Josh Brown, the money manager and bitcoin bear-turned-bull, had some harsh words for initial coin offerings (ICOs) in a new blog post: in his words, the funding model is “where the frauds will take place.”

Writing on his Reformed Broker blog, Brown – who earlier this month told CoinDesk that he thinks ICOs will “blow up in everyone’s face” – reiterated his position, citing the incredulity shared by West Loop Partners general partner Jeff Carter in a new blog post of his own.

He wrote:

“Jeff’s a friend of mine but he comes at these things from a Chicago floor trader – turned angel investor’s mentality. I come at these things from a reformed stock broker’s perspective. We don’t always see eye to eye but, in this case, we’ve arrived at exactly the same place. ICOs are where the frauds will take place.”

He blasted ICO-derived tokens as serving as little more than unregistered securities, stating that, unlike some cryptocurrencies, those pieces of data can only be used in conjunction with a particular app or platform.

“Unlike traditional securities sales, there is no regulation here. I can say that I’m starting a walrus sex ranch and that the digital token I am using to raise the capital will be good for two hours of sex with one of my walruses,” he wrote. “You buy five of my tokens, because you’ve always wanted to make love to a walrus, and this gives you the right to ten hours of unadulterated bliss with my product once I’ve raised enough from maniacs like you to go into operation.”

His comments come as securities regulators around the world more closely scrutinize the ICO model or develop new rules around them. Despite warnings from some governments that token sales may constitute securities offerings, institutional investors have moved in recent months to capitalize on the interest around them by backing dedicated hedge funds or taking part in ICOs directly.

Brown concluded by saying that, from his perspective, overall enthusiasm for the tech or cryptocurrencies in particular shouldn’t preclude a degree of skepticism about ICOs, which to date have generated more than $2 billion in investments, according to data from CoinDesk’s ICO Tracker.

“It’s okay to be bullish or even bull-curious about blockchain and bitcoin without being a credulous, fanatical moron about ICOs. This is where I stand,” he wrote.

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