nicmas 🎄 cheerter Profile picture
Nov 27 17 tweets 6 min read Read on X
So the whole tech world is learning about OCP2.0 today via pmarca on Rogan. What happened exactly? For those curious, let's dig into OCP as it pertained to crypto. Quick thread
In 2023, I noticed post FTX crypto firms were getting debanked - just like a16z, many of our portcos. I wrote this piece in Piratewires, coining OCP2.0 and summarizing what I was seeing

piratewires.com/p/crypto-choke…
Six weeks later, crypto banks Silvergate and Signature had collapsed under mysterious circumstances. Many saw this as just desserts for banks serving crypto. I felt differently, that they were "suicided" as part of OCP2.0

piratewires.com/p/2023-banking…
In this second post, I also discovered the exact mechanism of OCP2.0, which had not been reported anywhere else, because it was considered "confidential supervisory information" – the FDIC verbally messaged a secret 15% cap on crypto-related deposits to banks.
Over a year later, and choke point 2.0 was still in place. I took another look at Silvergate, post bankruptcy filing, and was increasingly convinced they were murdered by government edict.

piratewires.com/p/inside-biden…
Here's the X version of that article.

Here's a condensed version of that article in Coindesk if you don't feel like reading 8000 words.

coindesk.com/opinion/2024/1…
I was in Congress last week and raised the topic of OCP2.0 with several members. The good news is that Trump's FDIC and OCC appointees will end it day 1, Trump himself has vowed to end OCP2.0 as he said in a speech. But that's not enough...
First of all, we need a full and complete investigation into how a purportedly sleepy and nonpartisan bank regulatory body like the FDIC was deputized into a political death squad. We need to learn the role of the Fed, the OCC, the DoJ, the NEC, the names of those responsible
Second, we need legislation to end the politicization of the bank regulatory apparatus, because two democrat admins in a row haven't been able to keep their hands out of the cookie jar (Trump ended OCP1.0 in his first term). This will happen again and again...
We need a law on the books that stipulates that bank regulators cannot quash a specific legal industry just because it is politically disfavored. Choke Point style behavior has now targeted over a dozen industries, with crypto just one victim among many.
More resources for those curious. In 2021 I sat down with @ismurray to cover the history of OCP1.0. He wrote a great paper on OCP 1.0: cei.org/wp-content/upl…

onthebrink-podcast.com/ocp-murray/
@ismurray In April 2023 after OCP2.0 became clear the law firm Cooper and Kirk wrote a paper on how OCP2.0 is unconstitutional: cooperkirk.com/wp-content/upl…

onthebrink-podcast.com/thompsonocp/
@ismurray More recently, Coinbase FOIAed the FDIC and received documents summarizing a systematic FDIC campaign to get banks to de-bank crypto startups - hard evidence of OCP2.0

Last week, Rep French Hill asked FDIC Chair Gruenberg under oath whether the FDIC was in the habit of sending verbal guidance to banks to have them derisk crypto. He says no. We know that he's not telling the truth. Rep Hill has vowed to get to the bottom of it if he gets the chair of the House FinServ Cmte

@ismurray Trump has specifically vowed to end OCP2.0 – used the term directly in his speech in Nashville. I believe he will end it on day 1, but we need to go further and push for full investigations and legislation ensuring it can't happen again

theinformation.com/articles/crypt…Image
walling off banks from crypto makes the system _more_ fragile, not less. the SAB121 rule prohibiting banks from custodying crypto means that big custodians like BNY mellon can't enter the market. they would be manifestly more competent than the crypto firms that sprung up instead.

maintaining the anti-crypto posture meant that only boutiques were willing to serve crypto and ended up with high deposit concentration.

in an ordinary regime, banks would be free to serve crypto firms at their pleasure, meaning less deposit concentration.

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More from @nic__carter

Dec 3
Longer thread on the FDIC’s 2022-23 “pause letters” to banks regarding crypto-asset activities in 2022 and 2023. Strap in
So we all know that banks have been stymied from doing crypto stuff for years: regulators installed 15% deposit caps on fiat deposits from crypto firms, cutting off bank access for the whole industry; the SEC used SAB121 to stop banks custodying crypto; and the Fed effectively prohibited banks from doing stablecoin stuff. But maybe the worst and most brazen was the FDIC unilaterally barring banks from doing any crypto stuff at all…
So recently, Coinbase made FOIA requests to the FDIC regarding their guidance to banks on crypto matters. Last month, the FDIC published summaries of these letters, without saying what they said exactly, or which banks they were addressed to.
assets.ctfassets.net/c5bd0wqjc7v0/7…
Read 27 tweets
Nov 30
Is there any truth to @pmarca's claims on JRE regarding tech and crypto 'debanking'? Is the CFPB actually anti-debanking?

My latest on Medium (link in next tweet):

Marc Andreessen and the CFPB: Debunking the Debanking DebunkersImage
@pmarca Pmarca claims debanking is targeting crypto founders, fintech founders, and conservatives. He says the CFPI and other financial regulators are responsible. Lee Fang and others say the CFPI is anti-debanking. Who is right?

medium.com/@nic__carter/m…
Read 10 tweets
Sep 19
so many of you will remember my reporting around "operation choke point 2.0" from the spring of 2023; TLDR, Biden's financial regulators, namely the Fed, FDIC, and OCC launched a crackdown on banks covering the crypto space...
the first casualty was Silvergate bank, which _voluntarily liquidated_. the common reporting around Silvergate was that they lent to crypto depositors, those depositors were flighty, when rates rose they suffered m2m losses on bond portfolios, and ended up insolvent
except... that's not true. silvergate weathered the storm, even though short sellers (cohodes) and members of congress like warren encouraged a bank run, based on rumors that silvergate had criminal exposure to FTX (they have since been totally cleared of those allegations)
Read 22 tweets
Sep 15
Chainalysis has released their 2024 Global Adoption Index. Let's analyze trends over the last five years of the index:



(reposting due to mistakes) chainalysis.com/blog/2024-glob…
Image
India and Nigeria occupy the top two spots this year for a second consecutive year. Indonesia has surged into third place. The US is unchanged at fouth. Top 10 has largely solidified.
There's remarkable geographic dispersion in the list. All regions are consistently represented.

South East Asia has the most appearances in the last five years, followed by Europe, South America, and Africa. Image
Read 7 tweets
Sep 12
Gm! Excited to present our new whitepaper, written in collaboration with @BHDigitalAssets, @Visa and @artemis__xyz

castleisland.vc/writing/stable…
Pop in a zyn, grab a cold brew, and let's dig in. First: why did we do this? Well, everyone knows stablecoins are the killer app of crypto. The numbers tell a compelling story:

- Supply is >$170b
- >20m addresses onchain use a stablecoin every month
- >120 addresses hold a nonzero balance
- Stablecoin settlement volume annualizes at >$5 trillion in 2024Image
But critics still often maintain that stables are used only as collateral for traders, or a settlement medium between traders and exchanges. We know anecdotally that stables are crossing the chasm to mass adoption – but could we prove it?

castleisland.vc/writing/stable…
Read 20 tweets
Jul 13
a few comments on this new genre of reporting – crypto is threatening democracy etc

first of all, it's definitely amusing that the critics have pivoted from writing crypto off to being deeply concerned about its effect on Our Republic
molly seems to have pivoted smoothly from web3isgoinggreat (a sarcastic blog dedicated to showing how broken crypto is) to being very worried about Crypto Dark Money influencing politics. maybe web3 is going a little greater than you thought? maybe take a beat to introspect?
so the core critique seems to be that crypto donations are "disproportionate" given the size of the industry. of course, this is an insane claim.

crypto is pound for pound the most politically harassed industry in the US. chokepoint 2.0 targeted crypto, no one else. the SEC has primarily been going after crypto. the FDIC, DoJ, OCC, the Fed, NYAG, CFTC – the list goes on – have all been weaponized against the crypto space. the Biden admin has even tried to quash bitcoin miners because they were using power in a way that they politically disagreed with. its not remotely arguable that crypto gets far more political attention than any industry, especially when considering its (relatively small) size.

as a crypto founder, you risk getting thrown in jail for building privacy tools, attacked by the SEC (even if they tend to slink away after a few years), you will have an extremely hard time getting banking, you are automatically banned from using a bunch of B2B tools, and so on.

crypto finally getting its act together and pulling together donations to stick up for its interests in washington is entirely reasonable given how much harassment we've faced in DC over the last few years. and as a new industry, we don't have the embedded political networks in Washington that others do, so we have to work harder to get off the blocks. our relatively higher level of output is totally fair given this.
Read 8 tweets

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