December 11, 2022 (Published at www.OCCBlockChain.com; www.CaveatInsurer.com)

Michael J. Hsu, Esq.

Acting Comptroller of the Currency

Regarding your “Semiannual Risk Perspective Fall 2022” report at OCC.gov:

https://occ.gov/publications-and-resources/publications/semiannual-risk-perspective/files/pub-semiannual-risk-perspective-fall-2022.pdf ; kindly consider the below historically provable, verifiable, non-repudiable, quality managed, traceable, immutable, worth-of-your-trust realities after 21+ years of development and IAIS-member-regulated insured commercialization:

Anoop Bungay here; founding Governor of MQCC® Bungay International LLC, registered in Wyoming, USA with a domicile in Washington, DC, USA; founding LLC members are based in Calgary, Alberta, Canada. MQCC® Bungay International regulates (manages) some of the originating intellectual property and commercial applications used-in-commerce, developed between at least as early as August 14, 2001 and present day (2022+), by yours sincerely, Anoop Bungay. Intellectual property applications which - as  disclosed to at least four (4) current and past US Presidents (www.PresToPres.com), two (2) or more US Secretaries of the Treasury (www.TEACHINGSEC.com) and countless others  --  are proven safe, reliable and good, after 21+ years of development and commercialization; US Federal (National) Standards-integration; professional liability insured by 6 or more world-wide (global, international)) Property and Casualty (P&C) Companies (insurers) regulated by one or members of the International Association of Insurance Supervisors (IAIS) --- of which your bureau’s parent organization, namely the U.S. Department of the Treasury is a member through its subordinate office, namely the Federal Insurance Office of the United States Department of Treasury also known as FIO --- for over, up to 15 years or more, is correctly and properly described as haviing: 

“reshaped human understanding of how trust in regulated (non-free-trading) and non-regulated (free-trading) financial and non-financial commerce is established between two parties (on a peer-to-peer basis)” through correct and proper applications of the concepts, principles and core methods in the field of non-novel (exact) conformity science (www.conformity.org); further recognized by the US Government (Department of Commerce; United States Patent and Trademark Office (USPTO)) and up to 193+ countries world-wide (World Intellectual Property Organization (WIPO) convention) as the person in the leadership role as President of Bungay International Inc., (founding member of MQCC® Bungay International LLC) who, between at least as early as August 14, 2001 and April 9, 2005 effected the development and commercialization of the world’s first “peer-to-peer electronic (and obverse: non-electronic/physical) finance system” and subordinate “peer-to-peer electronic (and obverse: non-electronic/physical) cash system” found at the uniform resource locator (URL) www.privatelender.org; additionally, at least as early as May 9, 2008, recognized by the US Government (GSA General Services Administration; DOD Department of Defense; NASA National Aeronautics and Space Administration; NIST National Institute of Standards and Technology) for Federal (National; International) standards of trustworthy quality systems-integration and for having created what the Canada Supreme Court Justice Binnie J. essentially describes as “consumer safety devices” pursuant to “consumer protection legislation”, also known as trademarks, which are designed to notify government, industry and consumers at a prima facie (at a glance) basis, of the assurance of a standard of control of the nature and quality of goods or services, including one or more of the following family of world-famous marks, well-known marks, source identifier brand name (consumer protection; consumer safety devices);

MQCC® Bungay International: (www.mqcc.org) Worldwide (in 118+ Countries) Consumer Protection and Consumer Safety Devices for Source Identification: Proving to You a Standard of Quality™:

• FATHER OF DIGITAL ASSET & DIGITAL DEBT YIELDS (DADDY)™

• FATHER OF DEFI™

• FATHER OF NON-BANK FINANCIAL CREDIT INTERMEDIATION™

• FATHER OF RISK-BASED FINANCE™

• FATHER OF NET ZERO-CARBON REDUCING INNOVATIVE FINANCE™

• BLOCKCHAIN FOR LAWYERS™

• SAFE, RELIABLE, GOOD; BETTER, SAFER, MORE EFFICIENT™

• CRYPTO FOR LAWYERS™

• METAVERSE FOR LAWYERS™

• BLOCKCHAIN FOR POLICY MAKERS™

• CRYPTO FOR POLICY MAKERS™

• FATHER OF BLOCKCHAIN®

• FATHER OF CRYPTO®

• FATHER OF METAVERSE™

• THE GLOBAL STANDARD FOR CRYPTO®

• THE GLOBAL STANDARD FOR BLOCKCHAIN®

• THE GLOBAL STANDARD FOR BITCOIN™

• PRINCIPLES OF BLOCKCHAIN™

• CRYPTO, BITCOIN, BLOCKCHAIN AND METAVERSE FOR ELECTED OFFICIALS AND REGULATORY BODIES; REGULATORY PROFESSIONALS™

• BUNGAY INTERNATIONAL TECHNOLOGY CONFORMITY OF ORGANIZATION AND INDIVIDUAL NETWORK: BITCOIN™; The World's First Utility Token™

• BITMORTGAGE®; The World's First Securities Token™

• PROFESSIONAL BITCOINEER (P. BTCR.)®

• PROFESSIONAL BLOCKCHAINEER (P. BCR.)®

• BITCOINPEDIA®

• BLOCKCHAINPEDIA®

• BUNGAY LOGIC AND ORDER CONFORMITY KERNEL; CYBER/NON-CYBER HARMONIZED ARTIFICIAL/NON-ARTIFICIAL INTELLIGENT NETWORK: BLOCKCHAIN™ trademark brand quality management system

• OFFICIAL AUTHENTIC ORIGINAL OAO™

• WORLD BLOCKCHAIN DAY®

• WORLD CRYPTO DAY®

• FATHER OF FINTECH™

• FATHER OF CONFORMITYTECH™

• FATHER OF SYSTEMS-LEVEL AI (Artificial Intelligence)™; SL-AI™

• FATHER OF SYSTEMS-LEARNING AI (Artificial Intelligence)™; SLr-AI™

• FATHER COMMERCIALIZED QUANTUM COMPUTING CQC™

• BLOCKCHAIN HALL OF FAME®

• ACCREDITED CLASS®

• FATHER OF FREE TRADING SECURITIES™

• PRdIVATELENDER.org: PRIVATE LENDING NETWORK™/®

• not a complete list of goods and services source-identified by proprietary trademark brand names

OCC States on page 20: Crypto industry risk management practices lack maturity. Most crypto market participants appear unprepared for the stresses and surprises that have taken place this year, resulting in substantial losses for millions of consumers. Risk management and governance practices continue to evolve and are not yet robust. Scalability and efficiencies have not yet been obtained. Hacks and outages are frequent, and fraud and scams remain high throughout the industry. In some cases, ownership rights, custody arrangements, and financial representations have created a high degree of confusion. Addressing these risks and poor practices is a necessary, but not wholly sufficient, step toward market maturation.

REALITY ONE (1): OCC and millions of mainstreet Americans and billions of foreign direct and indirect investors into the US economy need to know that OCC and other organizations have at best an insufficient, incorrect or incomplete (imprecise) understanding, or -- at worse -- a misdescriptive or deceptively misdescriptive understanding of the underlying superordinate science domain, namely, non-novel (exact) conformity science (see www.conformity.org); and the subordinate genus and species of generic goods and services. The “world” at large - comprised of 99.9999999999% of persons not exposed to the originating intellectual property, OVERSTATE the “computer science” and object oriented programming paradigm aspect or programmatic aspect using the CLASSICAL COMPUTING systems when, in fact, GOOD, SAFE “CRYPTO” (the original NON-VOLATILE system) uses COMMERCIALIZED QUANTUM COMPUTING principles (visit www.QuantumComputingIsHere.com) because they are relying on an ‘anonymous’ “white paper” in 2009 (Oct/31) and subsequent “sourceforge” .exe file “dump” on Thursday, January 8, 2009 at 14:27:40 EST. 

For example, the commercialized concept system called “crypto” is - and always has been - from at least as April 9, 2005 - (www.privatelender.org) a RISK-BASED PROCESS that provides the user (beneficiary) the ability, to use a MQCC® trademark: SLEEP WELL AT NIGHT™/® in matters of peer-to-peer electronic (non-electronic (physical/cold)) finance, peer-to-peer electronic (non-electronic (physical/cold)) cash distribution (via a system-network); and achieves higher standards of trustworthy quality through over 14 years of continuous registration, since at least as May 9, 2008, to United States Federal (National) Standards trusted by NASA, DOD, NIST and the US Government system-wide, to ISO 9001:2000, ISO 9001:2008 and the risk-based ISO 9001-2005.  The implication is stark and since you are a lawyer, you are encouraged to read my training notes to the American Bar Association and other US and international legal supervisory bodies, at www.BlockChainforLawyers.org (also known as www.CryptoForLawyers.net).

More can be said. This is enough for this point. Much more; 21+ years.

OCC States on page 20: Contagion risk is high within the crypto industry. The events of this year in the crypto industry have revealed a high degree of interconnectedness between certain crypto participants through a variety of opaque lending and investing arrangements. The market stresses revealed that crypto participants may be engaging in highly leveraged trading, in addition to providing brokerage, custody, and exchange-like services to customers. The result is a high risk of contagion among connected parties. 

REALITY TWO (2): OCC and its peer regulatory organizations world-wide need to know that correct and proper understood and implemented “crypto” systems are truly FEDERATED (this is the correct term --- not ‘decentralized’ or ‘distributed’); and --- as proven by the MQCC® pleoverse of universes (visit www.metaverspedia.info); does NOT have any interconnectedness. As stated at scholar.mqcc.org, the trademark slogan says it all: Leaders in Government, Industry and Academia: WHEN YOU MIS-LEARN, YOU MIS-LEAD™

OCC States on page 20: Stablecoins may be unstable. Stablecoins are cryptocurrencies that are designed to have a relatively stable value. The collapse of an algorithmic stablecoin in the spring revealed the potential for run risk with stablecoins. The collapse affected not only algorithmic stablecoins but also asset-backed stablecoins, with some losing their pegs for periods of time. While stablecoin reserve practices have incrementally evolved since then, most stablecoins remain susceptible to run risk

REALITY THREE (3): OCC and its peer regulatory organizations world-wide need to know that the OFFICIAL AUTHENTIC ORIGINAL OAO™ utility token service, known by the world famous trademark source identifier: BUNGAY INTERNATIONAL TECHNOLOGY CONFORMITY OF ORGANIZATION AND INDIVIDUAL NETWORK: BITCOIN™ is inherently FIAT-INTEGRATED and inherently conforms to the same standards that one or more central bank uses to assure the highest quality of their central bank currency -- both digital and physical -- since at least as early May 9, 2008 -- and after over 14 years of existence, is proven to be stable. Read the textbook ORIGIN OF A SPECIE™ found on the internet; to learn for yourself. Oh, and yes, Michael, the “bitcoin” you are thinking of, is not an OFFICIAL AUTHENTIC ORIGINAL OAO™ brand of “utility token service” and, as such, you and countless others are being effectively mislead by nothing more than a non-conforming algorithm that fails to conform to the originating standards developed by MQCC® founding members at least as early as April 9, 2005 and the implication is clear: non-conforming “bitcoin” or bitcoin that is based on COMPUTER SCIENCE and NOT on CONFORMITY SCIENCE is “fake, counterfeit, pirated, non-standards-based, standardless and proven to be volatile and harmful in both economic terms ($$$) and emotional (mental well-being) terms to humans (mainstreet investors).

REALITY FOUR (4):  At least (1) or more (2+) of these insurance companies have insured the organization that operates the originating bitcoin system-network, which is globally accessible at many places including fcp.mqcc.org

Since at least as early as April 9, 2005 or later; MQCC® is continuously insured by (1) or more (2+) Office of the Superintendent of Financial Institutions OSFI-regulated or FSCO/FSRA regulated Insurance Company or RIBO Registered Insurance Brokers of Ontario organizations, for Errors and Omissions liability for over 12 years; here is a list (some companies might not appear since they might have merged or changed names);

FSRA Approved Errors and Omissions Insurance Providers (2020/10/22)

https://www.fsrao.ca/licensing/mortgage-brokerage/about-mortgage-brokerage-and-mortgage-administrator-licences/fsra-approved-errors-and-omissions-insurance-providers

(OSFI - (Office of the Superintendent of Financial Institutions) Regulated) or (RIBO - (Registered Insurance Brokers of Ontario) Regulated) or (FSRA - (Financial Services Regulatory Authority of Ontario) Regulated) YOUR FELLOW International Association of Insurance Supervisors (IAIS) MEMBER ORGANIZATION!

Insurer Insurance Broker

• AIG Insurance Company of Canada Various Brokers

• Victor Insurance Managers Inc. (formerly Encon Group Inc.) PROLINK Insurance Inc.

• Intact Insurance Company, Western Division IDRIS Insurance Brokers Ltd.

• International Insurance Company of Hannover SE through A.M. Fredericks Underwriting Management Ltd. Various Brokers

• Lloyd’s Underwriters RDA Inc.

• Lloyd’s Underwriters Holman Insurance Brokers Ltd.

• Lloyd’s Underwriters per Caitlin Canada Inc. Various Brokers

• Lloyd’s Underwriters through Special Risk Insurance Managers Ltd. InsureLine

• Lloyd’s Underwriters through Evolution Insurance Inc. Various

• Lloyd’s Underwriters as arranged by Trinity Underwriting Managers Various Brokers

• Royal & Sun Alliance Insurance Company of Canada (for existing clients only) Jones Brown Inc.

• Sovereign General Insurance Company through Premier Canada Assurance Managers Ltd. Various Brokers

• XL Specialty Insurance Company - Canadian Branch Various Brokers

So -- if any USA bank is insured by at least one (1) or more (2+) of these organizations, they might find it prudent to DEMAND that ALL PARTIES CEASE AND DESIST any further work in “crypto” or “NFT” or whatever “fintech” they have “going on” because once a smart lawyer or two figures out that the reason why the creator of the original “bitcoin” utility token and securities token (BITMORTGAGE®) was not on television or social media or flashing around in a supercar or yacht, is because he is painstakingly, maintaining the safety and quality standards and , as you will see when you google “Anoop Bungay” -- yelling as loud as he can (in writing -- because at MQCC® “TIME IS MONEY AND TALK IS CHEAP™) to leaders like you to take the time to learn --- then you will agree that it is fair and reasonable to infer that many lawyers will be starting to sue the “crypto” sales people (investors, developers, promoters) for failing to research the internet and research the United States Patent and Trademark website (where one normally goes to see “who invented what”, either by way of patent or trademark registration) for being reckless or wilfully blind for not taking the time to invest their $$$ to do some research NOT from a BLOG or a SOCIAL MEDIA POST - but from an OFFICIAL GOVERNMEMENT SOURCE and learn and conform to the de jure integrated de facto industry standards of quality, safety, non-volatility, reliability and more, established by MQCC® and Anoop Bungay since at least as early as April 9, 2005 to May 9, 2008 and onward) before soliciting investor funds or selling some ‘crypto’.

 By the way, Michael, it takes over 4 years for a bachelor degree and another 2 years for master's degree and 2+ more for a doctorate; with at least 5 years of work experience to gain necessary and sufficient competency and another 7+ years to gain a proficient level of competence (in accordance with consensus international standards recognized by the US Government); see www.TeachingPresident.com (where I explained this the President Biden and your team at the US Treasury; and scholar.mqcc.org to learn.

Read the rest of the items at www.OCCBlockChain.com; www.CaveatInsurer.com)

Do you know that the World-Famous trademark of financial services: BITMORTGAGE® is built (in part) on OCC Comptroller Standards for Risk Prevention & Safety?

Is anyone at OCC aware of the below “bitcoin crypto” risk disclosed back on January 8 2009? (“who read the packaging”?) see below:

MQCC®-Public Safety Memo RE-BITCOIN and Exchange CEO-Bitcoin v0.1 released (2009 - 2022+)

Government Regulated and Licensed Insurers & Insurance Supervisors: 

REDUCE YOUR OWN REGULATORY RISK!™

History of Consumer Protection Initiated by CLASS ACTION Lawsuits