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.

As I said then...
5/ And now I couldn't be more grateful that they invited me to be part of the team (alongside my continuing full-time role with @compoundfinance). 🙏🎉

The Variant team is still growing, too! Check out current opening on their careers page & come join us:
variant.fund/careers/

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More from @jchervinsky

24 Mar
1/ One interesting piece of Uniswap v3 is its use of Business Source License (BSL) 1.1, which restricts production use for two years.

I see people asking if @Uniswap can really use BSL 1.1 against v3 forks. Answer: yes, mostly, at a cost.

The DeFi + copyright situation 👇 Image
2/ NOT LEGAL ADVICE

(sorry, couldn't resist the reference)

But seriously, I'm not your lawyer. If you have a DeFi copyright issue, hire your own. Don't try to get legal advice from Twitter.
3/ For reasons that I hope are obvious, it's crucial for DeFi protocols to be free & open-source software.

As a result, most DeFi protocols are launched with fully open-source licenses like MIT, BSD, & GPL. Uniswap v2 was released under GPL.

Then Sushi & Pancake happened....
Read 14 tweets
24 Dec 20
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.
Read 5 tweets
23 Dec 20
1/ FinCEN is now accepting public comments on its proposal to extend AML regulation to non-custodial wallets.

The deadline is January 4. We have an unfairly (maybe illegally) short time for this, so we have to use it wisely.

Here's your ultimate guide on submitting a comment 👇
2/ I'll link to the comment form at the end of the thread, but I really want you to read through this first.

Writing a bad comment is worse than none at all. If you don't have time to take this seriously, use a pre-filled form instead (also linked below).
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.

This is worth your time.
Read 15 tweets
19 Dec 20
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.
Read 21 tweets
12 Oct 20
1/ There's been so much regulatory & enforcement news in crypto lately, it's impossible to keep up.

So instead of getting lost in the details, let's step back & consider the big picture. What's really going on here?

In short: an ideological war over self-custody & privacy. 👇
2/ This thread is long but very important.

If you believe in the principles of financial privacy & self-sovereignty at the heart of Bitcoin, as I do, you need to pay attention now.

We've made the world stage, but our biggest challenges still lie ahead.
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.
Read 21 tweets
28 Sep 20
1/ Great question.

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).
Read 14 tweets

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