Skip to text

Internal · CSAI board, officers, counsel · 11 September 2026

Not an offer · Counsel has not opined

Decision Support

How the path was scored

The fourteen standing lines

What each architecture does to the covenant

v0.18 §11.4 puts these in the publisher’s certificate. entity_structure_v0.19 restores line 1 to its v0.17 strength at the publisher because the holdings sit at the parent. A listing-primary SKU, and a USD bonded SKU, do not need to amend any of them. A DFY rail breaks six. V19 amends five and breaks none. P5 is not drawn as its own column: bonded-DFY is that column.

On the active path

14 hold

Amended

0

Broken

0

#LineUSDDFY railListedV19
1

No token held, issued, priced, accepted, referenced

Listed path: DFY is the venue’s wrapper unit; CSAI’s SKUs stay USD. Bonded-DFY: CSAI prices and accepts DFY. That is the token that exists outside the design.

holdbreakholdamend
2

USD fees, fixed, never negotiated

A listing licence at a USD list is the same line. A DFY list is a token price. NetCo’s D63 share is a fixed published percentage — the only amendment on V19.

holdbreakholdamend
3

Impersonal, scheduled Read

A listed underlier is the strongest form of an impersonal Read. A Read payable in DFY makes CSAI the buyer of last resort of a token its own efforts drive.

holdbreakholdhold
4

IOSCO statement and fallback with every settlement licence

A DCM listing will ask for this packet whether the network is bonded or open. A DFY rail does not write the statement.

holdholdholdhold
5

Derived-data agreements before first settlement licence

Publisher must exist before week 5 (entity_structure_v0.19 §5). Live F2 already settling makes this late on every path.

holdholdholdhold
6

Venue warranty on U.S. persons

Listing-primary makes this a DCM/ATS problem, not a CSAI problem — still required in the licence. A harbor does not replace it.

holdholdholdhold
7

No governance through any token

Hold only if DFY carries no vote. The 86.8% holding is an insider-supply failure, not a vote, and is still fatal to any mature-system claim.

holdholdholdhold
8

Frozen rule; pre-registration

The book is the pre-registration record. Live FN-F-v1 is a versioned instrument, which is the right form.

holdholdholdhold
9

No virtual-asset service by any party

Accepting DFY for a Freeze or a Read is a virtual-asset service. A Q4 harbor, if it exists, covers listed tokenized wrappers — not CSAI as a DFY merchant.

holdbreakholdamend
10

No fee intermediation (B1)

Direct pay can be in DFY without recreating OpCo, which is why bonded-DFY is not quite P5. P5 also broke this line.

holdholdholdhold
11

No market for W created or referenced

A DFY rail puts a DFY price in CSAI’s documents. Listed path: venues list wrappers; CSAI’s list stays USD and carries no DFY venue.

holdbreakholdamend
12

No intermediary between W payer and payee

Vacuous if there is no W. A DFY rail must still settle peer to peer. Keep the line; do not fill it with a router.

n/aholdn/ahold
13

No front-end, relayer or hosted wallet (Storm line)

Live /network is a console, not a wallet. A DFY rail that needed a hosted wallet would break this; the design forbids it on every path.

holdholdholdhold
14

No custody of W or deposits by CSAI

A DFY bond is virtual-asset custody. The three holders still need a licence for exactly that. USD bonds do not.

holdbreakholdamend

Publisher exclusion

A listed, impersonal, scheduled print sold at a USD list to every venue is the form Lowe and the IOSCO principles were written for. A Freeze licence that is a condition of register() is closer to an admission fee. Both can be held inside line 3. A Read payable in DFY cannot: CSAI becomes the buyer of last resort of a token its own efforts drive. That is the fourth Howey prong, conceded, and the exclusion is gone.

Status on these levers: clean.

VASP / money-transmission load

vasp_v0.17 tested every leg. Direct pay, USD contract bond, no front-end, no W market: no party performs a virtual-asset service. A listing licence paid in USD does not reopen it. A DFY rail does — accepting DFY for fees is a virtual-asset service; a DFY bond is virtual-asset custody. A Q4 harbor, if it exists, covers listed tokenized wrappers, not CSAI as a DFY merchant. NetCo’s primary sale and vault also reopen it, which is why V19 is a licensed operator, and why it is parked.

Load on these levers: none.

Line 3 during a financing

business_plan_v0.18 §11.5. A prospective investor asking for the Read during diligence gets the published product at the published USD price, or gets nothing. Not a free trial, not an early feed, not a sample of this week’s states, and not a DFY side letter. The public registry states, the reference implementation, the test vectors and the book are free. Diligence is conducted on those. The same sentence applies to F2: the freeze is public; the listing licence is not a side letter.