NateWebb03 / FilTestRepo

A test repository for allocator application automation
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Test app 1071 #1073

Open NateWebb03 opened 5 months ago

NateWebb03 commented 5 months ago

Notary Allocator Pathway Name:

FBG Allocator

Organization:

FBG Capital

Allocator's On-chain addresss:

f1zffqhxwq2rrg7rtot6lmkl6hb2xyrrseawprzsq

Country of Operation:

Singapore

Region(s) of operation:

Africa ,Asia minus GCR,Greater China,Europe,Oceania,Japan,North America,South America

Type of allocator: What is your overall diligence process? Automated (programmatic), Market-based, or Manual (human-in-the-loop at some phase). Initial allocations to these pathways will be capped.

Market-based

Amount of DataCap Requested for allocator for 12 months:

150PiB

Is your allocator providing a unique, new, or diverse pathway to DataCap? How does this allocator differentiate itself from other applicants, new or existing?

The FBG allocator is designed to simplify the data onboarding process for clients with following features: 1.Ease of Use: By providing a series of onboarding training sessions and efficient data preparation and deal-making tools, we can significantly reduce the technical barriers for clients.. 2.Data Monitoring: The allocator will track and record the data resources used by each applicant. DataCap can stay informed of the progress of each applicant's application and make necessary adjustments and optimizations as needed.

As a member in the Filecoin Community, I acknowledge that I must adhere to the Community Code of Conduct, as well other End User License Agreements for accessing various tools and services, such as GitHub and Slack. Additionally, I will adhere to all local & regional laws & regulations that may relate to my role as a business partner, organization, notary, or other operating entity. * You can read the Filecoin Code of Conduct here: https://github.com/filecoin-project/community/blob/master/CODE_OF_CONDUCT.md

Acknowledgment: Acknowledge

Cient Diligence Section:

This section pertains to client diligence processes.

Who are your target clients?

Individuals learning about Filecoin,Small-scale developers or data owners,Enterprise Data Clients

Describe in as much detail as possible how you will perform due diligence on clients.

In general, the higher the DataCap thresholds are, the more restricted the client scrutiny would be. For individual clients, online identity will be verified by both account age and account activity perspectives, and this will serve to prove that they are valid users and not bots or sybils. Third-party tools like twitteraudit may also be used to verify online identities.

For organizational clients, application organizations should be easy to verify through the appearance of their application. The developing applications may require further stringent investigation; this is to ensure that the application is valid and enclosed with meaningful content, rather than the shell of a malicious client. Large public datasets hosted by organizational clients are easy to verify because the data should be unencrypted and accessible to anyone. However, in the event that the organizational client has large private encrypted datasets(i.e., law firms), the Due Diligence procedure will be executed.

Below is the proposed procedure of Due Diligence. We need 3 types of information for review by myself or our compliance team depending on the volume of clients required Due Diligence:

  1. Entity Information
    • Formation documents - this includes certificates of registration/incorporation/information;
    • government-issued identification number for the entity
  2. Authorized Signatory Information
    • evidence of the authorized signatory’s authority to act on behalf of the application entity (evidence include written consent of the company board of directors, or a secretary’s certificate, a signed letter from the applicant’s CFO, or may be included in the company operation agreement);
    • close-up photo of the signatory’s face next to the visible passport or other government-issued photo-bearing ID
  3. Beneficial Owners - If there are any 25%+ shareholders, we need a document as a capitalization table, operating agreement, or similar to verify the ownership, and also the following information for each of them:
    • legal name;
    • date of birth;
    • street address (P.O. box number is not acceptable);
    • a government-issued identification number, which shall be either an SSN, ITIN, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence;
    • copy of an unexpired passport or other government-issued document evidencing the individual's nationality or residence which bears a photograph of the individual.

Please specify how many questions you'll ask, and provide a brief overview of the questions.

Questionnaire #1 Please describe answers as much specificity as you can.

  1. Can you introduce yourself? Where can I find you online? (Github, Twitter, Linkedin handle, Wechat, etc.)
  2. If you represent an organization, what is the name, nature, registration country, time since inception, and named officers of your organization?
  3. In which region(s) do you intend to use the DataCap?
  4. What is your use case for the DataCap being requested?
  5. Do you plan to specify advanced features when utilizing a DataCap in your storage deal? If so, please specify the feature.
  6. How many miners do you plan on allocating the DataCap? If you have a specific miner(s) you would like to allocate a DataCap, please specify.
  7. Do you agree on providing transparency of DataCap allocation decisions & execution details in public to prevent excessive/unfair self-dealing?

Questionnaire #2 Since you have requested DataCap from me before, I have some questions regarding your previous DataCap allocation.

  1. How much cumulative DataCap was allocated to you from me?
  2. In which region(s) did you use the DataCap?
  3. What was your use case for the previous allocation?
  4. Did you specify any advanced features for the previous allocation?
  5. How many miners did you allocate the DataCap to? Please specify transaction links to the storage deals.
  6. In your previous allocation, did you violent any community principles like excessive/unfair self-dealing?
  7. Is there anything I could improve to serve you better in future allocations?

Will you use a 3rd-party "Know your client" (KYC) service?

Yes, we will employ reputable third-party KYC service to ensure the eligibility of our clients, check against known sanctions lists, and mitigate the risk of Sybil attacks

Can any client apply to your pathway, or will you be closed to only your own internal clients? (eg: bizdev or self-referral)

Any client can apply. We will post the process of applying to us to make it easier for applicants to participate; Also, we have a professional technical team for technical support to solve the problems that clients may face in the process.

How do you plan to track the rate at which DataCap is being distributed to your clients?

Our approach to tracking DataCap distribution combines real-time monitoring with transparency and accessibility. We leverage our expertise as maintainers of DataCap (DC) tracking tools, ensuring accurate and up-to-date information on DataCap usage for each client.

Data Diligence

This section will cover the types of data that you expect to notarize.

As a reminder: The Filecoin Plus program defines quality data is all content that meets local regulatory requirements AND • the data owner wants to see on the network, including private/encrypted data • or is open and retrievable • or demonstrates proof of concept or utility of the network, such as efforts to improve onboarding

As an operating entity in the Filecoin Community, you are required to follow all local & regional regulations relating to any data, digital and otherwise. This may include PII and data deletion requirements, as well as the storing, transmitting, or accessing of data.

Acknowledgement: Acknowledge

What type(s) of data would be applicable for your pathway?

Public Open Dataset (Research/Non-Profit),Public Open Commercial/Enterprise,Private Commercial/Enterprise,Private Non-Profit/Social Impact

How will you verify a client's data ownership? Will you use 3rd-party KYB (know your business) service to verify enterprise clients?

For public dataset, we will ask clients to provide source information, including the name of the dataset, which website the dataset is located at, and the team to which the data is belonging to. For private dataset, we will ask the client to show data sample and provide the proof of their store. After we confirm that the data is reasonable and legitimate, we will grant DataCap for the client. For enterprise data, we will use 3rd party KYB to verify the client's corporate identity and ask the client to show data sample and provide the proof of their store. After we confirm that the data is reasonable and legitimate, we grant DataCap for the client.

How will you ensure the data meets local & regional legal requirements?

Through rigorous customer due diligence Conduct an assessment of the legal and policy environment in the location to reduce the loss of data protection caused by legal uncertainty, in order to ensure the legality and compliance of data in the location.

What types of data preparation will you support or require?

We have a technical team to support data packing services for our clients. We use tools to cut, pack, and compress the data provided by the client. These files are then converted to car files; We also support working with DP, DP will pack the qualified files and send them to client, and then the client will send the package to SP for sealing.

What tools or methodology will you use to sample and verify the data aligns with your pathway?

The process involves comparing the data with its metadata, including size, to ensure that the sectors store exactly what they claim to. This comparison aims to prevent padding abuse within a reasonable percentage, as well as avoiding duplications and enlargements of the data.

Data Distribution

This section covers deal-making and data distribution.

As a reminder, the Filecoin Plus program currently defines distributed onboarding as multiple physical locations AND multiple storage provider entities to serve client requirements.

Recommended Minimum: 3 locations, 4 to 5 storage providers, 5 copies

How many replicas will you require to meet programmatic requirements for distribution?

5+

What geographic or regional distribution will you require?

3 or more physical locations. 3 or more separate geopolitical regions. We will not exclude any geopolitical regions besides the regions that are illegal for a United States entity to work with.

How many Storage Provider owner/operators will you require to meet programmatic requirements for distribution?

5+

Do you require equal percentage distribution for your clients to their chosen SPs? Will you require preliminary SP distribution plans from the client before allocating any DataCap?

We require a detailed distribution plan from the client. Before the client's first round allocation, we will ask clients to fill out the form we provide. The form will contain the percentage of clients allocated to different SPs and the KYB information of the SPs. We will ask our clients to follow the distribution plan they provide.

What tooling will you use to verify client deal-making distribution?

Yes, we will use existing open-sourced tools AC Bot, CID Checker, and DataCapstats.io to check the distribution of our clients' transactions. We will check clients distribution from time to time after their first allocation. Then we will do automatically check and report on client deal-making distribution prior to subsequent allocations.

How will clients meet SP distribution requirements?

We will check through CID checker tool and check the geographic location of the SP.If we find problems, we will inform them in time, so that their subsequent operations will meet the SP distribution requirements.

As an allocator, do you support clients that engage in deal-making with SPs utilizing a VPN?

We are willing to support clients who work with SPs that use VPN. We understand that VPN are tools for SPs in some areas that can help them improve privacy and security. We will do KYB checks on each SP using VPN to confirm the reasons for SPs using VPN and their compliance, to ensure data security as well as distribution compliance.

DataCap Allocation Strategy

In this section, you will explain your client DataCap allocation strategy.

Keep in mind the program principle over Limited Trust Over Time. Parties, such as clients, start with a limited amount of trust and power. Additional trust and power need to be earned over time through good-faith execution of their responsibilities and transparency of their actions.

Will you use standardized DataCap allocations to clients?

Yes, standardized

Allocation Tranche Schedule to clients:

• First: 25% of requested datacap • Second: 25% of requested datacap • Third: 25% of requested datacap • Fourth: 25% of requested datacap • Max per client overall: Client and dataset specific

Will you use programmatic or software based allocations?

Yes, standardized and software based

What tooling will you use to construct messages and send allocations to clients?

filplus.storage for initial application intake. Lotus binary to issue datacap. Lassie to verify data content.


Describe the process for granting additional DataCap to previously verified clients.

When a client makes a request for additional DataCap, we will confirm the amount of demand from the client first. And use the open-source tool --- SA Robot to get a report on the client's DataCap usage to check the client's usage of the previous DataCap. When the client is using 80% of the DataCap, and upon our confirmation that the client's behavior complies with filecoin's rules, we will continue to grant DataCap to our clients. The amount of DataCap is consistent with previous allocation.

Tooling & Bookkeeping

This program relies on many software tools in order to function. The Filecoin Foundation and PL have invested in many different elements of this end-to-end process, and will continue to make those tools open-sourced. Our goal is to increase adoption, and we will balance customization with efficiency.

This section will cover the various UX/UI tools for your pathway. You should think high-level (GitHub repo architecture) as well as tactical (specific bots and API endoints).

Describe in as much detail as possible the tools used for: • client discoverability & applications • due diligence & investigation • bookkeeping • on-chain message construction • client deal-making behavior • tracking overall allocator health • dispute discussion & resolution • community updates & comms

• client discoverability & applications GitHub • due diligence & investigation https://www.yushanshuju.com/index.html ; https://www.x315.cn/overseasreport • bookkeeping GitHub, Own website(pangodbook.com), TecentSheet • on-chain message construction Ledger; https://filplus.fil.org/#/ • client deal-making behavior AC Bot, CID Checker, DataCapstats.io • tracking overall allocator health DataCapstats.io, Filfox • dispute discussion & resolution Slack, GitHub, Email • community updates & comms * Slack, GitHub, Email

Will you use open-source tooling from the Fil+ team?

Yes. We'll use open-source tools, such as AC Bot, CID Checker, Filecoin Plus These open source tools can help follow customers' DataCap usage in real time. Also, GitHub will be used for booking.

Where will you keep your records for bookkeeping? How will you maintain transparency in your allocation decisions?

We will maintain our distribution and client information in both public and private ways. We will show our allocation policy and records for DataCap openly on GitHub. All records are automatically updated real-time as they are allocated by us. Enable anyone of the community to monitor and point out potentially problems. Identity information provided by the client, along with allocation information that we are required to keep confidential, will be stored in a private database built by our company.

Risk Mitigation, Auditing, Compliance

This framework ensures the responsible allocation of DataCap by conducting regular audits, enforcing strict compliance checks, and requiring allocators to maintain transparency and engage with the community. This approach safeguards the ecosystem, deters misuse, and upholds the commitment to a fair and accountable storage marketplace.

In addition to setting their own rules, each notary allocator will be responsible for managing compliance within their own pathway. You will need to audit your own clients, manage interventions (such as removing DataCap from clients and keeping records), and respond to disputes.

Describe your proposed compliance check mechanisms for your own clients.

We will track the datacap distribution using the CID checker bot. As long as the client has good communication of any blockers or issues, we will be understanding of their demographic choices and time metrics. Trust evaluations are done at the start and checked between datacap tranche allocations.

Describe your process for handling disputes. Highlight response times, transparency, and accountability mechanisms.

When our clients use violations or have serious abuses, we respond within 48 hours. First, we will submit a dispute, and we will notify the community not to continue to allocate datacap to this organization or individual. Second, we will collect disputed data content or reports and disclose them to the community in a timely manner. Then we will ask fil+ team and neutral parties in the community to check and give reasonable opinions. If we did not investigate clearly and were deceived by a client, we will make a review. And will promptly recover the allocated DC. This organization or individual will be reported to the blacklist of the community, and will not be allocated DC in the future.

Detail how you will announce updates to tooling, pathway guidelines, parameters, and process alterations.

Certain material programmatic changes or updates may be deemed out of scope by the Fil+ Governance Team, and may require a reapplication to be scored against the rubric. For example, an 'update' from a single automated diligence process to include a new manual process may require a new notary allocator application.

How long will you allow the community to provide feedback before implementing changes?

We allow one month for the community to provide feedback before changes are implemented. It will give the community enough time to voice their opinions. We will also post pending updates on our website, GitHub, and slack, and engage in interactive discussions with the community to ensure changes are possible.

Regarding security, how will you structure and secure the on-chain notary address? If you will utilize a multisig, how will it be structured? Who will have administrative & signatory rights?

We use a multisig that has multiple signers with a threshold >2. Only these signers will have administrative and signatory rights after approval to sign has reached a consensus and approved.

Will you deploy smart contracts for program or policy procedures? If so, how will you track and fund them?

We will not be deploying smart contracts.

Monetization

While the Filecoin Foundation and PL will continue to make investments into developing the program and open-sourcing tools, we are also striving to expand and encourage high levels of service and professionalism through these new Notary Allocator pathways. These pathways require increasingly complex tooling and auditing platforms, and we understand that Notaries (and the teams and organizations responsible) are making investments into building effective systems.

It is reasonable for teams building services in this marketplace to include monetization structures. Our primary guiding principles in this regard are transparency and equity. We require these monetization pathways to be clear, consistent, and auditable.

Outline your monetization models for the services you provide as a notary allocator pathway.

If the clients do not have the DP's ability to prepare the data themselves. If they need us to help them with data preparation services, they need to pay us a data fee of 10USDT/TiB. If clients need us to help send the hard drive to SPs, we will charge them for the courier fee. Also, we'll ask for a labor fee of 80USDT/day. Our fees are set to cover the cost of the services we provide, the cost of labor and to ensure that we can maintain a high quality and sustainable service.

Describe your organization's structure, such as the legal entity and other business & market ventures.

FBG Capital is Asia’s leading digital asset management and investment firm. We started Filecoin mining back in 2020. As of Feb 2022, we have data center setup in Singapore and North America. We are dedicated to supporting the whole Filecoin ecosystem. We’ve invested a few Filecoin eco projects & funds, such as CID Gravity, FilSwan and Fenbushi Capital. We’re also planning to set up a stand-alone Filecoin eco fund to further support the Filecoin eco projects.

Where will accounting for fees be maintained?

Regarding the service fee, we will have a Filecoin payment address, and the payment at this address will be publicized on the chain. We will help clients to calculate the staking, burning or release mechanism, and let them notify the cooperating SPs to prepare so that the project can continue to operate. Regarding audit monetization, we will disclose the reasons for each income and expenditure to the community when necessary.

If you've received DataCap allocation privileges before, please link to prior notary applications.

https://github.com/filecoin-project/notary-governance/issues/458, https://github.com/filecoin-project/notary-governance/issues/722

How are you connected to the Filecoin ecosystem? Describe your (or your organization's) Filecoin relationships, investments, or ownership.

We started Filecoin mining back in 2020. As of Feb 2022, we have data center setup in Singapore and North America. We are dedicated to supporting the whole Filecoin ecosystem. We’ve invested a few Filecoin eco projects & funds, such as CID Gravity, FilSwan and Fenbushi Capital. We’re also planning to set up a stand-alone Filecoin eco fund to further support the Filecoin eco projects.

How are you estimating your client demand and pathway usage? Do you have existing clients and an onboarding funnel?

We have worked with many clients. We keep in touch with our existing clients through meetings and emails, and we regularly do online and offline activities, to bring in new clients.