1/ I'm thrilled to announce that I'm joining the @variantfund team as a strategic advisor!
@jessewldn & @spencernoon are two of the most insightful, hardworking, & effective investors in crypto. I'm beyond excited to help them & their founders build out the Ownership Economy. 🔥
2/ I've been a huge fan of Jesse's work for a long time, especially since he wrote the definitive playbook on "progressive decentralization" in January 2020.
This piece has become a cornerstone of protocol development strategy across the entire industry: a16z.com/2020/01/09/pro…
3/ When he started Variant, I was deeply impressed with his Ownership Economy thesis—the idea that the *users* of a network should be the *owners* of that network, instead of being productized & exploited by rent-seeking companies (the typical Web2 model). variant.fund/the-ownership-…
4/ So it was no surprise when Spencer, another of the sharpest & most forward-thinking minds in crypto, joined up as a partner in December. If you have any interest in DeFi & you aren't subscribed to @ournetwork__, you're doing it wrong.
It's extremely unlikely that changes in SEC leadership will have any impact on the Ripple case.
Given Comm'r Peirce's conspicuous silence, I'd guess the vote was unanimous in favor of filing.
Regardless, the case is being prosecuted by enforcement lawyers who are here to stay.
To clarify the point re: Comm'r Peirce, she's often vocal when she disagrees with her colleagues on enforcement (e.g., Kik, Unikrn).
That she hasn't commented may suggest she approved. OTOH, it may be inappropriate to speak up while charges are pending, so it might mean nothing.
Even so, she's the only one who's shown interest in voting not to approve crypto enforcement actions. You can see the results of Commission votes on district court actions here (after they're resolved): sec.gov/about/commissi….
You'll struggle to find "no" votes other than hers.
3/ First, let me assure you that public comments do matter.
A LOT.
Agencies have to read & respond to the substance of every single one. Your voice will be heard. It might change minds on the other side. Even if not, it still might slow them down.
1/ After a long wait, FinCEN has finally issued its new proposed rule extending AML regulation to non-custodial wallets.
It could've been worse (really), but it's still a terrible rule in both process & substance.
Here's what it says, what's wrong with it, & what we do next 👇
2/ The rule would impose new obligations on virtual asset service providers (VASPs) like exchanges & custodians.
For deposits & withdrawals > $3k involving a non-custodial wallet, VASPs would have to record the name & physical address of the wallet owner. home.treasury.gov/news/press-rel…
3/ VASPs would also have to report any deposit or withdrawal > $10k to FinCEN in the form of a currency transaction report (CTR).
FinCEN says these requirements are necessary to "combat the financing of global terrorism," "address transnational money laundering...." You get it.
3/ Crypto market infrastructure has improved dramatically in recent years.
It's now quite easy for most people to convert fiat into crypto, withdraw any amount to their own wallet, & then do as they wish without restriction or identification, subject only to the consensus rules.
The short answer (not legal advice) is the money probably gets bailed-in just like other deposits at the failed bank & no special dynamics protect stablecoin holders, afaik.
The longer answer requires looking at the relationships between all the parties . . .
2/ First, you have the stablecoin issuer & the bank custodying its reserve; is there anything special here to protect against a bail-in?
Second, you have the stablecoin issuer & the stablecoin holders; is there anything special here to give holders recourse in case of a bail-in?
3/ The best place I can think of to look for insight on these questions is in the terms, conditions, & disclosures of the issuers' whitepapers, user agreements, & attestations (links at end of thread).