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They registered their stock as offered only to qualified investors per Rule 506(c). So all they had to file is a Form D, which has a name and address and not much else.

Their loan system isn't registered as a security. They even say "Earn accounts have not been registered under the Securities Act and may not be offered or sold in the United States, to U.S. persons, for the account or benefit of a U.S. person or in any jurisdiction in which such offer would be prohibited." But not prominently on their home page.

They will get to explain to the SEC why they have the US toll-free number "1-866-HODL-NOW" and are on the Apple Play Store for the US.

Yes, you can look at their transaction log, but it's doesn't tell you all that much. 7 hours ago, they sent 50,000 ETH to somebody.[1] Some people are "paused" less than others, apparently. Someone noted this on Twitter[2]

[1] https://etherscan.io/tx/0xf9e0788094c0bbfdc61ed2fbcf79dfcd4d...

[2] https://twitter.com/btcinchina/status/1536186927707066368



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