1/ I’VE BEEN THINKING, while doing yard work, abt the #crypto crash & Fathers’ Day. They both relate to one of the biggest lessons my late dad taught me, which came from my grandpa (an 8th grade educated Iowa farmer who had a PhD in common sense). He scoffed at “paper wealth.”
2/ For context, my dad—his oldest child—was born just days after the 1929 stock mkt crash. Grandpa watched as some neighbors, who had leveraged their farms to play the roaring ‘20s stock mkt, lost them in the crash. Grandpa died before I was born but Dad passed his wisdom to me.
3/ That paternal nugget of common sense influenced my studies of finance & economics in school, in work, in reading history & in my journey of studying the whole range of economic schools of thought after the 2008 financial crisis. Applying it to today, what Grandpa observed…
4/ …was the dangers of the siren song of debauching one’s balance sheet to make a quick buck in rising financial mkts. There are debauched balance sheets all over #crypto right now (& in #tradfi too). It’s not just in leveraged lending, #rehypothecation, #nakedshorting, etc.
5/ It’s also in derivatives. Studying what happened with #stETH, that’s a complex derivative akin to a “loose cannon on the deck of the world, amid a tempest-tossed era” (Hoover’s quote from 1931).
The cleanse is painful but healthy. Satoshi didn’t gift humanity with #bitcoin…
6/ …only to see its trading mkts leveraged in the way they have been since ~2017. #Bitcoin is equity-based money that has no issuer, so it has no balance sheet to debauch (unlike debt-based money). That’s what makes it different—no counterparty, but ONLY if you self-custody it.
7/ What we learn in leverage flushes is that counterparty insolvencies were always there, but it’s usually not until a liquidity crunch comes that they’re revealed for all to see.
Be careful.
Happy Fathers’ Day to all the dads. Thanks for all you do & the wisdom you impart!🙏
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1/ NEW ARTICLE abt why USD-collateralized #stablecoins shld be backed 100% by cash deposited at Fed. Even T-bills don't work--bc they settle next day, but last wk a stablecoin collapsed w/in hours. Need *real-time* liquidity (only avail at Fed).@RiskDotNet risk.net/comment/794869…
2/ This is another in a long collaboration w/ Dr. Manmohan Singh of @IMFNews about financial sector plumbing. He has taught me so much over past decade.
Sum:
* D.C. policymakers are moving away from view that #stablecoins should be issued only by insured depository institutions
3/ That's good IMHO bc deposit insurance funds should be insulated from crypto--bc settlement differences are too big (could trigger runs on banks at financial system core). Policymakers r moving toward ring-fencing the risk as they should IMHO
1/ REMARKABLE SPEECH by US federal bank regulator abt #stablecoins (even cites yours truly at footnote 20). He discusses potential special-purpose, ring-fenced, non-lending banks as stablecoin issuers--ie, what #Wyoming SPDIs are. + nods to state efforts. occ.gov/news-issuances…
2/ This feels like the moment when another national group (the ULC), which had initially been critical of #Wyoming jumping ahead to recognize digital assets in its commercial laws, started to replicate some of Wyoming's good ideas. The ULC later saluted Wyoming as a pioneer. 🙏🤠
3/ While I wouldn't ever expect the federal bank regulator to salute #Wyoming as pioneer here (there's a long history of fighting between the federal & state bank regulators), the nod he gives to the **IDEAS** is remarkable.
Here are snippets from OCC Acting Commissioner Hsu:
STILL THINKING abt the SEC's staff acctg bulletin abt #crypto custody. It's an ENORMOUS change that disadvantages custody of crypto vs custody of securities, commodities, art, etc, for which many of the same issues exist. @HesterPeirce--can the SEC simply overrule FASB by fiat?
To illustrate just how staggering a change like this could be, here are State Street's numbers from its latest 10-K (2021):
* assets under custody: $43.6 trillion (TRILLION!!)
* on-balance sheet assets: $314.6 billion
* shareholders' equity: $27.3 billion
1/ THE SEC's new staff accounting bulletin on #crypto custody brazenly violates "same activity/same regulation" principle. There are similarly huge counterparty risks in securities custody, but the SEC doesn't require extra disclosure of those, or on-balance sheet acctg treatment
2/ Can you imagine if securities custody banks like State Street/BONY/etc had to account for securities custody on-balance sheet + hold 5% tier 1 capital against those huge liabilities? They'd be staggeringly undercapitalized. Yet that's what SEC now requires of crypto custodians
3/ It's a SHOCKING double standard, esp when the SEC knows that securities custody entails many of the VERY SAME RISKS! For ex, there are huge differences in the treatment of assets under custody in receivership that depend on whether your custodian is a bank vs. a trust company.
MORE on the below 🧵. There's so much inconsistency in #tradfi collateral posting rqmts (eg, most govts & corporates aren't req'd to post while trading firms are but with v diff collateral thresholds). It's all obfuscated. I lament that these derivative games are now in #crypto😢
There's no question derivatives games put a lid on #bitcoin's price appreciation in recent cycle, just as the same #WallSt derivatives games do same to #tradfi mkts. But when the epic short squeeze inevitably finally hits you get #LME-type games (yep, even in regulated mkts).
And derivatives can debauch otherwise strong balance sheets VERY fast in unexpected ways when BIG moves happen.
Little known fact: big banks' interest rate trading books often have BIG swaps receivables from state/local govts & swaps payables to corporates--UNCOLLATERALIZED.
I LEARNED interesting things at #ETHDenver2022—#DAOs are organizing under either coop or LLC laws🤠, & despite testing all the thousands of attendees for COVID a staggeringly low # were testing positive. I hope the latter is basically over🤞—the former seems to be taking off tho.
For #DAOs that choose to register there’s a race btwn using state cooperative laws vs state LLC laws. WY’s #DAO LLC law is hot but so is CO’s coop law. Our panel didn’t have time to dive into the differences in how each limits liability for members. #crypto lawyers—pls debate it!
Here's a blog on the topic of limiting member liability for coops. I'm hoping #crypto lawyers pick this thread up & start discussing bc there are likely differences between state coop laws & state LLC laws when used by a #DAO. I find the topic interesting. cooperativesfirst.com/blog/2020/08/0…