Consumer complaint received 2019-06-24
Company: Circle Internet Financial
Product: Money transfer, virtual currency, or money service
Sub-product: Virtual currency
Issue: Confusing or missing disclosures

Complaint:
On " XX/XX/XXXX '' I and many Poloniex users received an email announcing that the exchange had faced on " XX/XX/XXXX '' with a price crash in a coin market named CLAM   that had caused " a roughly 1800 BTC generalized loss across the Poloniex BTC margin lending pool ''. At that announcement they said that all Bitcoin loans are lent in a common pool and because of that all BTC lenders would have lost 16.202 % of their bitcoins. 
Immediately after the announcement, many users and community traders started to express their resentment about this event and the unfairness way Poloniex treated they customers. Beside the fact they dont show any kind of commitment with users, the answer they showed sounded very illegal. 
First of all, there is a lack of information in what really happened. They took about 10 days to inform they users about this event. None of us got an audited report or even any other details about it until now. The only thing they did was giving back 10 % of the total confiscated saying we should expected more, but no news until now. What they answered is that they are sad about the event and they are trying to contact borrowers that had defaulted. They don't show any schedule or deadlines to solve the problem they had created, proving that they don't want to be responsible to what happened. 
On top of that, theyd NEVER explained that loans were dealt in a common pool. I'd never seen that before by the way. The way we place a lend order shows and proves that loans were dealt in a peer-to-peer manner. Each loan had a specific rate, maturity and amount. Socializing the defaults shows that there is a serious problem with their controls. Checking the lending statement, we can prove we pay for them to manage loan contracts and so Poloniex do have some responsibility and must pay for it. As an intermediary, they must act in favor of system integrity. It is not reasonable to you take several precautions to prevent borrowing Users from defaulting on loans and then you allow users to allocate low liquidity coin like CLAM as margin. To show how absurd and fraudulent seems Poloniex controls, despite their SEVERAL PRECAUTIONS, they allowed that 16.2 % of all their BTC loan market ( more than XXXX mln usd at that moment ) were backed with a coin of XXXX mln usd of mkt cap and with average daily volumes well below XXXX usd ( https : //coinmarketcap.com/currencies/clams/ ). 
If it couldnt become worse, many users that had entered in Poloniex loan market AFTER the event had their funds confiscated too. 
The lack of transparency and communication in this event prove us that certainly there is something hidden from this history. Just another example of the lack of transparency, we can not monitor in our Poloniex account how much they took from us. Our statement didn't show the exactly amount that was taken from us. The only thing I know is that in fact there is something missing ... 
Many evidences prove that Lenders were misguided by Poloniex disclosures and trusted on certificates and licenses gave by US authorities to Poloniex. Probably, US authorities may had been misguided by Poloniex too and that is the reason I will also write to them. Analyzing CLAM market behavior, we can strong believe that it was a manipulated market and even the SEC and FBI should investigate what happened.

Company response to consumer: Closed with explanation