How the model is governed

One published rulebook

Everything the model does is set out in one rulebook, published in full and open to anyone to read. It covers:

• how a programme is admitted, and how it can be suspended or leave;
• how conversion rates are agreed, published and changed;
• the collateral and guarantees each programme must hold;
• the settlement timetable between programmes;
• how mistakes are corrected and disputes are heard;
• how the rulebook itself is changed;
• the wind-down plan.

The seven governed roles each answer for their part of it. No single party can both write an entry and approve it.

Collateral is held in trust, apart from the operator’s own assets, so it stays available to the programmes even if the operator fails. The 2002 illiquid-assets filing describes the same protection: assets in a trust that “could be bankruptcy-remote and creditor-protected”.^⁠[1]

Audits and attestations

Independent accountants check the ledger and the collateral. There is a full audit each year, and attestations in between that confirm, as at a stated date, that the collateral held covers what programmes owe each other. Every report is published in full, on the date it is signed.

The auditors can read the whole ledger. They confirm that every point in a member’s account traces back to a programme’s credit, that every conversion used the rate published for that day, and that no point exists twice.

Notice before any change

Nothing changes without notice. A change to a conversion rate, to the rulebook or to what points can be used on is published at least 60 days before it takes effect, with the date it applies and the reason for it.

Every change goes into a public change log, with the earlier wording kept beside it, so anyone can see which rules applied on any date.

No devaluation of points already held

A change never reaches back. Points already in a member’s account keep the use they had when they were collected: a programme can change what new points will do, with notice, but cannot shrink what members already hold.

Points do not expire because time has passed. If a programme closes an account that has been inactive for a long time, it gives notice first, and the member can use or convert their points before it does.

Consumer regulators already look at points this way. The US Consumer Financial Protection Bureau has warned that rewards programmes may act unfairly or deceptively when “they materially reduce the overall value of rewards that consumers have already earned or purchased”, or revoke rewards “based on buried or vague conditions”.^⁠[2] Ontario barred points from expiring “due to the passage of time alone”, and Quebec’s Bill 134, adopted on 15 November 2017, carried substantially similar wording.^⁠[3] In December 2025 Ontario’s legislature was studying a bill that the opposition said could let points expire again and that the government said would not make it easier to take points away.^⁠[4] This model does not wait for the law: the rule is written into the rulebook.

A wind-down plan, published from the start

The model says how it would end before it begins. If the clearing-house ever closed, it would follow these steps, in this order:

1. Members and programmes are told the closing date, at least 90 days ahead.
2. Conversions stop on that date. Points stay in members’ accounts, usable on each programme’s own rewards as before.
3. Programmes settle what they owe each other one last time.
4. The custodian releases collateral only after every final settlement is complete and audited.
5. Each member’s balance in each programme is confirmed, and the final ledger is kept for the auditors.

Nothing a member holds is lost: points remain with the programme that issued them, under its own terms. Lessons shows why this comes first. In the experiments that closed badly, the closing was the moment members lost most.

Corrections and disputes

A mistake is corrected by a new, signed entry that reverses it; the original stays on the ledger, so the correction can be seen. A member who disagrees with an entry asks their programme first, and can take it to the independent dispute body the rulebook names.

Who governs

MarkCrest runs this site and holds the concept, so that the model remains a governed one: published rules, independent checks and no shortcuts. Who would hold each role if the model were ever built is not decided, and no party is named here. About says more about MarkCrest.