VI. Risks & Honest Assessment
Technical Risks
Risk: AI Model Performance
Our credit models may:
- Produce higher default rates than predicted
- Perform poorly for certain demographic groups
- Fail to generalize from copilot users to general population
Mitigation:
- Start with traditional credit + AI hybrid
- Conservative initial underwriting
- Continuous monitoring and retraining
- Large insurance reserves
- Gradual scaling only when models prove out
Reality: We won't know if AI credit scoring works until we lend real money. Models that work in simulation often fail in production.
Risk: Smart Contract Vulnerabilities
Bugs in smart contracts could lead to:
- Loss of user funds
- Manipulation of loan terms
- Protocol exploitation
Mitigation:
- Multiple security audits (Trail of Bits, OpenZeppelin, etc.)
- Bug bounty program ($50k-100k rewards)
- Gradual rollout (start with small amounts)
- Emergency pause mechanisms
- Insurance coverage for smart contract failures
Reality: Even audited contracts have bugs. We'll likely have issues; question is whether we catch them before major damage.
Regulatory Risks
Risk: Banking License Challenges
Regulators may:
- Deny or delay bank acquisition approval
- Impose restrictions on lending operations
- Require higher capital reserves than planned
Mitigation:
- Experienced banking compliance team
- Proactive regulatory engagement
- Multiple acquisition targets identified
- Backup plan (state-by-state licensing)
- Willingness to start slower/smaller than hoped
Reality: Banking regulation is conservative. We may face delays, additional costs, or operational restrictions we haven't anticipated.
Risk: Token Classification as Security
If SEC determines DREAM is a security:
- Community sale becomes more complex/expensive
- Ongoing registration and reporting requirements
- Potential enforcement action if launched improperly
Mitigation:
- Securities law counsel from day 1
- Utility-first design
- International token launch structure if needed
- Willingness to register as security if required
- Focus on legitimate utility, not speculation
Market Risks
Risk: Insufficient User Adoption
Copilot may not:
- Attract enough users
- Generate sufficient viral growth
- Retain users long-term
- Provide useful data for underwriting
Mitigation:
- Continuous product improvement
- User feedback and iteration
- Marketing spend if needed (not $0 CAC forever)
- Pivot if copilot approach doesn't work
Reality: Product-market fit is never guaranteed. Many fintech apps have failed to achieve scale despite seeming useful.
Risk: Higher Default Rates Than Expected
Actual defaults may exceed projections due to:
- Model failures
- Adverse selection (worst borrowers seek us out)
- Economic downturn
- Fraud
Mitigation:
- Conservative initial rate pricing
- Large insurance reserves (10% of tokens)
- Dynamic rate adjustments
- Rigorous fraud prevention
- Acceptance that some losses are inevitable
Reality: Default rates will likely be higher than modeled, especially early on. Question is whether they're manageable or fatal.
Competitive Risks
Risk: Incumbent Response
Large banks could:
- Launch competing AI copilots
- Lower their rates to match ours
- Lobby for regulations that disadvantage us
- Acquire us before we scale
Mitigation:
- Move fast to build moat
- Focus on community ownership (can't replicate)
- Build brand loyalty and network effects
- Have strong governance to resist acquisition pressure
Reality: Incumbents have more resources and political power. They may not let us scale without a fight.