Quadrillions: The Crypto Capital of the World | Acting Chairman Pham

And I said, look, America is back. We want you to come and invest, hire, and build in America. We have regulatory clarity. Uh, yes, you can conduct these activities here in a regulated manner. And that's actually had such a huge impact.

Quadrillions is a miniseries produced by Blockworks and is sponsored by Canton Network. Nothing on this show is a recommendation to buy or sell securities or tokens. It's for informational purposes only, and the views expressed by anyone on the show are solely their opinions, not financial advice or necessarily the views of Blockworks. Our hosts, guests, and the Blockworks team may hold positions in companies, funds, or projects discussed, including those related to Canton Network. All right, everyone, welcome back to Quadrillions. Very excited about this one. We have Acting Chairman of the CFTC Caroline Pham here to talk about regulations, and the US. Let's get into it.

Thank you. Thanks so much for having me here.

Yeah. Yeah. Very excited about this one. Um, okay. Let's, let's jump right into it. So I was reading one of your quotes from, I think it was back in January of this year. You said, uh, you kind of publicly declared it is time for the CFTC to get back to basics. I would love to just hear what you had in mind when you said that.

Yes, 100%. I'm so glad we're starting there because that really has been my mantra ever since I came back to the CFTC for the fourth time as a commissioner. So a lot of people have heard kind of my origin story, but I started off at the CFTC as an intern, actually in the enforcement division when I was in law school. So I have the benefit of honestly, for the past 15 years, my whole career started and has been shaped by very much the CFTC and the markets that it oversees. So I have this institutional knowledge I know what the CFTC was like in the quote unquote old days. We actually celebrated our 50th anniversary as a commission this year, which was an amazing thing to do to celebrate for our staff and for, you know, all of our former chairmen and commissioners and the whole community that we have around the CFTC. And generally speaking, I feel like your roots is really important. Like you really need to understand like where did you come from, you know, why are you here in order to know where you should be going and what your future should look like. So for me, the CFTC has always been about a mission that is to ensure that our markets are well-functioning and that we're protecting market integrity and that we're preventing fraud, abuse, and manipulation. I mean, it's pretty straightforward. And, you know, in order to really understand that in context, you of course have to understand what are the markets that the CFTC oversees. So we oversee everything that is basically not a security. And we're talking about the intersection of the real economy and financial markets. So it's all asset classes. I mean, yes, everybody talks about commodities, which is like gold, silver, oil, you know, natural gas, lumber, grains, um, pork bellies, frozen orange juice concentrate, right? So all of those, you know, ag commodities, the physical commodities, but also we oversee the rates market. The biggest market in the world. We oversee FX markets, we oversee credit markets, we oversee certain equity derivatives, we oversee all the markets. And so it's really looking at this $700 trillion notional financial market that we oversee that's global by design, by nature. That's something that means that we really need to be on top of our A-game. And we really have to get back to basics. That's why we have principles-based regulatory framework, by the way, because of the breadth of the markets and the fact that there's always innovation happening. What does that mean, like, from a concrete perspective? So I was very focused on ending regulation by enforcement, right? There had been this period of time where I think we really lost that touchstone that I'm talking about, you know, making sure that we have markets that serve the economy by giving people a place to mitigate price risk by being able to do price discovery and being able to have price dissemination so that way people understand like, you know, how much is a bushel of corn? You know, how much is a barrel of oil? You know, how much is whatever of gold? Um, how do I price my 30-year IRS, right? All of these things, uh, people want to know from our markets. And instead of being focused on the well-functioning markets piece of it, I think it became a little bit about How do we get big headlines? You know, how do we kind of chase after the issue du jour, go after, you know, whoever we've declared are the bad guys, you know, do trophy hunting almost. And I feel like that's not what we should not— that we should not be doing that. That is not what the government is for. The government is not there to pick winners or losers. The government's not there to say this industry or this sector is a bad industry or a bad sector. We're here to make sure that the rules are clear, that the game is fair, that people are able to build, to grow, to use our markets for what is intended, you know, to really serve the economy, the commercial economy.

If I can, Jason, I just want to, I just want to chime in. I just cannot applaud enough Commissioner Pam for what she just said. I think that a lot of times people ask me, 'Are you excited about all the new rules that are coming, you know, to the space?' And I say, 'Yeah, I am excited, but actually what gets me more excited is the posture of the administration and the regulators, because it is— it is even things that were possible within the regulatory framework, and previously people were scared to use the technology.' because it was the posture that was just talked about that was intimidating. It's like, yeah, we think it's— we're okay to do what we want to do, but we actually think we're going to get in trouble regardless. So it's actually the posture, the positive posture. We're here to innovate. We're here to allow use of technology. That posture, in my opinion, is actually the biggest bolster of this space in the last year is that both administration and regulator like Commissioner Pam have said, no, no, no, we want you to use this technology, we encourage it, and we're going to do it in a safe and sound manner. Yeah.

Yeah. Thank you so much, Yuval, because I think, look, it's not just Operation Chokepoint 2.0, right? It's not just that. It is the fact that there was what I've called before almost this allergic reaction to new technology. So it's sort of like, oh no, no, no, this is new, it must be bad. We have to be very skeptical. We have to kind of discourage people using this new technology. And I also think that's something unfortunately that got lost in this whole narrative in Washington was this idea that bad actors who commit fraud in the crypto space means that the blockchain technology is bad. Now that's just, crazy to me. I'm sorry. Like, a technology is not good or bad, it's just technology. People do good things and bad things, but people commit fraud all over the place, no matter what, anything, right? You know, you go down to the street and, um, you know, somebody could be trying to mug somebody else, uh, people. So that's just where I feel like that got all mixed up together and really was just wrong.

Yeah. Yeah. I mean, the pace of innovation inside of the organization right now has just been pretty remarkable. Maybe we can actually talk about, um, uh, I'd love to get your take on, there's a lot of conversations right now about how to divide responsibilities between, uh, the CFTC and the SEC. Um, especially, you know, we've got this comprehensive market structure framework that's coming. Uh, and there's been a lot of talk about what is the, you know, I think the industry maybe thought the SEC was the most important, then it was like, oh, maybe the CFTC is more important for our industry, or maybe they're both important. I'd love to hear how you you think about dividing responsibilities here?

They're both important. They're both really important.

Yeah.

I think, um, people have gotten kind of hung up on this part.

Yeah.

I think hung up to a degree that's overthinking it, to be honest. So one of the other things about getting back to basics is it's actually also very much getting back to regular order, right? The CFTC has existed in one form or another since the late 19— 20s or early 1930s, I think. The SEC also similarly from the 1930s. And we've always engaged with one another in a productive and responsible way throughout the last, you know, almost 100 years. And then especially once the CFTC came into its current iteration in 1975 as a commission, actually modeled after the format of the SEC, right? So it's like a board of directors. There's 5 commissioners. One of the commissioners is the chairman. I am the acting chairman right now, and also the whole commission, but that's a different story. So the, uh, it's always been a very healthy and very respectful working relationship, right? Right back to, you know, I like to talk about like in the 1980s you had CFTC Chairman Philip McBride Johnson, who actually was one of my law professors when I was at GW Law, which is really cool to take regulation of derivatives from him. and then you had, um, SEC Chairman John Shad, and they came together and they were like, well, we've got some of these new products and, you know, it's sort of, uh, based on a security, but it is like a derivative. And, you know, we think, you know, where's, where do we draw the lines here? Um, and they sat down and they hashed it out. And it's that spirit of just coming together and trying to find a practical solution, right? We don't have to overengineer it. We don't have to overthink it. Let's just come together and think about what's best for the market and what supports Responsible Innovation. That is exactly the same spirit of cooperation and working together that SEC Chairman Paul Atkins and I brought to the table when we decided to do our joint roundtable for the first time in 15 years, not since Dodd-Frank had the SEC and the CFTC done a joint roundtable. And so that was on September 29th. It was a huge success. It's just, I think that's also the kind of positive, constructive energy that we're bringing to the table in this administration about wanting to just tackle problems head-on, coming up with pragmatic solutions, and not getting so hung up on, like, red herrings or false flags that people have kind of made into a boogeyman. Okay, what does that mean from, like, a practical perspective? Okay, there's a lot of different products where Single stock futures is something that came up a lot during the roundtable. That was a product that sort of was kind of a failure to launch, and honestly, it was— a lot of it was because of a turf war situation, um, and people trying to sort of protect their, um, maybe their regulatory moats, possibly. I'm not sure. I don't, I don't want to like over, uh, belabor it, but why not try again? Like, that's something that we want to come together and try again and see if that's something that we can make work this time if we don't focus so much on, oh, is it yours or is it mine? But just let's look at the merits of the product. Let's look at the liquidity profile. Let's look at the economics, like what's the best way. So that's why I said at the beginning of that roundtable, we should be taking almost a blank piece of paper and thinking about what is the best, most optimal market structure to foster liquidity formation, and capital efficiency. And once we know what good looks like, then let's figure out how to get there from a regulatory perspective. Yeah. So it's very outcomes-focused and I just think that's the most productive way to do it.

Can we get into the nitty-gritty of some of the, the, the work, the work that you've been working on? I'd love to hear like the, the, yeah, just the projects and the challenges that you've been trying to tackle and that you're trying to get done in the next couple of months or, or even next year. Yeah.

Yeah. So, um, so I just told you what the endgame is, right? Right. Like that's the endgame. Let's come up with a market structure that provides the most liquidity formation, the most capital efficiency, and both of us have very robust and strong regulatory frameworks, right? I don't think anybody's looking at our securities exchanges and saying that those aren't like the, you know, best in class gold standard around the world for efficient capital markets, right? I mean, our stock market is incredible here in the United States. Everybody wants to, you know, start their public companies here, get access to our public markets here. Also for the same similar reasons, the futures markets that the CFTC oversees are also the gold standard and the best in class. And we set the prices for commodities all over the world. And when I say commodities, again, I'm being very broad. It's everything from 10-year treasuries, right, to yes, like barrels of oil and, you know, the price of gold in our futures markets. So they both work, they're both, tried and true, time-tested. That's why we did a joint statement between SEC Chairman Atkins and myself, where we did this joint statement where we said, yes, we're going to start to look at allowing different kinds of assets to trade on, you know, futures exchanges and on securities exchanges. Because if we're trying to regulate crypto, right, we want to bring it inside the regulatory perimeter, then let's do it. Let's put it on our futures exchanges. Let's put it on our securities exchanges. Let's apply our existing regulatory frameworks to that. So how are we, how are we getting there? So as you all know, the President's Working Group on Digital Asset Markets issued a report. Sometimes you call it the White House Crypto Report. It's really a roadmap for the administration about how we're going to tackle digital assets and provide regulatory clarity here in the United States. And that was issued at the end of July. So the SEC announced their Project Crypto, which is how they're going to make America the crypto capital of the world, enable tokenization, enable digital assets in their markets. And I launched the CFTC's Crypto Sprint. So the CFTC's Crypto Sprint is a 12-month initiative. We will be all done implementing the CFTC's recommendations from the President's Working Group report by August of next year. It's fast, but I've been saying since the last couple of years, but I put out an op-ed in March where I said, yes, I think we can implement all of this in 12 to 18 months and like we're going to do it. So the first phase of the CFTC's Crypto Sprint was a comment period. Like a public consultation on listed spot crypto on our futures exchanges with leverage. So in our statute, and it's been in there since Dodd-Frank, so since 2010, it actually says that if you are doing a retail commodity transaction, so let's say like, you know, retail Bitcoin, spot Bitcoin, and there's leverage or margin or financing, then it must be traded as if it was futures. Meaning it needs to be traded on a futures exchange. So it's been there. We've had this authority all of this time, right, for 15 years. But nobody's ever said how people should do that. And actually, people have come to us to propose ways to list these products on futures exchanges since at least 2020, maybe even earlier than that, that come to us and asked us to do that. And honestly, you know, the CFTC wasn't comfortable with it at the time. They weren't comfortable with it. They didn't approve it. They didn't allow it to go forward. Um, but I kind of wish that they had because I think you'd see America being at the forefront of digital assets and crypto instead of playing catch-up right now. But at least, you know, it's never too late. I'm glad that we're doing it now. So that's a very important part of the CFTC's crypto sprint. We have the comments, um, they're very helpful. People were very constructive with the comments, and so that's why I'm saying we're going to approve it and it's going to be, um, live listed spot crypto with leverage live on our futures exchanges by the end of the year. Uh, the other, um, the next, you know, phase or part of the CFTC's crypto sprint was where I asked for comments on tokenized collateral, including stablecoins, in CFTC markets. So this builds upon this fantastic initiative that my Global Markets Advisory Committee, which is a industry and public advisory committee that's got experts from, you know, every aspect of the market, whether it's the sell side, the buy side, service providers, financial market infrastructures. Yuval, thank you for your service on the Global Markets Advisory Committee. We created a Digital Asset Markets Subcommittee. And so key amongst the accomplishments of what I'll call the DAMS, the Digital Asset Markets Subcommittee, is that they put out the first ever US digital asset taxonomy. Which was really a resource to help guide US policymakers to bridge what fits within the US legal and regulatory framework and what's already been established overseas. Because, you know, look, the rest of the world has been moving forward. Obviously, Europe has the Markets in Crypto Assets regulation. There's been Financial Stability Board principles. There's the International Organization of Securities Commissions principles, other jurisdictions in Asia. Have come up with their, you know, regulatory regime. So this was really going to bridge it, right? This was going to help show how the United States could integrate because it's a global market. We can't, you know, just be on an island here by ourselves, even though we are the biggest market. That was super important. The other really important recommendation that the GMAC did was around tokenized non-cash collateral. So think about tokenized Treasury money market funds. So there is a set of— it was a principles-based approach. Really looking at standards, set forth a number of different recommendations. So I announced in September, end of September, yeah, towards the end of September, I announced a tokenized collateral and stablecoins initiative. And I was happy to do that with some key partners from the industry. So the firms that had participated in the CFTC's Crypto CEO Forum that I held back in February, so that included, you know, Circle, and Ripple, Coinbase, Crypto.com. So, you know, these firms are leading the way in some of the adoption of this technology. So we also have an open comment period on that. We will, and we ask people to look at the GMAC recommendation, provide feedback on that, but just generally speaking, provide more feedback on what they think this should look like. So when, as just as soon as we get outta shutdown, we're gonna go and look at all of those comments. We're gonna put that together and create an advisory. So that way people can feel comfortable using tokenized collateral in our markets. Now I will, you know, skip to the end of the book and tell you that our rules allow it, right? Like it's technology neutral. Our rules just say treasury money market funds are eligible collateral, right? It doesn't say that it has to be on paper or it needs to be in a computer or it has to be, you know, on a blockchain. It's just technology neutral. So some of the principles that we're going to reinforce in our advisory are just that. It should not matter what is the technology wrapper around the underlying asset. So that's a key, key aspect. I think I've always said that I think the killer app for stablecoins is collateral management when you think about the efficiencies. And so I'm really proud and excited about that. Then the next phase, so that's all by the end of the year. For next year, I think that stablecoins will probably be live collateral and cleared markets, like so for our clearinghouses, probably in the first or second quarter of next year. And then the only remaining part of the crypto sprint is then to make all of the technical amendments to our rules that'll be necessary to enable the blockchain technology. So those are rules like collateral eligibility, margin treatment, clearing, settlement, reporting, and recordkeeping. I think we can do all of that with just one rulemaking to kind of edit all of about a half dozen rules. That's also out for comment right now. It's more technical, so we're going to really need to, you know, get that information and then do something thoughtful. But we can do a proposed rule, um, uh, first quarter of next year, and then we can finalize that rule in second quarter, and then boom, the 12-month crypto sprint is done, and we now have regulatory clarity, uh, at the agency level for, uh, crypto and tokenized, uh, assets.

Yeah, amazing. It is very cool to see how quickly you guys are moving. Yuval, I would actually love to ask you, um, you were kind of nodding your head around like tokenized collateral, collateral on-chain. Like, why is this something that you think is so important?

Um, I think I, I share a lot of times this stat that I don't think people appreciate. Only about 15% of eligible collateral ends up being used. And it's not because people don't want to use more collateral. It's because moving collateral in an efficient and cheap to deliver is not very possible today. And I think that that's really one of the biggest opportunities with this technology. So I do believe that collateral management, whether it's into clearinghouses, but even just as you think about global banks thinking about how to manage their balance sheet more efficiently. Is probably one of the biggest low-hanging fruits opportunities out there today. I think that the fact that you are able to deliver collateral, I think people should not be mistaken that every collateral will have the same risk parameters. And this is really what I like about the DAMS working group is that you're creating a framework to say, yeah, you can deliver tokenized collateral. But again, we need to make sure that we create frameworks and standards of people figuring out how to price that collateral. So for example, today, when you're a clearinghouse, you'll say, well, if you deliver me cash, I'll give you 100% benefit, because cash is king, right? And then after that, I think it's like treasuries are like the next best thing. But already there, you're getting a haircut on your collateral, and then you go into like Indices and even single names could technically be speaking given as collateral. But again, they start to get less, less and less treatment. And I think that one of the things that have been great in these working groups is really starting to think about how should we think about the risk of collateral. So I would say stablecoins are a huge step forward. I think it's a huge opportunity. But again, it doesn't mean that all stablecoins are created equally and understanding the frameworks, understanding where the deposits are being held. Are they all being held in treasuries? Are they being held as deposits? I mean, all of those things are things that, you know, what Commissioner Pan have done is really trying to say, we're going to enable tokenized collateral, but we also need to understand, like, how do we look at it, right? Because again, they're not all going to be created equally, and we need to educate the market. So I just think, first of all, as an opportunity set, it's one of the biggest. I think that there are still a lot of tools, instruments like working with rating agencies, thinking about how do we rate collateral from a quality perspective, understanding what is the liquidity. Because if you're a clearinghouse, clearly if you need to put your hands on the collateral and liquidate it, you need to make sure that you could actually do that. So all of those things are things that will have to happen. But again, having a regulator that is saying like it should happen, we encourage it to happen, and let's do it in a safe and sound manner is kind of like, in my opinion, the most important thing. And now you're going to see all the innovation around how to make it possible and safe.

Yeah.

Yeah. And I can't emphasize like how everything Yuval was talking about is so true, but it's also something that we know is true. I mean, we are talking about institutional wholesale markets. People have been looking at collateral and what is eligible collateral and what is good collateral and how do you manage the risk of collateral. So just because it's a new technology doesn't mean that we forget all of the lessons that we've learned and all of the standards that we have around this. And in some, in some cases it may be just as simple as doing a look-through to the underlying collateral. So if you have literally a treasury money market fund and it's registered with the SEC, it just happens to be tokenized. Maybe you just look through and you're like, yep, that's a treasury money market fund. Right. And it doesn't matter the technology that's enabling it.

Hmm. Chairman Fan, I'd love to get your take on just making crypto America kind of the crypto capital of the world. For, I think, you know, you've all and I've been building in the industry for a while, and it feels like every couple of years the industry goes back and forth between, you know, it's all in on China and then China shuts down Bitcoin mining, goes to the States, then SEC cracks down on it, then it goes overseas, then it comes back. And how do you think about like making it so that that does not happen again, that America is the crypto capital of the world?

I love this question because I worked at one of the biggest global banks in the world, so I know exactly what it's like to have to thread that needle between your legal entity strategy, you know, what are your permissible activities, where do you want to find the talent, where do you want to set up your, you know, key hubs, that kind of thing. So I feel like I actually am fairly uniquely qualified to answer this question and figure out how to do it. So I'll tell you how the, how the CFTC is making sure that America is the crypto capital of the world, right? So number one, cannot understate the chilling effect of, like you've all said, the regulatory posture of the last several years, right? If all of your regulators are publicly, even if privately, they are okay with the technology and obviously examining it and understanding that people are, you know, utilizing blockchain technology in a safe and sound manner, which the Prudential Bank supervisors were doing. But if publicly you're saying that crypto or blockchain is bad, then yeah, people— doing things that are illegal is very bad for business. Going to jail is terrible for business, right? Having an investigation that goes on for 3 or 4 years is horrible for your business. What's going to happen to your investors, right? Look at your cap table. So I just feel like this is such a basic thing, but everybody was— businesses and companies want to do the right thing because that's good for business and it's good for their customers. It's good for their employees. It's good for their management. It's just people want to do the right thing, generally speaking. All right, so changing that narrative, changing the overall tone from the top, um, getting that messaging. I think the executive order from day one was super powerful from the president, and then obviously the, um, president's working group passing the Genius Act, huge. Working on market structure legislation, huge. And then what we're doing at the, um, agency level, uh, one of the things I've done to really make sure that we change the tone and the narrative is I actually went on a roadshow, like the greatest roadshow on earth, which is selling America, pitching America. So I went to Money 2020 in Middle East, and I went to Korea Blockchain Week, and then I went to Paris as well. And I said, look, America is back. We want you to come and invest, hire, and build in America. We have regulatory clarity. Yes, you can conduct these activities here in a regulated manner. And that's actually had such a huge impact. I've had a lot of different crypto companies come up to me and say, you know what, we were thinking about expanding in Singapore. We were thinking about trying to hire more in Paris. But you know what, now we're going to come to New York because the talent is in New York. We see that the regulators in the US are prepared to move very quickly. Actually, I think people are not— I think people are having actually a hard time processing just how fast the SEC and the CFTC are moving and how much it's a complete 180 from what was going on before. Because also, I've been thinking about how to do this since 2013. Many people in the industry have been thinking about how to do this since 2015, 2016, 2017, 2018. So everyone's like ready to go. We just needed to flip the switch and say, yes, this is legal and you can do it in this way. All right, so getting the word out, huge. There's a couple other things. One of the things that I think is really important but hasn't gotten enough airtime is what I consider to be like two key lessons from Dodd-Frank, right? So I worked on the Dodd-Frank rulemakings at the CFTC. I then went to Citi and worked on implementing Dodd-Frank. Dodd-Frank is the most consequential piece of market structure legislation that we've had in the United States. And so there's a lot of lessons learned as we work on, you know, coming up with this new regulatory approach for digital assets. So number one, regulatory moats, right? Dodd-Frank created these massive regulatory moats, which made it very difficult. It created consolidation and concentration in the sector. It also made it really difficult for new entrants startups, entrepreneurs to get going. It was just cost prohibitive because of the registration, compliance, reporting, and other capital requirements. All of that just completely non-economic, not commercial. The second thing is market fragmentation. So by not thinking about having a harmonized cross-border framework, it really fractured pools of liquidity. It created essentially a US pool of liquidity and a non-US pool of liquidity. And that was detrimental for, you know, efficiency, pricing, capital management, risk management, all of that was really a very unfortunate consequence of this United States, the CFTC's initial approach to Dodd-Frank implementation. So for the last 15 years, the CFTC has been trying to fix the cross-border framework for swaps for Dodd-Frank. I have done a ton of that. It's actually taken up a lot of my time at the CFTC so far. So I've done a couple things. Number one, I've told everybody that we should be using our existing registration categories, which already have passporting and mutual recognition for non-US entities to come and get registered in our market. So for example, a lot of US companies went and set up non-US affiliates, like let's say in the EU. So now I'm saying if you are a regulated market under MiFID, in the EU, you can apply to be a Foreign Board of Trade, an FBOT, with the CFTC. It's a much faster path to get recognized and begin legally operating and offering direct access to US participants to your exchange, your foreign exchange. And you don't have to stand up and separately capitalize a US legal entity. So that's a really key aspect of trying to make sure that these are global markets and that we have— they're frictionless as much as possible and that we have these deep pools of liquidity and we don't have market fragmentation. I'm also working on trying to see if there's a way that I can do recognition for these crypto asset service providers, like crypto spot exchanges, like under MICA, for example. Is there a way that I can provide recognition of those using my FBOT framework? That's another key aspect too.

Yeah, if I can just add real quick there, you know, maybe a more simple answer is with everything that Commissioner Pam just said, I think the way we don't go back, because that was part of your question, is we just need to put real shit on chain. You know, we actually need to drive real businesses. And the reality is that, you know, with whomever will come back and try to change, right, it's almost like saying like ridesharing or like things like Uber and Lyft can now not be legal anymore. There is no putting the genie in the bottle anymore, or Airbnb, right? As much as people will want. And I think that the important task for us, and I think it's critical for our industry to achieve, is actually take these regulated markets and put them on-chain and show all of these benefits. Because once you do that, there's just no going back. So we have this like really like unique opportunity in time to actually make it happen. And then I just, I just don't see how it comes back. And I will say that once you do it in the US, it also becomes a platform how to do it elsewhere. And I think that we saw that in the previous administration. Every time you would go abroad, they'd go, well, you know, what's going on in the US? You guys are behind. And now everybody's trying to catch up to what is being done in the US. So I also think that generally speaking, US markets, just as a result of the size and what Commissioner Pam said early on, it's effectively kind of like the model which everybody follows will become kind of like a lighthouse tower, right, to actually show how this gets exported abroad.

Yeah, 100%.

Yeah. And I'll give you two— I'll give you two examples of commercial use cases. That exactly proves Yuval's point, right? Um, because I've literally said we have to Uberize crypto because anybody can come along and ignore the laws and the rules on the books. That's what happened in the last administration. We already had laws and rules that prohibited the regulation by enforcement, but they just decided to ignore it. So even if we get the market structure legislation, somebody else in the future can just ignore it. Like, then where does that put us? You have to Uberize it. You have to massively scale it. You have to have adoption so that you can't take it away. It's politically untenable. So that means in the institutional use case, I think repo is a great example. I think looking at sort of digital securities issuance, like whether it's digital bond issuance or something else, is a great example. And in the retail use case, again, when you are able to trade the crypto on a securities exchange or futures exchange, that is going to be something you just can't, you can't take away. If you have Bitcoin in your brokerage account, like you're not going to take that away from people.

I mean, we are already today, I don't think a lot of people know, we are already today getting close to doing 10% of the US repo market on-chain. So we do about, one of our partners is doing $400 billion of repo every day and already showing the value of the technology. So I just don't think that there's going back from that.

Yeah. I think that's a good place to wrap. That's an exciting note. Chairman Pham, first off, thank you for joining the podcast. Great chatting with you, but also just thank you and congrats on everything over the last, you know, many, many years of the work that you've been doing. And yeah, Yuval, congrats again on all the work you guys are doing.

Yeah, and maybe just to take this opportunity, we should congratulate and thank Commissioner Pym for coming to an end soon on her tenure, and good luck. A good run. With a new journey.

Yeah, indeed.

Thank you. Thanks so much. I can't wait to build.

Indeed.