Crypto Regulation: Present & Future | #SALTNY

Crypto Regulation: Present & Future with Sydney Schaub, Chief Legal Officer, Gemini. Ryne Miller, General Counsel, FTX US. Zach Dexter, Chief Executive Officer & Co-Founder, LedgerX.

Moderated by Robert Hackett, Senior Writer & Tech Editor, Fortune.

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SPEAKERS

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Sydney Schaub

Chief Legal Officer

Gemini

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Ryne Miller

General Counsel

FTX US

 
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Zach Dexter

Chief Executive Officer & Co-Founder

LedgerX

MODERATOR

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Robert Hackett

Senior Writer & Tech Editor

Fortune

TIMESTAMPS

EPISODE TRANSCRIPT

Robert Hackett: (00:07)
Hi, everybody. I'm Robert Hackett, a senior writer and tech editor at Fortune. And today, we're going to talk about crypto regulations with our esteemed panelists here. It seems lately, like there's been a bit of an unfriendly turn, especially here in the US. A lot of regulators are getting a little bit more aggressive about regulation, or at least talking more about it, that things are going to come and some things are not going to fly.

Robert Hackett: (00:31)
The recent news, I think that everybody really caught, was Coinbase getting told by the SEC that they would get sued if they launched a high yield product for crypto lending. So Sydney, as somebody at a rival exchange at Gemini, which offers a lending product that gives people yield for lending out their crypto, what was your reaction to the Coinbase news?

Sydney Schaub: (00:58)
Well, first of all, thanks so much to Salt for having me here. And it's great to chat with Ryan and Zach and Robert, about these timely issues. There's always a lot going on in crypto, but it feels like at this moment in the regulatory space, there is really a lot going on. And obviously, we are aware of the Coinbase dustup with the SEC, and we're following that. I'll say, as a general matter, there's two things. There are a lot of crypto yield products out there, and they're all different.

Sydney Schaub: (01:33)
So Gemini does have a crypto yield product as well. Many other players in the space have products, and they vary wildly. And Coinbase's product is if you've seen the news about them recently, is not live yet. So it's hard to make any kind of comparisons. But I'm not surprised to see these things happen, because crypto is so new that there aren't always perfect analogies or perfect fit between the new products that we all want to offer, and the existing landscape that's applicable to more established products and financial assets.

Sydney Schaub: (02:11)
So you do sometimes see these things happen. And of course, it's our view as Gemini and many other of our peers who are actually seeking regulation, that it's better to make regulation through a dialog with regulators, as opposed to through enforcement. And it's unfortunate when you see those dialogues break down. So obviously, it's on our radar. It's something that we notice. And it's something that we're cognizant of.

Sydney Schaub: (02:36)
And I think it's hard to imagine it now, but thinking back even just a couple years ago there, wasn't the kind of trust in the asset class that you see now. Bulge bracket banks weren't looking to offer their customers exposure to it. So I think we and Coinbase, and many of our peers, actually do want a regulatory landscape to be applicable. They want clarity, they want trust. And that's what we're all going for at the end of the day.

Robert Hackett: (03:05)
Did Gemini reach out to regulators in the wake of Coinbase, what they revealed about their discussions with the SEC? Are you having these conversations as well? And what's coming out of them?

Sydney Schaub: (03:18)
I wouldn't say so much in the wake of Coinbase, of what's happening with Coinbase. We're sort of always talking to regulators because one of the things that is somewhat unique about Gemini is that we are a DFS, New York Department of Financial Services regulated trust company. And there's a lot of talk about how regulators, including in this instance, the SEC, from Coinbase's perspective, are obstructionist and they don't get it, and they're slow.

Sydney Schaub: (03:47)
And there's a lot of frustration. And we experience that from time to time as well. And we get that. But the DFS has been our regulator since we launched in 2015. They really blaze the trail in terms of crypto regulation, and they dove in and got it right away, and actually applied one of the oldest structures that are applicable to financial assets, which is the trust company charter, to one of the newest innovations, which is crypto.

Sydney Schaub: (04:19)
And that was back in 2015, and was the precursor to the BitLicense that a lot of people love to hate because it's hard to get them. But we've been really happy with our dialogue with the innovation team at DFS. And that is a dialogue that we have to have with respect to every product that we offer out of our exchange in custody business, which is DFS regulated. That's ongoing, no matter what else is happening in the landscape.

Robert Hackett: (04:45)
I figure I should ask. Is Gemini's high yield lending product, a security?

Sydney Schaub: (04:49)
No, it's our position that it is not.

Robert Hackett: (04:51)
I had a feeling that you would say that.

Sydney Schaub: (04:53)
But thank you for asking.

Robert Hackett: (04:55)
Sure. Ryan, tell us about FTX US. You are sort of related to FTX, the global exchange, but you are particularly focused on the US market, which has a host of its own regulatory requirements. What are the differences between that global operation and what you need to do to craft something for the US market?

Ryne Miller: (05:18)
Sure. Yeah, it's a great question, one we get a lot. So under Sam Bankman-Fried, I think he spoke earlier this morning, he is the majority owner of a business called FTX.com, and also a business called FTX US, that we run under the brand FTX US. I'm the general counsel of FTX US. So, speaking for that entity. A big part of the market, globally, for the crypto space is derivative.

Ryne Miller: (05:42)
And that can be a margin product, that can be options, that can be futures, but a big part of the global demand is derivatives. And there's a handful of exchanges not in the United States that have offered those products. FTX.com is one of those. As Sam saw that business grow, he kept looking over his shoulder and saying, "The US market's there. It would be great to have a presence."

Ryne Miller: (06:03)
He's from the US. I think a lot of his leadership team had experience here. And he said, "Let's build a US business." And the one product that you could launch by partnering with some trust companies, by working with different regulators and licenses on the money transmitters side, was a spot cryptocurrency exchange. So FTX US today, is a spot cryptocurrency exchange. We have an NFT marketplace, and then we have ambitions.

Ryne Miller: (06:26)
And we've talked to the CFTC a lot about this, of getting into derivatives in the United States, for US users. And so I think that's probably the two things you think of us, FTX US spot exchange, FTX.com, derivatives exchange, not available in the us.

Robert Hackett: (06:42)
And this is probably a good segue to hear from Zach, whose company that you are purchasing.

Ryne Miller: (06:48)
Sure, I'll let Zach introduce that.

Zach Dexter: (06:50)
Yeah, sure. So I'm CEO of LedgerX. We are a commodity futures trading, commission-regulated clearinghouse and exchange, which means we have the necessary federal licenses to offer derivative products on cryptocurrencies that are considered commodities, like Bitcoin and Ethereum.

Zach Dexter: (07:08)
We've been operational since 2017. We offer future swaps and options on Bitcoin and on Eth now, and convenient one 100th contract sizes. And we're very excited to be working with FTX US to take everything to the next level.

Ryne Miller: (07:25)
Yeah, a little color on that. So we announced, I don't know if it was a week or two or three weeks ago, but we've agreed to acquire LedgerX. They'll be under the FTX US structure. And we've talked with the CFTC about this. They've been encouraging and supportive. Their real goal is engagement and dialogue.

Ryne Miller: (07:41)
And both with our team and with Zach's team together, we've done a lot of that with the CFTC and a handful of other regulators. But there are some closing conditions to sort out. And hopefully, by some time in October, we can say that transaction is closed and done, and moving forward.

Robert Hackett: (07:57)
And at that point in time, people will be able to trade derivatives on FTX US?

Ryne Miller: (08:02)
Well, they'll be able to trade as they are today, futures and options on LedgerX. LedgerX will be an FTX US company. Whether it's someday called the FTX Derivatives Exchange, who knows? Smarter people than me will make those marketing decisions.

Robert Hackett: (08:16)
Got it. How has the uptick in usage been since your big commercial? You had Tom Brady feature in an FTX US commercial, getting people's attention.

Ryne Miller: (08:26)
Well, my mom texted me when she saw the commercial with Tom Brady that said he's on the FTX team. And she said, "Where do you work again? It seems interesting." So it was a hugely positive reaction. It was a national audience.

Ryne Miller: (08:38)
There were some commercials that played during the week's NFL games. Anyway, Tom Brady is one of our endorsers. He's been hugely enthusiastic with his wife, and we're proud to be able to partner with him to reach potential users of our business.

Robert Hackett: (08:51)
Excellent. Zach, tell me a little bit about the outlook for derivatives in the US. It seems like it's caught on slower here than it has abroad. There were some businesses that Ryan mentioned that were big on options trading, one of them, the hammer came down on, BitMEX.

Robert Hackett: (09:09)
The founders got indicted for some funny business that they were up to. And FTX filled in the gap and got a lot of customers after they fell by the wayside. Why has it been so much slower going in the US than it has been abroad?

Zach Dexter: (09:24)
I think it just takes a while to get through the registration process as a clearinghouse, as an exchange. And here in the US, because of the split regulatory regime between the SEC and the CFTC, there's been a lot of attention paid to just getting the spot businesses up and running. Most people have started there. We actually decided to start on the derivative side, but the registration process for a clearinghouse, for an exchange de novo, can take four to five years.

Zach Dexter: (09:49)
So it is an intensive process. And for that reason, I think just because of how new crypto is, that's how long it's taken. And it's as simple as that. But that doesn't mean that it's on a constructive regime to work under. I think it's extremely constructive. And if you approach the regulators, you register, you fill out the paperwork, you walk them through what you're doing, it can make a lot of sense for people to enter the US derivatives spaces.

Robert Hackett: (10:14)
What is the biggest change you would make to the US regulatory regime right now?

Zach Dexter: (10:21)
I think the biggest change should come from the industry side, actually. The framework is there. The CFTC has a website where you can see the forms for registering for any kind of derivatives activity that you want to engage in. And the response from the industry to date has been somewhat tepid. There hasn't been a lot of registration, frankly, over the years. And I think I'd like to see more of that.

Zach Dexter: (10:42)
And the more engagement there is from the industry, the more walking in the front door there is. As opposed to trying to seek no action relief or get around the regime, I think the more we'll see from the regulators in terms of a positive response to innovation. But I think it's the responsibility of the crypto industry to approach them constructively and through the front door.

Robert Hackett: (11:03)
Although I think it might depend, because Coinbase certainly seemed to try this, at least in the telling of their CEO, Brian Armstrong. He said they knocked on the door, tried to do everything by the book, and they sort of got slapped as a result. So I wonder whether that is the right approach, asking for permission, and whether people will be received warmly.

Ryne Miller: (11:26)
I've been with FTX almost two months, so I'm a legacy employee at this point. But we've found the regulators receptive to meetings, all the way up to the top of the SEC and the top of the CFTC. They're going to give you those meetings, and across the state regulators, too. They want to hear what you're doing. They want to hear what your plans are. They've had very thoughtful questions.

Ryne Miller: (11:48)
They've done their homework on I think, all the businesses in this space that have notable profiles. And what they don't always do is say, "Here is a clean and clear, unambiguous path to what you want to do." And that's not their job. And it's not their job to give you the legal counsel and to create a strategic plan that works for you and them.

Ryne Miller: (12:08)
And it really is an engagement. And sometimes it takes longer, I think Sydney alluded to this, than just one meeting, answer, go forward. And that can be frustrating. And I think what we've seen in some of the recent posting is folks, you get tired, you get frustrated. And you try to ... let's push another way and see if that has a different result to be seen.

Sydney Schaub: (12:29)
Yeah, I agree with that. Obviously, it's been a long road, and a longer road with some regulators than others. I think that the CFTC has been much faster to weigh in and offer guidance and thoughts, as Zach mentioned. And obviously DFS, a success story there. I think there's been some criticism of the SEC, not only recently by Coinbase, but going back prior to that, that they were a little bit slow under the prior chairman to take a position on crypto. I think that there were some regulators and some industry players, financial industry players who didn't think that crypto was real.

Sydney Schaub: (13:13)
And if you think back, I remember we were talking before the panel again, a bit just about how much more legitimate crypto has become, and how much more regulators have started to pay attention to it. Even when I started at Gemini, which was almost three years ago, the notion that the Treasury, that Janet Yellen would be paying attention to crypto and putting out a statement and thinking about stable coins ...

Sydney Schaub: (13:38)
Gemini launched our stable coin, the Gemini dollar, through our DFS regulated entity in 2018. And the notion that Treasury would be thinking about or caring about this technology, that seemed improbable at the time. And so much has changed. So I think there is a learning curve for all of us to come up, and regulators are no exception to that. And different agencies vary in terms of their response to the crypto industry. And it depends on the personalities, who's there, whether they're curious about it, whether they're open to it, and what else is on their plate.

Robert Hackett: (14:17)
Now, you mentioned stable coin, so I want to just double click on that for a second, because the Fed is obviously very interested in looking at digital currency initiatives.

Robert Hackett: (14:25)
They are kind of doing a survey of the space and trying to understand whether there's a place for the government itself to offer a stable coin of the US dollar. What is your best estimation of how that's all going to shake out, and whether Gemini dollar can exist in that world, where maybe there is a sort of Fed coin?

Sydney Schaub: (14:46)
Yeah, I wish I knew the timeline. I think there's a lot of speculation and questions around the timeline. It is clear that the Fed and many other regulators are looking at this. And it's again, gotten too big to ignore. I think this is an incredible proof point for the technology, that the notion of a central bank digital currency is a real, legitimate notion.

Sydney Schaub: (15:15)
And that a number of governments, not just the US, obviously China and others are looking at it. It's again, an incredible proof point for blockchain technology. It's our understanding that the president's working group, which is made up of a whole host of federal regulators, has been looking at this. They've been engaging with the industry.

Sydney Schaub: (15:37)
And that they're planning to release a white paper. Again, no real sense of the timing there. And it'll be interesting to see what it says, and what regulators do to actually promulgate any kind of regulation around that.

Robert Hackett: (15:54)
Are you speaking with the Fed members about that? Are they canvasing private industry for-

Sydney Schaub: (15:58)
Whenever anyone reaches out to industry players for our thoughts, we always respond.

Robert Hackett: (16:03)
Got it. By the way, I want to make it known also that I'm going to open up the floor to questions in a little bit. So we will reserve time. If anybody in the audience has something they want to ask, you can start thinking about that now.

Ryne Miller: (16:18)
You're already quitting being the moderator?

Robert Hackett: (16:20)
I am, yeah.

Ryne Miller: (16:20)
You just started.

Robert Hackett: (16:20)
No, I'm bailing.

Ryne Miller: (16:22)
Okay.

Robert Hackett: (16:23)
Ryan, I'd like to get your view on this as well, because I asked Zach. What is the biggest thing you would change in the US regulatory regime, as it relates to crypto?

Ryne Miller: (16:35)
Yeah, it's a good question. I think I'm tempted to say it would be awesome to have a single federal source to go and get your crypto regulatory stack, as opposed to, let's say navigating a 50-state maze and other territories, et cetera. But I'm not sure that's where I want on a land.

Ryne Miller: (16:54)
I think I want some clear policy priorities from regulators, and they've given us these in many senses, and then an ability to engage towards a solution that meet those policy priorities, even if they don't fit inside of the technology that regulation was designed for many years ago.

Ryne Miller: (17:12)
And so customer protection, transparency, risk management, if you can show up with really strong faith, not just good faith, really strong faith products that meet customer protection, investor protection, transparency, disclosures, then let's find a path to get that to the market. Particularly when you've got this non-US market that's become super competitive for US investor dollars, US institutional investors, let's acknowledge it.

Ryne Miller: (17:38)
Maybe it's at the federal level. Maybe it's federal and state partnerships really engaging on this, but I think it's being open to new products that we all admit on day one don't fit inside of our traditional regulatory structure. And Zach mentioned the laws are already there. I think they pretty much are. Certainly, the principles behind the different policy goals that we want to see pursued, are there. So let's use the regulation and legislation we have.

Ryne Miller: (18:03)
If there's new legislation, great. Let's not overdo it. But I think just a real encouragement, maybe it's a sandbox, or maybe it's a movement towards a sandbox, and say, "If you've got a really strong faith product that meets our policy priorities, we're going to get that to market." That's a big ask, but I think that's the idea.

Robert Hackett: (18:20)
And this single front door you've described, is this a new governmental entity, or is this an existing one, a partnership across various ones? It seems like the SEC would like to be that place. And Gary Gensler is certainly positioning the agency in that way.

Ryne Miller: (18:34)
So look, the banking regulators are prudential regulators. They care about systemic risk. The prudential safety and soundness of the financial institutions that we authorize provide those services to users. And then the CFTC is a markets regulator. They care about integrity of markets, efficiency of markets. And the SEC is sort of investor protection and disclosure and capital formation.

Ryne Miller: (18:56)
So, do we need a new regulatory body to come up besides those? Probably not. But I think what you're seeing in Treasury and FinCEN, I'm sorry, Treasury and FSOC is an ability to bring those regulators together and maybe figure out ... You don't see a lot of partnership among regulators for new regulatory programs, but something like a partnership with our existing regulators where they're working together and say, "This can work."

Ryne Miller: (19:21)
And a lot of it does depend on the products itself. So investment products, you're thinking CFTC or SEC. But as you get more towards traditional banking products, I think it's fair for the bank regulators to have an interest. So it's maybe not one single front door, but the ability to have the regulators partner on regulating those entities or products.

Robert Hackett: (19:41)
Got it. Before we open the floor to some questions, I want to ask Sydney the same question. What's the number one policy proposal you'd push through, or something you would change about the current regulatory regime?

Sydney Schaub: (19:53)
Yeah, I was thinking about that as Zach and Ryan were responding to the question. And I think that it is really challenging, given how many different regulators have an interest in crypto. Ryan went through some of them, and there's also the sanctions in money laundering, know-your-custom component that FinCEN brings to the table.

Sydney Schaub: (20:14)
So between markets and prudential regulation around safety and soundness, and consumer protection disclosures, and market surveillance, et cetera, that's just the way that the US system has grown up over the years, for better or worse. You have a number of different constituents that potentially have a perspective on the asset class.

Sydney Schaub: (20:38)
And again, Gemini has been fortunate to work with DFS, that brings all of those things to bear from the state perspective. And because we're in a federalist system, you have 50 states that have the ability to regulate as well. And then the Feds can come in and there's preemption, but only in part. And so it's a complex a host of folks.

Sydney Schaub: (21:03)
We again, have been by and large, very happy with our relationship with the DFS and with the innovation team there. I think to the extent that federal regulators could take that perspective, and as Ryan suggested, perhaps come together, and as Zach suggested, there's perhaps an opportunity for some self-regulation among industry, to come together.

Sydney Schaub: (21:28)
And obviously, FINRA came out of that spirit in the securities industry. So I think that there's a potential for some self-regulation for the like-minded crypto companies that do want to continue to foster a sense of security, safety, and trust in the asset class.

Robert Hackett: (21:46)
That's something that Tyler and Cameron, the founders of Gemini have been pushing for a while now, to have a self-regulatory body. How has the progress been on that initiative?

Sydney Schaub: (21:56)
That's right. We have long been in favor of self-regulation and for a level playing field with respect to that, actually a statutory mandate around a self-regulatory organization. I think people differ about whether the CFTC in particular, has the statutory authority to mandate an SRO. I think that from a principal's perspective, we continue to believe it.

Sydney Schaub: (22:22)
And actually, since those conversations, and I believe it was 2018, there has been a great example of industry coming together, not as an SRO per se, but the US Travel Rule Working Group, which has now been renamed Trust, is an industry consortium of which Gemini is a part, Coinbase and others, is creating a technological solution to the travel rule.

Sydney Schaub: (22:49)
Which not to go into too much detail and have everyone's eyes glaze over, there's a rule in the traditional banking industry that certain information has to be transmitted along with certain transactions. FATF and FinCEN have mandated that with respect to certain crypto transactions from a technical standpoint, just because of how crypto works.

Sydney Schaub: (23:11)
It's very challenging to implement that, but industry has come together to think it through and to bring expertise to bear on how the government's legitimate interest in anti money laundering and protecting the ecosystem can be applied to this novel technology.

Robert Hackett: (23:33)
Excellent. So let's toss it over to the audience for questions at this point. We've got a little over five minutes left. I see one in the back. We'll start with you. Yeah. Oh, and please give your name and title.

Speaker 5: (23:48)
[inaudible 00:23:48].

Ryne Miller: (23:55)
You just yell. Yell very [crosstalk 00:23:57].

Robert Hackett: (23:57)
We can hear you.

Speaker 5: (23:59)
[inaudible 00:23:59] My question, from the legal [inaudible 00:24:11].

Robert Hackett: (24:21)
Okay. So the question is, with the software upgrades and changes to the Ethereum network that have recently been passed and are still to come, is that going to affect the classification of Ether? Before, there was an SEC advisor who had suggested that it was decentralized enough not to be a security, but could these changes affect Ether's status?

Ryne Miller: (24:45)
I think Bill Hinman, the former Director of the Division of Corporation Finance said directly that transactions involving Ether were not securities transactions. And I think he came out the right way there. In fact, I'm sure he did. The background to me is, who knows?

Ryne Miller: (25:01)
Who knows what tokens are or are not going to become a security? I think the SEC has done a decent job trying to show us at least their thought process. We've got the framework. We've got the Howey Test. We've got the Dow Report. I think all of those things give counsel a lot of tools to do the analysis and come to reasoned views.

Ryne Miller: (25:22)
I think without jumping on Eth 2.0 and what the new analysis is, if it's more or less decentralized than it was before, we do know that the SEC cares about decentralization. And to me, it's important that they gave that guidance. And I think it's helpful. I don't know, Sydney, if you have thoughts past that.

Sydney Schaub: (25:38)
Yeah. The changes to Eth 2.0 and how exactly they will come out, and what exactly the chain will look like and the ecosystem will look like, I think it's TBD. And Ryan is right, that there has been some guidance in Bill Hinman. Obviously, not so much an official guidance, but in creatively titled speeches and through the FinHub, which has been a very helpful source of information from the SEC around how we should think about token taxonomy and whether or not a crypto token constitutes security.

Sydney Schaub: (26:14)
There has been some guidance there. Exactly how Gensler and his SEC will apply that and change that and augment that, and particularly with respect to the specific changes in Eth 2.0, I think that's a little bit beyond the scope of this panel. But I generally agree with Ryan's comments here, of course.

Robert Hackett: (26:37)
Excellent. Thanks for your question. Over here. I don't know if our microphones are working.

Rhonda: (26:42)
Hi, I'm Rhonda. I am running a [inaudible 00:26:43] school for the underserved and to get the message to persons who are not in the room. So a question for when earlier Sam mentioned three jurisdictions that you had approval, regulatory approval in. You mentioned Bahamas, Gibraltar, US. Are those the three? And what can you do in those countries? Thank you.

Ryne Miller: (27:10)
Yeah, it's a good question. So remember at the beginning, we've got the FTX US business, which is a US focused business right now. And then in the US, we do the spot cryptocurrency exchange, and through LedgerX, futures and options down on the road. LedgerX is doing those now. FTX.com is looking at several different jurisdictions globally, two of which are The Bahamas and Gibraltar.

Ryne Miller: (27:33)
And they have different licensing regimes there that have been open for us to explore. And I think that's the path we're going down, both in The Bahamas and Gibraltar. What we're able to do with those licenses, it's dependent on different jurisdictions, how they structure their derivatives industry. But part of our derivatives business will be there's.

Robert Hackett: (27:54)
We've got a question right here. We've got a mic coming.

Mitchell Dong: (28:04)
Hi, I'm Mitchell Dong. Pythagoras' crypto hedge fun. So Gary Gensler is thinking about going to Congress to get spot exchanges regulated. And obviously, the CFT is already regulating derivative exchanges. In Asia, like Huobi, Binance, OKEx, they're unregulated exchanges with both spot and futures, which some of us traders find very convenient.

Mitchell Dong: (28:31)
It's going to be kind of funny or awkward to have spot exchanges regulated by the CFTC. I mean, excuse me, SEC, and derivatives by the CFTC. How do you think you're going to sort that out?

Ryne Miller: (28:44)
I have so many thoughts on this.

Robert Hackett: (28:45)
Well, we've only got one minute left.

Ryne Miller: (28:47)
It's the time. Yeah. Look, there are a handful of provisions in both the SEC's statutory authorities and the CFTC's, that if they jointly decided to go after any financial products set out there, I think they could create a regime where they partnered together and had some credible jurisdiction over that. And so I think there's at least an intellectual path for spot exchanges to find a spot somewhere between CFTC and SEC regulation.

Ryne Miller: (29:18)
As you know, today, all the CFTC gets is fraud or manipulation authority over the spot exchange itself. And then they've got the clear regulatory authority over the derivatives. I don't see the SEC's clear or direct path to the spot exchanges right now, but I think if they're willing to partner with the CFTC, who's got that fraud and manipulation authority, and potentially do some exemptive-based language where both sides preserve some ability to be involved, you could have a path for some federal regulation.

Ryne Miller: (29:46)
The question is, does it solve for any of the 50 states? And if not, then it's just another layer on top of it. But if you got there, if you got an SEC CFTC partnership over spot, then you could probably have a much more direct relationship between the spot and derivatives markets, which would be a good outcome for US traders, I think.

Robert Hackett: (30:05)
Well, that is all the time we have. I hope that everybody took something away from that conversation. There's certainly no shortage of things to discuss when it comes to regulation, as it applies to crypto. Sydney, Ryan, Zach, thank you so much for being here. And thanks for your time, people.

Ryne Miller: (30:18)
Yeah.