Transcript: The Evolution of Money: Cryptocurrency Regulation - The Washington Post

MS. CORATTI KELLY: Hi. Good morning, everyone. Thank you.

My name is Kris Coratti. I am chief communications officer at The Washington Post and general manager of Washington Post Live. Welcome. I'm so thrilled. We've got some old friends I see in the audience and some new faces. So thank you all for being here with us as we dive into the world of cryptocurrency and its regulation.

I'd like to think about the democratization of money, the elimination of a central banking system, immediate access to funds. These are some of the promises of cryptocurrency, but we've seen in recent weeks that crypto may not always be stable or reliable, and questions remain as to how we best protect consumers in this new world order of digitized money. Should these assets be regulated, and if so, by whom?

We begin today by hearing from Rostin Benham, chair of the Commodity Futures Trading Commission, which is one of the main bodies that could be tasked with regulating cryptocurrency.

Next, Senators Lummis and Gillibrand join us to talk about their joint legislation, which was just unveiled yesterday, and it proposes establishing guardrails around digital currencies.

Finally, we're joined by two experts in the industry, Dante Disparte, who is the chief strategy officer and head of Global Policy at Circle, and Tomicah Tillemann, global chief policy officer at Haun Ventures. We'll hear their perspective on how digital assets should be regulated and what they think about crypto's impact on the larger financial system and the economy.

I'd like to thank our presenting sponsor, Grayscale, who you will hear from later in this program.

And now I'd like to hand it off to my colleague, Leigh Ann Caldwell, who is amazing. She'll be out with our first guest right after this video.

Thank you again for joining us.

[Video plays]

MS. CALDWELL: Good morning, everyone. I'm Leigh Ann Caldwell. I am an anchor here at Washington Post Live, and I'm also coauthor of the Early 202 Newsletter here at The Washington Post. Thank you, everyone, so much for joining us. We are thrilled today to welcome the chair of the Commodity Futures Trading Commission, Rostin Benham, today to talk about the future of crypto. It's such a timely conversation, and I want to tell our audience that if you have any questions, go to Twitter and tweet those questions at @PostLive, and we will try to get to them.

Chair, thanks so much for joining us.

MR. BENHAM: Thanks for having me. It's great to be here.

MS. CALDWELL: The timing is incredible. As we know, there has been new legislation that has been introduced yesterday by Senator Lummis and Senator Gillibrand attempting to, for the first time, regulate the crypto marketplace, the industry, and they gave you a lot of power, the CFTC chair. So are you thrilled with how they wrote that legislation?

MR. BENHAM: Well, I'm excited about the fact that we have members of Congress, and certainly credit to Senators Lummis and Gillibrand for taking a leadership role. I know there are several others who are thinking about these issues, but I am thrilled about the fact that we're taking steps towards regulating and putting guardrails around this technology.

You know, I've said this multiple times. We saw some clips earlier. There's a lot of retail exposure. There's a lot of speculation, and there's a lot of volatility, as we've seen in the price movements over the past couple months and years. And I think smart, sensible regulation will protect customers, will bring credibility to the marketplace, and as we see this technology emerge and develop over the years, I think, you know, in our securities markets and our derivatives market‑‑I say this often. We have the strongest, deepest markets in the world because of the regulation we have, and I think we can replicate that same model in the crypto space.

MS. CALDWELL: Well, part of the reasons they decided to put a lot of the regulation under the CFTC is because they defined a lot of these as a commodity, and so do you agree with that, that a lot of these digital currencies are, in fact, commodities and should be regulated that way?

MR. BENHAM: I do, and I think it's important for all of us collectively to think about the two market regulators that we have in the U.S. government, the SEC, of course, and the CFTC, and the purpose of each of the laws that have been developing over many decades, nearly a hundred years.

And starting with the SEC and just‑‑I don't want to generalize too much, but what we're trying to accomplish with our securities laws is to bridge a gap, an information gap, an information asymmetry between an issuer of a security and an investor of a security, and this manifests itself in the form of 8‑Ks and 10‑Ks and 10‑Qs, these forms that we see out of public reporting companies.

On the commodities side, you know, typically‑‑and just thinking about traditional commodities, whether it's agricultural commodities, energy commodities, or metals commodities‑‑you're not going to have that same disclosure requirement. These are decentralized stores of value that end users use, obviously consumers use in many different ways, and from a digital asset perspective, it's pretty clear that many of the digital assets themselves replicate or look like commodities. They're more like stores of value than they are securities.

And we have precedent and common law, you know, going back many decades to sort of define how we view securities versus commodities, but I think it's really important to just go back and take stock of what's the purpose of the securities laws, what's the purpose of the commodities laws, and where do these digital assets fit.

MS. CALDWELL: Well, the chair of the SEC would most likely disagree with you. He said recently, just in April, I believe, that the digital currency marketplace has a lot of similarities to the current traditional marketplace, and they should be regulated similarly. Why should‑‑why is that not the case?

MR. BENHAM: Well, Chairman Gensler and I agree on many things. We disagree on many things. I think the most important thing for everyone and the viewers is to know that we share the same values and in what we want to accomplish, right? It's customer protections and a regulatory structure around this market.

But there are thousands of coins, and I certainly agree that many of them and probably hundreds of them replicate security coins and should be regulated as securities. But there are also many commodity coins, and we could start with the two biggest coins within the market capitalization of digital assets, Bitcoin and Ether, and if you look at the market cap of digital assets, it's obviously fluctuated a lot in the past 6 to 12 months, peaking at about $3 trillion back in November, probably now just over a trillion dollars. But what hasn't changed is the correlation in terms of the size of Bitcoin and Ether relative to the total market capitalization, and these are two of the biggest coins that are commodities, look like commodities, and I think should be regulated by a commodity regulator.

MS. CALDWELL: A lot of the industry wants the CFTC to regulate them. Does that mean that the CFTC is a weaker regulator than the SEC?

MR. BENHAM: No. It‑‑no. It's just a missed understanding of the securities laws and the commodities laws, and it's‑‑you know, it's what I said earlier. It doesn't make sense for us to issue information disclosures on a commodity. What we're trying to accomplish is provide risk disclosures to investors, make sure that investors understand the risks that they're taking in terms of capital allocation, but on a periodic basis and using Bitcoin as an example, as a commodity, it doesn't make sense to have an 8‑K, an S‑1, a 10‑K, or a 10‑Q. It is a store value. It acts like a commodity, and we need to treat it like that.

The CFTC‑‑I've said this before‑‑we are one of the toughest cops on the beat. We have a strong enforcement program, and we are very, very strong in terms of our market oversight and surveillance. We have some of the best experts across the commodity space and especially across the digital asset space as well.

MS. CALDWELL: Well, what should‑‑what should regulation look like? Do you need to regulate the exchange? Do you need to regulate the transaction? A combination of both? Can you lay out what your vision would be if you had ultimate authority?

MR. BENHAM: Sure, sure. I mean, it wouldn't be very different than what we see in the traditional commodity space, which is we have direct oversight over exchanges. To the extent that the products and the trades would be cleared through a clearinghouse, we have direct oversight over the clearinghouses. We have oversight over the intermediaries, which essentially act as the brokers who are facilitating the purchase and sale of the asset, so the commodities, and then on a more granular level, I would say on a more boots‑on‑the‑ground level, we're making sure that investment advisors and individuals that are introducing retail customers to these assets are registered. We're doing background checks, whether it's AML and KYC, and ensuring, above all else, that information disclosures are made to investors so that when they make a choice about how to allocate their capital, they know exactly all the information they need to do before they make that decision.

MS. CALDWELL: We have a question from Twitter from Emma Manny. She or he says I'd be curious to know whether the present‑use cases are for cryptocurrencies that are meaningful improvement over non‑crypto systems. So why does crypto matter?

MR. BENHAM: Yeah. I think from a regulatory perspective‑‑and I think about this question a lot. It's an excellent question. But what we've seen over the past decade and I would say specifically even over the past five years while I've been at the commission, both as a commissioner and as chair, is a marketplace has developed, it has evolved, and it has grown. And it moves very quickly in directions that we often can't predict, and as a regulator of markets, as a regulator of commodities, I believe I have both an interest and a responsibility to oversee these markets to protect customers.

I would suggest to not‑‑you know, you don't have to look any further than a list of our enforcement cases. We've brought over 15 enforcement cases in the past six or seven years, ranging up to $100 million for fraud and manipulation. These are individuals across the country who are, unbeknownst to them, investing their money in fraudulent schemes.

So, regardless of what the future of the technology may be, I have to at least, in my sort of view, view this as one scenario, the development of this technology, the evolution of this technology, and use cases potentially emerging and growing, but regardless, I have to think about the marketplace. I have to think about the trading platforms that exist and the millions of individuals who invest their money into digital assets.

MS. CALDWELL: But, you know, digital currencies have lost a trillion dollars this year, I think $400 billion just in the past month. You yourself even said, I think, last month that a large portion of these are frauds, are going to collapse. You had Terra collapse. So how are you going to protect consumers, and should there be confidence in digital currencies?

MR. BENHAM: So this in lies the problem, right, because right now our enforcement program, which is really the only mechanism we have into this digital asset space, because we don't have regulatory authority over the trading platforms or the exchanges. We don't have regulatory authority over the brokers that we traditionally do in a traditional marketplace, in a commodity marketplace. So what we've had to rely on over the past five, six, or seven years is essentially whistleblower tips from the public saying, "Hey, I think we had a scam here" or "I lost my money here. Can you help?" And then we pursue this through our enforcement authority, which is limited to fraud and manipulation.

So, in the gamut of a rate regulatory oversight, we have this very limited authority to pursue bad actors, and what I've been arguing for and really goes to this point is we need more extensive, more exhaustive, inclusive regulatory authority so that we can surveil markets before fraud occurs, so that we can review individuals and institutions who are participating in this market, selling these products to investors, so that we can do the regular checks that we do in the marketplace and develop resilient, safe markets.

I'll add as well is, yes, we've seen a huge decrease in the size of markets over the past couple months, but another issue or discussion I'm having with my colleagues, both domestically and across the globe, is if this market returns and grows and grows over time, what market resiliency and financial stability issues start to rise because the market is so large?

MS. CALDWELL: And so you need Congress to give you more authority to do more regulatory actions?

MR. BENHAM: A hundred percent.

MS. CALDWELL: Okay. Well, currently, CFTC has some authority as it stands now. There's some in the industry who are begging to be regulated. Should you approve licenses faster, or should you move forward in the powers you have right now as it‑‑

MR. BENHAM: I think we are doing everything, and I could say this with a hundred percent confidence to share with the viewers. We are doing everything we can with the resources we have to protect investors and to police the market.

But I'm going to just take 30 seconds to give an example because I think it will clarify some things. As you pointed out, we regulate derivatives contracts, which are financial contracts whose price is derived from an underlying commodity, anything from wheat, natural gas, or gold. We do not surveil, we do not oversee cash markets, which is the actual transaction of the underlying commodity. However, Congress did provide us this very limited authority, which I mentioned earlier, over fraud and manipulation in the cash market. So, for decades, we've been policing fraud and manipulation in cash markets, and the reason Congress did this is because, you can imagine, there is a correlation between the cash market transaction and the derivatives market transaction. If there is a dislocation in those prices, then something is wrong with our markets.

So we have that policing authority in the cash market under very limited circumstances. It's a very powerful tool. We use it when we can and with the resources we have, but I will just emphasize, it is limited, given the scope and size of this market, and the fact that we can only essentially bring cases when we get tips from people from the outside. We don't have the traditional surveillance tools that we do in regulated markets to surveil markets and to anticipate fraud or manipulation or to anticipate bad actors.

MS. CALDWELL: And kind of a clarifying follow‑up, what do you think that the biggest‑‑the biggest thing is that needs to have oversight? Is it fraud? Is it manipulation? Is it something else? Is it illicit activity from international organizations? Like, what do you think needs to be cracked down on the most?

MR. BENHAM: Sure. I mean, it's a great question and one that I don't want to put any weight to any one over another because it's really hard to tell right now. I know Treasury is doing a great job on the illicit activity, given the authority that they have, but I'm a market regulator. I think about markets, and I think about the trading platforms, many of which we know, across the U.S. and globally, and these are, at this moment, largely regulated by state money transmitter licenses, which just as a little bit of information is essentially a Western Union‑era license that states have been issuing for decades.

So, as a market regulator, it doesn't make me feel very comfortable that these trading platforms, what we know as essentially exchanges, are only being regulated by state money transmitter licenses.

There is regulation around illicit money activity, AML, KYC, but from a markets perspective, conflicts of interest, the way that, you know, traditional trading occurs and avoiding disruptive trading practices, pre‑trading agreements, these are typical types of conduct, illicit or, you know, illegal conduct in the trading markets that we need authority to pursue if it's occurring.

MS. CALDWELL: And does this Gillibrand and Lummis legislation give you the authority that you need, or do you need more?

MR. BENHAM: No, it does. It does a very good job in, I think, identifying, and, you know, one of the trickiest things we're going to have to do‑‑and this has been an issue, and I think they addressed this very well‑‑is deciphering between commodity and security. But, in terms of giving us authority within what we call "core principles," it would give the CFTC authority to write rules and regulate these stakeholders within the financial ecosystem.

MS. CALDWELL: We have another Twitter question from Alex Allaire. Do you believe that a sound industrial policy for crypto and Blockchain technology is critical for national security?

MR. BENHAM: You know, it depends on where the technology is going, and I think it is‑‑it would be‑‑it's important for the U.S. government to be thinking about this technology under a scenario analysis, and this is something that is very, you know‑‑everything in terms of market risk, I look under scenario analysis, and there could be a scenario where this technology goes away. There could be a scenario where this technology just sort of ebbs and flows over time, but there certainly could be a scenario where this technology scales and grows, and this becomes sort of ubiquitous within our economy and within commerce and within foreign transactions, and in that case, I think this question is very pertinent and the reason why we need to get ahead of a possible scenario where this technology develops and evolves, because naturally it could become a baseline for payments and for payment processing. It could be‑‑obviously, we're seeing with the Ukraine crisis, at least rumors of using cryptocurrency or digital assets as a way to move money around illicitly. These are the types of scenarios that I think we collectively need to think about as a possibility and therefore get ahead of it from a policy perspective so that we know what's happening, we can trace illicit and bad activity, and we can stop bad actors, obviously, before they do something that is illegal.

MS. CALDWELL: How do you get ahead of it?

MR. BENHAM: We have‑‑it's the first step. It's the Lummis and Gillibrand bill. It's starting to write policy. It's to get bipartisan support. It's to start to talk to regulators, talk to stakeholders, and build an infrastructure over this technology, because in many respects, there are common elements of it to our traditional financial system, but in most respects, it's so unique that we have to rethink what the financial system might look like, how commerce is going to be conducted, and what the economy will look like.

MS. CALDWELL: Ultimately, what is‑‑for consumer protection, I know Senator Elizabeth Warren is huge on this, and there's others as well who are very concerned about this. What is the biggest tool that you need in order to protect consumers? You know, we touched on this earlier, but just to put a finer point on it?

MR. BENHAM: Yeah. You know, from a traditional markets perspective, it's about disclosures, and it's about information flow, and it's knowing what risks are at stake when an investor, whether on an individual basis or through an institution that they invest their retirement money or their pension money, understands the risks involved. You know, it's a very fine line to tell an individual how they can allocate their capital.

But, at a minimum, I think I have a responsibility to ensure that information is being shared with that individual about what risks are involved, what is the history with that sort of asset, and what they might expect in terms of returns or loss. And we do a very good job of that at the CFTC, given we have leveraged markets. We have some of the best investment disclosures in terms of risk disclosures.

What we don't have‑‑and I mentioned this earlier‑‑is these periodic reporting requirements, which again doesn't make sense for commodity markets. It doesn't make sense for securities. But this is the type of information that I think we need to get out to investors.

The other element of it and the more important element is just having regulatory guardrails around the infrastructure of the market, having the exchanges, the platforms regulated, having the intermediaries and the brokers regulated, having conduct requirements so that individuals and institutions can report information, and that we have a better sense of what's going on in the marketplace so that we can make more informed decisions and ultimately root out bad actors and fraud, because that's the biggest problem, right, is‑‑is the price representative of supply and demand? Are there trades and conduct occurring off exchange that we don't know about? Are there two individuals sort of colluding to set a price that is not representative, again, of supply and demand? These are the things that market regulators and market rules provide, and again, another reason why we have the best markets in the world, because we have the strongest, most transparent rules in the world.

MS. CALDWELL: Well, how do you maintain that U.S. advantage in this? There's a lot of competition out there.

MR. BENHAM: There is, and I think it's a balance because‑‑this is a frequent argument I hear is that if you don't move quick enough, we're just going to go overseas. And I get that, right? But it's balance because, you know, preserving American exceptionalism is obviously important. I think it's important for economic growth, the labor market, for national security purposes, but also, I think we have the greatest markets in the world. We have the strongest economy in the world because we move through things thoughtfully and deliberatively and we think about things before we move too quickly.

And, you know, you could probably get a sense or think that some jurisdictions may have moved too quickly in this space. This should not be a race to the bottom. This should be about preserving market integrity and market resiliency and making sure that we're moving forward. I understand that many, many people, stakeholders think maybe we've moved too slow, but quite frankly, I think we're moving at a good clip. And the fact that we have legislation being introduced by two Senators today, there's been several bills on the House side and the Senate side, I believe there's more coming from the chair and ranking member of the Agriculture Committee, these are the types of things that I think will preserve American exceptionalism, will preserve the market in the U.S., and keep this conversation moving forward in a thoughtful way so that we can have very exhaustive discussions about what this technology does, what risks it poses, and what opportunities there are for the economy in the country.

MS. CALDWELL: There is also an environmental component to this.

MR. BENHAM: Yep.

MS. CALDWELL: Bitcoin is extremely energy‑intensive. What sort of oversight needs to happen with that? Is there anything that can be done, and are there alternatives?

MR. BENHAM: Yeah. If I recall correctly, the Lummis‑Gillibrand bill does require a report conducted by FERC, the Federal Energy Regulatory Commission, and the CFTC, but I couldn't agree with you more.

You know, at this point‑‑and this goes back to the, I think, first Twitter question about the use cases‑‑certainly, there's a lot of opportunity. We don't know how that's going to change and evolve over time, but in terms of the relationship between the current use case and the energy usage and energy consumption from mining, I think there's a pretty significant dislocation right now, and we need to remove that dislocation. And that either is through technology, a term, proof of work or proof of stake. I know some of the miners are thinking about transitioning the way they mine so that they can reduce energy consumption.

But the one thing that I've thought about and I've had a few conversations with members is at a minimum‑‑and I think this is what the report will start to accomplish. Perhaps we need to think more about it is, what information flow is getting to investors and customers about this issue, about this fact? Because on the one hand, we need the industry to transition and change and understand that the energy consumption is too big, but we also need consumers to understand and appreciate what's at stake so that through essentially economic incentives, they can steer their choice away from the more energy consumptive behavior. And that, you know, is a sort of age‑old economic, I think, theory that if we create that information flow, incentives and disincentives will move the market in the right direction, and given the climate crisis, given the issues around climate change, I think with the right and accurate disclosures, incentives will move people away from that energy‑consuming behavior.

MS. CALDWELL: In the last 20 seconds we have, what is the one thing that the CFTC needs to do now to show that they are serious regulators in this space before any legislation is passed?

MR. BENHAM: We have to keep doing what we're doing, and I would‑‑again, there's nothing more we need to do. We are one of the strongest enforcement agencies. We have the best folks in the world in terms of expertise. One important thing‑‑and I know the bill mentioned this‑‑is increasing our funding. That will have to change, and the bill does provide a user fee for us so that we can leverage a fee against stakeholders or the industry to raise our funding so that we can hire the right people, have the resources to regulate the market in an appropriate way.

MS. CALDWELL: Great. Mr. Chairman, thank you so much for joining us.

MR. BENHAM: Thank you.

MS. CALDWELL: I really appreciate it.

MR. BENHAM: Thank you.

[Applause]

[Video plays]

MR. NEWMYER: Good morning. I'm Tory Newmyer, a business reporter here at The Washington Post, and I am delighted to be joined today by two Senators who made major news yesterday with the introduction of a widely anticipated bill that is proposing a comprehensive regulatory framework for cryptocurrencies, the first of its kind and is already setting off a lot of debate. So I'd like to welcome both of you here to The Washington Post, Senator Gillibrand and Senator Lummis.

SEN. LUMMIS: Thank you. Thanks for having us.

SEN. GILLIBRAND: Yeah. Thanks for having us.

MR. NEWMYER: Thanks. Thanks for being with us.

And a reminder to our guests, we want to hear from you. So tweet us your questions using the handle @WashingtonPostLive, and we will try to work them in to the conversation today.

So we're going to get to your bill in a moment here. There's a lot to discuss, but I just‑‑I kind of want to start by scene‑setting a little bit.

Senator Lummis, you started working on this bill last year. Since then, we've seen a lot happen in this industry and in this space. The total value of digital assets has fallen roughly by half, I think, since when you started working on this in December‑‑or it was reported that you were working on this from about $2.5 trillion to $1.2 trillion, roughly, today.

Digital thieves are on track for a record‑breaking year, having stolen $1.3 billion worth of crypto in the first quarter of this year, including more than $600 million in the biggest hack of its kind perpetrated by a state‑backed‑‑North Korean state‑backed group that is using the proceeds to fund their weapons program.

Terra, a so‑called algorithmic stablecoin, and its associated ecosystem collapsed last month, erasing roughly $45 billion in market value with it. Just last week, the FTC said crypto has become the payment method of choice for scammers, accounting for more than a billion in consumer losses since the start of 2021 or one out of every four dollars lost to such fraud. That's obviously a grab bag of a lot of bad news. It doesn't paint the complete picture, but I point to all of those things to say a casual observer of this space could be forgiven for thinking maybe despite all of this hype I've heard over the last year, crypto isn't the next big thing.

And, you know, both of you all are here because you are believers in the potential of this technology, and I'm curious if the developments that we've seen over the last weeks and months have changed your view of that at all, just as a starting point.

SEN. LUMMIS: Well, I think the developments of the last few months simply illustrate that it's time‑‑in fact, past time for this piece of legislation. That stablecoins, algorithmic stablecoins that are backed by nothing, perhaps don't have a place, that stablecoins should be backed either by 100 percent hard assets or by financial institution that is insured by the FDIC, and so that's what our bill provides.

It also is true that there are certain cyber-attacks that we want to send to the committee of jurisdiction that can address the consequences of cyber, and we also believe that because there is fraud among the more than 10,000‑‑some people say up to 19,000 cryptocurrencies. Yes, some of them are fraudulent. That's why the disclosure capabilities of the SEC are so important, and we want to make sure that those that are securities are subject to disclosure requirements by the SEC.

So we recognize some of the issues that you've pointed out, and we want to make sure that this piece of legislation is capable of putting us on a regulatory sound footing, so the good guys can continue to operate and flourish and the bad guys are meted out.

MR. NEWMYER: Senator Gillibrand, did any of the‑‑we talked to‑‑Senator Lummis mentioned stablecoins.

SEN. GILLIBRAND: Mm‑hmm.

MR. NEWMYER: Did the collapse of Terra inform the stablecoin provision in the bill?

SEN. GILLIBRAND: Absolutely. As did a lot of people in this room, this bill is a comprehensive approach to how to create safety and soundness in this industry, how to create transparency, accountability, and how to create consumer protections, because of everything that's happened in the last several weeks.

And what's so interesting about this process is the realization that we have a huge opportunity with Web3. If we get Web3 right, we can set innovation and democratization of finance and decentralized finance on a path that can solve really big problems and make a huge difference for people across the globe.

So we need to act now to place this regulatory framework, basic rules of the road in place, so we don't make the mistakes we made with Web 2.0. We never regulated Web 2.0. We never looked at the platforms and said what is the privacy harm. We never looked at requirements about who owns someone's data. We never looked at the question of surveillance capitalism. We never made decisions about any of these very hard issues that unfortunately are harming our children, are harming our economy, are harming our nation with division. And so, if we get Web3 right, we can then maybe go back and look at Web 2.0 and say what would a data protection agency look like, to begin to look at that.

But that's why Cynthia and I are so passionate about taking this moment to do the right thing by Web3 to set safety and soundness up.

And specific to the cybersecurity issue, in our bill, we have a requirement that the CFTC, the SEC work directly with Treasury and NIST to come up with basic cyber standards.

We also have a self‑funding mechanisms within the CFTC so that resources go directly there. So, if they are required to do the oversight and accountability for Bitcoin and Ether and spot markets and futures markets, that they have the resources to hire more lawyers, more cybersecurity experts, and build that cyber capability to handle that aspect of digital assets.

MR. NEWMYER: So you mentioned that the CFTC is going to be the primary regulator under your bill, which seems like there's a lot in here, but that seems like one of the main pillars.

You also do something in this bill where you are creating, I think, a new designation for cryptocurrencies, and you're calling them "ancillary assets." Can you describe that for us?

SEN. GILLIBRAND: Do you want to go first?

- October 25, 2025

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