> When there is about $100.00 USD in BAT for a

> specific publisher, from all contributors, Brave

> makes three attempts to complete the publisher

> verification process. We will hold unclaimed

> funds for a minimum of 90 days, after which it

> will be added to the UGP (User Growth Pool).

They also claim that "This new ability will especially benefit YouTube creators who have under 10,000 lifetime views, as they do not receive ad revenue from YouTube". This claim of benefitting smaller creators seems very suspect.

Brave doesn't publish full user numbers, but some quick napkin math based on their 13,000 Android app reviews vs Chrome's 8,000,000 leads me to estimate < 2,000,000 users. There are 1,000,000,000 Youtube users according to https://www.youtube.com/yt/about/press/. Assuming the average channel with < 10,000 lifetime views has < 100 subscribers, and assuming a uniform distribution of Brave users over channels, the average channel only has a 20% chance of having _1_ Brave donator. Even if they have 3 people donating $10 worth of BAT per month, they won't be contacted, because they will only get $90 within the 90-day withholding window. Brave then confiscates those donations and feeds it into their "User Growth Pool".

Of course, I made a lot of assumptions / back of the envelope math here due to a lack of data (it's possible that Brave users tend to congregate towards certain kinds of channels, and therefore those channels are more likely to break the 3 donator threshold), but I think the point is reasonable.

There's a simple way to fix this: if funds are unclaimed within 90 days, they should be _returned_, not confiscated. And if one of my assumptions is wrong, then prove it: Brave should release information about what percent of user donations are being used towards the UGP instead of being claimed by creators.