
1/15 Celsius frequently represented that it intended to create a “community” amongst its customers, to whom Celsius referred to as “the Celsians.” Celsius paired its public goal of creating a Celsius community with its promise that Celsius would provide a

Pages 240-244
2/15 measure of altruistic goodwill to customers. In a since- deleted 2019 blog post, Celsius wrote that it was “founded by an innovative team with a simple idea: Financial services should only ever act in the best interest of their community.”
3/15 The post went on to distinguish Celsius from interest- earning accounts at its competitor, BlockFi. Celsius noted that BlockFi’s terms of use expressly stated that BlockFi did not have a fiduciary relationship with its customers.
Read 15 tweets
Feb 5
1/18 At the same time Celsius was struggling to balance its growth with revenue generation and its lack of sufficient risk or oversight management, Celsius engaged in a robust advertising campaign that did not reflect these challenges.

Pages 235-239
2/18 From inception, Celsius waged an aggressive public campaign to attract new customers to the Celsius platform and retain existing customers, and in many instances, to use existing customers as "ambassadors" to bring in new customers.
3/18 Celsius repeatedly emphasized multiple themes in its campaign, which continued even up until it filed for bankruptcy, including the following: (1) Celsius put its 'community' of customers "first;"
Read 18 tweets
Feb 5
1/7 “Perhaps the harshest assessment of the Freeze Report came from Celsius’s Risk Team. In February 2022, members of the Risk Team discussed new deployment proposals. Mr. Sunada-Wong reminded the Risk Team that new strategies were not approved until the
2/7 “current Freeze Report was finalized. Tamas Antal (Head of Model Risk and Quantitative Analytics) in response, said:
‘From what I understand the main problem is not that people are not signing off on the freeze but that the freeze is taken way too seriously for
3/7 “what it is: it is one analyst’s lonely guess of what the firm’s positions are. It is a random spreadsheet that we (the firm) did not take seriously enough to assign proper resources.’ Mr. Chan agreed: ‘[t]he freeze is unfortunately one analyst’s guess of the firm’s
Read 7 tweets
Feb 5
1/10 “In or before 2021, Celsius also formed a Coin Listing Committee to review and assess crypto assets as possible additions to the platform. The Coin Listing Committee met every other week and was chaired by Celsius’s Head of

Pages 217-220
2/10 “Research, Ron Sabo. One well-known problem that Celsius employees routinely mentioned was the listing (and potential deployment) of assets that did not yield any revenue or profit for the company. In June 2021, Yaron Shalem, then Chief Financial
3/10 “Officer, consulted with Mr. Tappen and Mr. Nolan and told Mr. Sabo that if Celsius did not have a way to deploy an asset, it should lower the reward rate for the given asset. Mr. Sabo initially questioned the decision, suggesting that Celsius look at the larger market
Read 10 tweets
Feb 5
1/9 “When Mr. Maglic arrived at Celsius in June 2021, ‘there was no robust liquidity framework’ and ‘no firmwide understanding of what our liquidity was on a coin level and . . . at top of house.’ He prioritized developing a framework for measuring Celsius’s
2/9 “liquidity and then expanded the infrastructure to encompass risks related to other areas such as market, credit, and economic capital. The Liquidity Reserve/Modeled Liquidity Outflow (‘MLO’) report, first created during the summer of 2021, offered the
3/9 “missing insight into Celsius’s liquidity. The MLO is described in Celsius’s Liquidity Risk Policy as ‘a set of models, rules, and business logic designed to determine liquidity under a given scenario,’ with the underlying report intended ‘to ensure that the Firm maintain[ed]
Read 9 tweets

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