1/ I'VE BEEN THINKING MORE abt the #bitcoin ETF. For yrs, I've said ETFs are a double-edged sword for bitcoin (bc ETF mkt makers are permitted by law to create more claims to the underlying asset than the quantity of the underlying, which distorts the price of the underlying).
2/ But, as I wrote in @Newsweek this week, the SEC's decisions to reject spot #bitcoin ETFs don't exist in a vacuum. They must be viewed in context of the SEC's decisions in 2015 to approve 1 (& only 1) fund structure for bitcoin--& not another until 2021.
newsweek.com/crypto-crash-w…
3/ The decisions from 2015-21 + the inherent structure of closed-end funds (which can trade at very different prices than their underlying asset) created a massive market distortion, as detailed in my @Newsweek post. That market distortion brought in the fast-money #WallSt crowd.
4/ With them came huge leverage that, using Hoover's analogy, was like a loose cannon on the ship of #bitcoin mkts in a tempest-tossed era. Leverage games began w/ arbitraging GBTC's premium, then moved to futures mkts (not 2.5x leverage on regulated exchanges but 125x offshore!)
5/ & then ping-ponged to Anchor etc. The leverage unwind was inevitable, has been epic & is healthy.

But I keep thinking abt the impact of the SEC's decision to approve only 1 way for US investors to gain exposure to #bitcoin in brokerage accts for ~6yrs (in a closed-end fund!)
6/ Again, that created a huge mkt distortion (the big GBTC premium), which attracted the #WallSt boyz. The SEC analysis in rejecting spot #bitcoin ETFs points to manipulation in bitcoin spot trading mkts. It's not wrong! But such probs existed in 2015 too, when it approved GBTC.
7/ The SEC's analysis points out such manipulation has gotten worse, not better. But to what extent was the SEC's own decisions since 2015 (both to approve only 1 fund & then to reject all others until 2021) a big contributing factor??
8/ There's path-dependence to the SEC's regulatory decisions (ie, the mkt impact of rejecting spot #bitcoin ETFs isn't independent of SEC's 2015 decision to approve only 1 fund (a closed-end fund) which went on to trade at a huge premium that finally collapsed to a big discount).
9/ My big point is that the whole episode is not a free-market failure. It has nothing to do with #Bitcoin itself (which just keeps on adding blocks & doesn't care about mkt structure issues in its trading mkts).

But it raises an important policy question.
10/ Here's the important policy question: If an SEC decision has the impact of creating a big mkt distortion (especially one that hurts retail investors, as this one did), what is the SEC's obligation to address it??

Remember, the SEC's mission is investor protection.
11/ Related: when #WallSt hedge funds can arbitrage retail investors due to the inherent structure of closed-end funds in a market where a huge supply/demand imbalance develops (which causes the closed-end fund to trade at a big premium), what is the SEC's obligation??🤔🤔🤔
12/ I suspect there will be a big retrospective on all this at some point, as well there should be. Some will argue the SEC had no obligation to fix the problem its 2015-21 decisions helped create. Others will argue the SEC should have approved ETFs to prick that premium bubble.
13/ I take no position on those policy questions--I'm just raising them for discussion bc I've been thinking a lot about them. 🤔🤔🤔

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More from @CaitlinLong_

Jun 19
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…
Read 7 tweets
May 17
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

* Next ?=back w/ T-bills or cash? Image
Read 8 tweets
Apr 8
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:
Read 8 tweets
Apr 1
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
Read 5 tweets
Mar 31
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.
Read 5 tweets
Mar 15
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.
Read 6 tweets

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