Trust · Tokens
HCR & HCC — what we believe, what we're confirming, what we don't claim.
Conceptual Health® operates two tokens on Conceptual Chain. HCR (HEALTHCOIN™) is patient-mined via verified health actions. HCC (Conceptual Healthcare Coin) is work-mined via clinical encounters, engineering merges, compliance attestations, IP filings, research milestones, and verified compute. The posture below is what we believe about classification under U.S. federal and Florida state law, what we're still confirming with counsel, and what we explicitly do not claim. Last reviewed by counsel: 2026-05-16. Posture v1.0.
Four operating principles
Constitutional, not marketing.
1 · We never sell the tokens.
Conceptual Healthcare Corporation does not sell HCR or HCC for fiat to anyone, ever. The Company's only on-network revenue is a 0.5% protocol settlement fee — 80% to the Sustainability Pool, 20% to the Protocol Fee Treasury. No founder reserve. No advisor reserve. No unsold Company tokens.
2 · Each token has a 21-billion hard cap.
HCR: 21,000,000,000 units, halving on patient-count milestones (10k / 50k / 250k / 1M / 5M / 25M). HCC: 21,000,000,000 units, mined through verified work events. The cap is in the protocol, not in marketing copy — see the whitepaper §4 for the schedule.
3 · No investment framing on any surface.
No "buy," no "invest," no "price target," no "guaranteed yield" appears on any patient, provider, or partner surface — by editorial review and by automated content scan before every release. The HC.exchange marketplace exists; pricing reflects supply and demand on that book, not a corporate guarantee.
4 · Each transfer is screened.
Every token transfer is OFAC-screened before mint. Sanctioned jurisdictions are blocked; transfers attempting to cross sanctions are held or forfeited with a public board notation. KYC is required for all participants in mining or transfer flows.
Pre-launch supply, honestly
What's actually minted today — and which part is test data.
The hcc_mining_events ledger currently holds 211 events totaling 1,211.91 HCC (0.0000058% of the 21B cap). That number is the simple sum the public provenance endpoint returns, and we publish it as-is. But it isn't all real economic activity yet — we are pre-launch, and three categories sit inside it:
- Treasury — 7 events · 124.00 HCC. Genesis seeding to wallets matching
0xHCC_CORP_TREASURY_*, written 2026-05-07. - Organic small mints — 16 events · 15.98 HCC. Sub-1-HCC reward events from real workflow exercise.
- Pre-launch test bulk — 188 events · 1,071.93 HCC. Large mints (≥1 HCC each) across two developer wallets, written 2026-04-21 through 2026-05-25 to exercise the mining write path. Not real economic activity.
The chain is append-only, so we don't delete the test bulk; we document it. The full disclosure is chain-stamped at audit_logs sequence #24732 — read the row, verify the chain holds, draw your own conclusions. The public provenance endpoint at /api/v1/admin/provenance/hcc.minted_total now returns a per-bucket breakdown alongside the simple total, and a new /api/v1/admin/provenance/hcc.minted_clean entry returns the treasury + organic total with the test contribution explicitly subtracted (139.98 HCC today).
Once the platform reaches a paying-clinic milestone and production volume meaningfully exceeds the test contribution, we'll consider a chain-stamped "genesis cutover" record that splits pre-launch test data from production volume in the public reporting. Until then, this is the honest number: a few hundred HCC of real exercise, a few thousand HCC of dev-wallet practice, all six orders of magnitude under the cap.
Posture summary
Five regulators, five postures, one document.
| Regulator | What we believe | Status |
|---|---|---|
| CFTC | Both tokens are digital commodities under 7 U.S.C. § 1a(9). Dual-track posture: conservative fallback obeys both CFTC and SEC ceilings if jurisdiction is contested. | Primary |
| SEC | Out of scope. Howey analysis fails prongs 1, 3, and 4; no common enterprise fails prong 2. Detailed prong-by-prong below. | Believe out-of-scope |
| FinCEN | Convertible-Virtual-Currency administrator analysis underway. State-by-state Money Transmitter License matrix in progress. | Confirming |
| IRS | Ordinary income at fair market value on receipt. W-2 for employees, 1099-NEC for contractors and patients above §6041 threshold, W-8BEN/W-8BEN-E for non-U.S. participants. | Posture set |
| FLSA / FL wage | Employees are paid cash USD at or above federal and Florida minimum wage. HCC is supplemental work-credit, never wage replacement. | Posture set |
SEC · Howey
Prong by prong. Out of scope on three.
Prong 1 — Investment of money. Patients do not pay to receive HCR; they earn it by performing verified health actions. Work-miners do not pay to receive HCC; they earn it by performing verified work. Fail.
Prong 2 — Common enterprise. A patient's HCR balance is a function of that patient's own behavior, not the pooled fortunes of other patients. There is no horizontal or vertical commonality required by SEC v. Howey or its progeny. Fail.
Prong 3 — Expectation of profits. No surface marketed to patients, providers, or partners frames either token as an investment, a profit opportunity, or a yield instrument. Fail.
Prong 4 — From the efforts of others. A patient's HCR is mined by that patient. A work-miner's HCC is mined by that miner. The "others" who would generate profit do not exist. Fail.
All four prongs fail, so we believe neither HCR nor HCC is a security under federal law. We will update this page if counsel's view changes.
IRS · Tax treatment
Ordinary income, on receipt, at fair market value.
The IRS treats cryptocurrency received for services as ordinary income at fair market value on the date of receipt. We apply this consistently across recipient types:
- U.S. employee — W-2, with FICA and FUTA withholding.
- U.S. contractor — 1099-NEC above the §6041 threshold.
- U.S. patient — 1099-MISC if aggregate annual receipt meets the threshold, for verified healthy actions.
- Bug researcher — 1099-NEC (self-employment income).
- Non-U.S. recipient — W-8BEN or W-8BEN-E on file; no U.S. withholding unless income is ECI or FDAP.
If a tax treatment table here ever disagrees with the IRS's official guidance, the IRS's guidance controls — write to counsel@conceptualhealth.com with the citation and we'll update.
FinCEN · Money-transmission
CVC-administrator analysis underway.
FinCEN treats a Convertible-Virtual-Currency administrator that accepts CVC from one party and transmits it to another as a money services business under 31 CFR 1010. We are completing the analysis of whether our network architecture brings the corporation within that definition, and in parallel building a state-by-state Money Transmitter License (MTL) matrix so that, if registration is required, we register before flipping the switch — not after. NMLS records will be published here once issued.
OIG · Federal-program inducement
Medicare and Medicaid beneficiaries: preventive-care carve-out only.
The Anti-Kickback Statute and the Civil Monetary Penalty rules against inducement to a federal-program beneficiary are taken seriously. Medicare and Medicaid beneficiaries earn HCR rewards only via the preventive-care carve-out (42 CFR 1003.110) — for example, completing an annual wellness visit or filling a preventive-medication refill on schedule. No reward for choosing a particular provider, plan, or treatment. The full list of permitted-action codes is published in the Medicare/Medicaid compliance page.
What we don't claim
A short list. Read it twice.
- HCR and HCC are not bank deposits. The Sustainability Pool is not a depository institution.
- HC.exchange is not a registered national securities exchange and does not claim to be.
- Neither token is a security, a futures contract, a stable coin, a memo for fiat, or a claim against the Company's assets.
- No promise of redemption against fiat. No promise of liquidity. No promise of future exchange value.
- No partner, vendor, or counterparty has authority to make claims on our behalf that contradict this page. If you see one, write counsel@conceptualhealth.com.
Contact
Counsel reads every regulator inbox.
Counsel: counsel@conceptualhealth.com
Compliance: compliance@conceptualhealth.com
NDA-gated regulator access: regulator portal
If you're a regulator and any posture above is materially incorrect, please write — we'd rather correct the page today than litigate the position tomorrow.