ICDevs Votes on SNS and NNS Proposals

ICDevs Votes on SNS and NNS Proposals

Just a quick update from ICDevs as we know we have a lot of people following us that “Inherited” following us on the SNS topic.

TLDR: We will start voting “Reject” on all SNS and community fund topics. You may want to follow us or unfollow us on that topic depending on your risk preference/nationality. We will also begin to “Reject” updates on the Network(System) Canister Management topic proposals for canister qoctq-giaaa-aaaaa-aaaea-cai (NNS front end) as long as it includes token swap functionality. Again, you may want to begin following ICDevs on that topic if you are under certain risks.

ICDevs is a 501c3 non-profit and as a result, must comply with US-based laws. According to our analysis, the way the SNS has been deployed in its current iteration constitutes putting NNS participants in flagrant violation of SEC guidance as issued in the 2017 DAO Opinion:

“Those participating in unregistered offerings also may be liable for violations of the securities laws. Additionally, securities exchanges providing for trading in these securities must register unless they are exempt. The purpose of the registration provisions of the federal securities laws is to ensure that investors are sold investments that include all the proper disclosures and are subject to regulatory scrutiny for investors’ protection.”

In our opinion, voting “accept” to launch a token sale may be viewed as “participating” in an unregistered offering for us or the people that follow our neuron. As a result, we will in the future vote “reject” on all SNS and Community fund proposals.

Further, since the NNS app hosted at https://nns.ic0.app now enables the swapping of ICP for potentially unregulated security offerings we have to be careful not to actively participate in enabling that, so we will begin to vote reject on all Network(System) Canister Management topic proposals for canister qoctq-giaaa-aaaaa-aaaea-cai (NNS front end) that include the launch pad functionality). If you have concerns about this as a US Citizen or someone that may want to travel to the US in the future, you can follow us on that topic and we will continue to accept other System Canister management requests and only(at this time) reject the NNS Front-end requests.

While we are incredibly excited about the functionality of the SNS and the launch pad and the world they could enable, we believe that putting the NNS in a position of pro-actively launching token sales and publishing a swap marketplace places the entire NNS site in the crosshairs of regulators that could demand that US-based boundary node block access to the nns.ic0.app domain name cutting off access to hundreds of ICP and NNS users. This seems like an entirely undue risk when NNS token launches could(and in fact can be) launched by manually installing the code without the help/approval of the NNS and the launchpad could be published to the IC without the need for NNS approval(as a standard IC frontend canister).

We aren’t happy about this and wish the US government would be more descriptive and exact in their guidance on what does constitute participation. We do have to deal with reality though and we believe that given current the regulatory environment we should do what we can to protect our access to the ICDevs treasury and advocate for the protection of the funds that IC Developers may have locked into an interface that may become inaccessible.

While we will be unlikely to vote to approve SNS launches in the foreseeable future until we see regulatory guidance, we are excited about SNS as an enabling technology with IC.


Q: What is the actual worst that you think could happen?

A:Worst case: The Executive Director, Board of Directors, and Developer Board end up in jail as participants as ICDevs voters to launch the sale of unregulated securities and ICDevs is asked to provide records on followers of our neurons. NNS.ic0.app is blocked by US boundary nodes for selling unregulated securities US citizens and US ICP holders lose access to their neurons.

The fact that these are not technically correct or possible is irrelevant because the regulators could likely be trying to make an example and they have the power to do so.

Q: What would enable ICDevs to begin voting Accept on new NNS Front end votes?

A: Removal of the Launchpad functionality that allows the swapping of one Token for another.

Q: What would enable ICDevs to begin voting Accept on new SNS token launches?

A: The US government would need to give more strict guidance on what “participation” is and what constitutes legal participation in token launches.

Q: Won’t the “wisdom of the crowds” keep offending SNS tokens from being launched?

A: The fallacy of this assumption(to me) that the NNS will be a filter is the belief that the community can self-regulate and self-discern what is a utility token from what is a security and/or what is a useful new protocol vs what is a Ponzi scheme. Further, there is nothing to keep a protocol from going ponzi after approval and undoing the diligence the community attempted beforehand. The public won’t care…they will just see the next Luna or FTX and point at the people that voted to approve the sale as having violated any number of SEC regulations.

The fact that the NNS is becoming a storefront for advertising these things is an even more flagrant nose-thumbing at the specific rules against doing that. I know we have a genuine, hardy, and justified opposition to the current status quo in the regulatory space, but there is a reality to deal with and if we’re going to engage in civil disobedience we need to be very clear that that usually ends up with people in jail and significant legal fees. It is unlikely that everyone using the NNS has that level of buy-in and it seems…unfair?..maybe even unethical? To drag people into that that don’t know what they are getting into.


There are many questions wrapped up in that. I personally think there are valid concerns but am under the impression that the legal side has been sweated through extensively by people who know that stuff. I am not a lawyer and would be happy if someone who is could deal with that side of life for me. For ever. :slight_smile:

I am under the impression that SNS parameters should be flexible enough to cover both non-profit and for-profit use cases. Maybe for starters it would be good to find examples of each and find ways of making it super-clear what kind of financial vehicle each SNS is, in each jurisdiction, so that people have a good idea of what they are dealing with. Charities look for donors, so I don’t believe that not-for-profit implies that an SNS may not have funds to do stuff. But maybe there is something simple such as “no maturity” => not for profit in most/all jurisdictions and can be marked as such. For sure, a “no funds involved whatsoever” SNS could also be a category and I can easily see lots of things fitting in there but not by any means all.

Yes, I want freedom, but with capabilities and a solid trust model.


“I personally think there are valid concerns but am under the impression that the legal side has been sweated through extensively by people who know that stuff.”

Could these people express themselves and defend their opinion on the forum? I dont know anything about law and regulations, but it seems like skilesare’s points are legit.

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Like you, I would also be happy if this can been explained by the legal side.

Until then, the prudent defensive posture for me in my opinion, as a US citizen, is for my neurons to follow ICDev as long as they vote NO(Reject) on all SNS and Community Fund proposals as well as any token swap functionality.

Yeah, I may not agree with all of your views on topics related to the IC @skilesare, and I at times (even now) want to push back on your leadership styles. I agree and will be following you only on these topics. I do appreciate you posting this. I have been concerned with the flags you’ve raised in several threads. It led me to do my own research on “what the heck you were going on about”. That rabbit hole was equally as important as seeking a tax advisor. Because I feel you are right on the money with these issues (for us in the areas where it could be seen as a risk). This was something that is not going to be on the surface for many newer users or investors. Not sure how many will want to spend the time sifting through/ paying for legal opinions for these exact reasons.

If I could flag this for ALL newer USA users just entering the IC rabbit hole with neuron ownership I would.

Again, thank you for posting and making this abundantly clear for everyone

EDIT: For newer users who may have a hard time re-sifting and finding the correct topics spoken of I wanted to just put in a list here because I personally struggled re-sifting while selecting on the NNS dapp itself lol

Topic 1: Reject” on all SNS and community fund topics.

Topic 2: “Reject” updates on the Network(System) Canister Management topic proposals for canister qoctq-giaaa-aaaaa-aaaea-cai (NNS front end)

for transparency, I will only be following your neuron on the Network (system) canister management topic to avoid confusion and peace of mind. I personally, will manually “Reject” all SNS and community fund topics from this point forward.

Thanks again

Thank you for being upfront about your voting position.
I have chosen to retract my 25k neuron vote power from your voting pool.


I don’t understand why you are voting reject. The logic of what you said above is to abstain from voting.

We have to vote to get rewards.It is a moral dilemma and likely am anti-pattern inside the NNS set up that should be studied and corrected. The NNS should generally avoid putting users in a position where they face financial harm due to a regulatory issue. If there was an abstain option we’d certainly use it, but that breaks other things in the NNS.

Quick reminder…everyone can choose who they follow for the SNS and Community Fund proposal topic. It is a separate proposal topic from Governance, so it is not necessary to follow the same entity for both. In fact, it is not even required to follow anyone for SNS and Community Fund. If you believe that the right answer is to abstain on SNS proposal topics and you don’t want any Followee to vote for you, then remove all Followees from that topic. SNS & Community Fund does not fall into the All Topics catch all category, which means unselecting Followees means your neuron will not vote on those topics. You will lose voting rewards for the SNS topic only, which so far has been a rare proposal type.

To clarify, I understand the ICDevs position and see no issue with it. It’s just another opportunity to point out that all of us are empowered to configure our neurons however we feel is best for us. If you want to abstain, then you have the option to make that personal decision and implement the configuration yourself. It is not required to keep the default following for this proposal topic.


I understand that your decisions are more responsible than Dfinity decisions.