Latest / Bitcoin for Financial Services Podcast / What Regulators Actually Think About Bitcoin: A Compliance Chief on RIAs, Cold Card, and Debanking

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What Regulators Actually Think About Bitcoin: A Compliance Chief on RIAs, Cold Card, and Debanking · Bitcoin for Financial Services Podcast

• 0:00
  Yeah, I think, you know, when these cases come up, you know, generally it's a reactive response from a regulator.
• 0:10
  You know, I know this is not the same way, but like FTX, et cetera, when there is a large kind of public event, they're going to kind of look at if there is any kind of like first thing is they're going to try to find like retail client harm, right?
• 0:25
  Like were there assets that you potentially managed that were impacted and clients were impacted and obviously they lost money.
• 0:35
  If there's no general loss of funds, they may kind of go for the bigger fish, right?
• 0:42
  You know, for that area.
• 0:44
  So I think, you know, once they dig in, they're going to look at, is there a way that you could have reasonably identified the issue?
• 0:52
  So looking at your kind of vendor due diligence program.
• 1:22
  Everything is bullish for Bitcoin.
• 1:24
  Immoral.
• 1:25
  It's going up forever, Laura.
• 1:27
  Fix the money.
• 1:28
  Fix the world.
• 1:52
  Be convinced from a qualified tax legal or investment advisor to determine whether any information presented may be suitable for their specific situation.
• 1:56
  Past performance is not indicative of future performance.
• 1:57
  Any statements or opinions are subject to change without notice.
• 2:04
  Welcome back to Big Mark Financial Services podcast.
• 2:09
  Joined by special friend, Mark Dempsey, founder of Crypto Regulatory Solutions.
• 2:14
  Thanks for joining us, Mark.
• 2:16
  Thank you, Wyatt.
• 2:16
  And thank you, Jordan, as well.
• 2:18
  Looking forward to the conversation.
• 2:22
  Yeah, and for exciting conversation today, it's a pleasure of getting to know you over
• 2:30
  the last summer by a mutual friend, Eric Runge.
• 2:38
  He's also going to be out at the summit.
• 2:41
  We started working together in August.
• 2:43
  It's been awesome.
• 2:44
  I always joke that I have to have been, I don't know if I've ever actually told you this,
• 2:48
  but I tell other people that I had to have been your easiest sell ever.
• 2:55
  No, yeah, they, I won't, you know, you're, you're not,
• 2:58
  I won't give you that, but it was, it was a great conversation.
• 3:04
  It flowed really well. And I think, you know,
• 3:07
  it comes down to like when you come across when there's a right place at the
• 3:10
  right time and you got need and you have, you kick it off. It kind of,
• 3:15
  you know, it moves a little faster, I think.
• 3:18
  Yeah.
• 3:20
  I was excited to get to meet you in Columbus, right?
• 3:24
  Being on the panel together, that was fun.
• 3:27
  And yeah, I don't think we had crossed paths before that.
• 3:30
  So that was good.
• 3:31
  And like Wyatt, I'm also excited for this conversation because, you know, we were speaking about it right before we hit record.
• 3:38
  But a lot of people sleep on this specific side of financial services landscape, especially in the Bitcoin space.
• 3:46
  but in order for us to actually achieve the goals that we're working towards,
• 3:51
  like this is very important.
• 3:53
  And if we could nail some of the stuff that we're going to talk about today
• 3:56
  with regulators and having them understand things more clearly
• 4:01
  and then legislate that way, that would kind of propel us into the future.
• 4:06
  So looking forward to it.
• 4:08
  Wyatt, you want to kick us off with the first question for Mr. Mark?
• 4:11
  Yeah. And so framing this in the context of, you know, I get, this isn't very Christian. I try to find it, fight it, but I do get envious of Jordan sometimes not only because of his good looks and, you know, successful business, but how much lighter the CPA compliance seems to be than the RIA compliance.
• 4:33
  compliance. And I know you have a lot of history in the compliance and regulatory space. So I would
• 4:40
  love to hear about some of your background, different parts of your career, where you worked,
• 4:46
  how you got in the space, and ultimately how you ended up kind of pivoting out of it and starting
• 4:52
  crypto regulatory solutions and working. Do you exclusively work with RIAs or is it other
• 4:57
  professional service providers? And maybe just how you started the business, the services you offer,
• 5:01
  and how those two seemingly despair worlds in Bitcoin land seem to overlap in your work Yeah no happy to Yeah my first kind of entrance in the compliance regulatory side as I worked at FINRA who regulates broker dealers This was a little bit after the financial
• 5:20
  crisis. So I was on the mortgage-backed security, asset-backed security team. So
• 5:24
  they launched a team after the fact, right? But it was a great, obviously a great learning
• 5:35
  experience this is outside of dc so i'm originally from delaware lived in baltimore for about five
• 5:41
  years i've been in the dc area ever since 15 plus years jordan's a ravens fan i don't know if you
• 5:47
  knew that dude did anyone catch the game i know we're that's a meme in the bitcoin space but the
• 5:52
  game last night actually was crazy yeah i watched it mark so given that i grew up in northern
• 5:59
  Delaware I'm an Eagles fan by okay so it was tough we had a rough weekend yeah yeah we had two two the
• 6:07
  last two weekends were kind of rough for both games I would say that we probably should have won but
• 6:12
  yeah yeah no so the so at Fenra from there I served in the when I was in college served in the
• 6:23
  in the Marine Corps Reserves. And at that time, I came across the AB Federal Credit Union.
• 6:31
  They're based, like headquartered outside of DC in Vienna, Virginia. So worked on their compliance
• 6:36
  side. They have an RIA broker dealer and worked out to be their chief compliance officer. So was
• 6:43
  there for about five to six years. So that was really my entrance into kind of wealth management
• 6:49
  side. They have financial advisors across, you know, across the country and many of the Navy
• 6:54
  federal branches, as well as, you know, some digital offerings as well, kind of direct,
• 7:00
  direct to clients. And that's where I got my, you know, certainly my experience of running a
• 7:05
  client's team, SEC, you know, examinations, et cetera. And then from there, I was in-house at
• 7:12
  Mission Square, which runs like private sector retirement plans in DC, and then got into the
• 7:18
  consulting side about six years back, well, five plus years back. And that's right around the time
• 7:27
  where I discovered Bitcoin. And, you know, obviously being, you know, involved in financial
• 7:34
  services, I'm not, I'm not the one giving advice, I'm giving it our investment advice, I'm giving,
• 7:40
  you know, more compliance regulatory advice and came across Bitcoin, as well as obviously some of
• 7:47
  the other digital assets and was interested and kind of wanted to learn more about it.
• 7:53
  So kind of went down some of the rabbit holes, definitely listened to some of the Michael
• 7:57
  Saylor videos, et cetera.
• 7:59
  They kind of got into that.
• 8:01
  I'm actually going to see him.
• 8:03
  He speaks tomorrow at DC FinTech Week.
• 8:06
  And, you know, what I wanted to kind of understand is a way that I can have a pathway to kind
• 8:13
  of get into the Bitcoin space and then still kind of stay in my lane, like with regards
• 8:19
  to my background on investment advisor compliance and, you know, worked at a consulting firm
• 8:25
  that focused in that area.
• 8:27
  So worked on like wealth managers and hedge funds, VC firms that were kind of in the space
• 8:34
  maybe earlier on.
• 8:36
  And I like being in the gray area because I think, you know, there's definitely on the
• 8:41
  compliance end, it's not always like the, you know, the most fun and exciting role. So having that
• 8:49
  kind of daily kind of gray area kind of experience was exciting to me and still is. And we've
• 8:57
  obviously gone a long way in the last, you know, even five years, but we still have a little ways
• 9:02
  to go from clear rules and regulations. And I started about back in February, so just about
• 9:13
  eight plus months back. I really wanted to, always had a desire to kind of go out on my own,
• 9:20
  develop, you know, be an entrepreneur and focus my business on helping primarily investment advisors.
• 9:28
  I do, you know, I, you know, given my background, you know, I can, you know, have the ability to work with like broker dealers and, and other projects, but primarily with investment advisors in the space.
• 9:40
  And those are both state registered and SEC registered investment advisors.
• 9:44
  Today's episode is brought to you by Falcon, Rappaport & Bergman, a full-service law firm
• 9:56
  with one of the most respected digital asset practices in the country. FRB works on digital
• 10:01
  asset, tax and IRS matters, fund formation, estate and trust planning, and regulatory guidance for
• 10:08
  RAs and fintech services. As Bitcoin moves deeper into wealth management, their legal partner,
• 10:13
  advisors and family offices turn to when questions get complicated Learn more at frvlaw Very nice Yeah I mean i think uh why did i you know we spent some time in vegas talking
• 10:32
  specifically on like the de minimis tax law we could go like i'd be curious i'm just gonna throw
• 10:38
  some of these out there i don't know why it has specific things so we don't have to go here
• 10:42
  immediately but another one i'll throw out there beyond the you know maybe clarity act and like
• 10:48
  crypto tax legislation is the the mining the mining revenue recognition I don't know if you've
• 10:55
  ever had any clients or looked into that but at some point I don't want to hop on this off of this
• 11:01
  podcast without discussing your thoughts on on basically how Bitcoin is being singled out as a
• 11:08
  commodity with its tax treatment right now and if you see any uh have you seen any creative ways to
• 11:14
  to kind of circumvent that in the near term while we let the legislators do their thing
• 11:18
  or if you uh if you're bullish on bitcoin being treated similarly to like gold binding so i'll
• 11:26
  just throw all those out there because those are some like three things that i want to make sure
• 11:29
  that we talk about but i know why it likes why it has a structure and he's like yeah to this i'm
• 11:35
  gonna get to that so why you i'm gonna let you jump in and you ask a question i just want to
• 11:40
  make sure I got that off my chest. No, I appreciate it. I mean, we have cold notes for a reason. I
• 11:46
  know you don't really look at them or read them, but we might as well start there, Mark. I'm curious
• 11:52
  in your thoughts and opinions too. Yeah, I think on the, I mean, one of the lucky things of being
• 11:59
  right in DC, so we're in Capitol Hill. And I know that the, like PubKey has their, like a number of,
• 12:07
  you know, Bitcoin focused events. I think the Bitcoin Policy Institute's based there. Some
• 12:11
  folks have kind of definitely run into a lot of the areas. And I know that all the things that are
• 12:16
  items that you're mentioning with regards to tax legislation, you know, and, you know, mining
• 12:23
  revenue recognition have come up and they're definitely fighting for Bitcoin. You know,
• 12:30
  I think one thing that I've learned, especially through this and through the clarity act is this
• 12:35
  legislation takes a lot of time. So even if we're not in where we want to be today,
• 12:43
  there is some opportunity to get there. I think what's been clear on the legislation side and on
• 12:50
  the regulatory front is education has helped definitely paint the picture and understand,
• 12:59
  because I think there was a lot of misunderstanding or lack of understanding for many years.
• 13:04
  And now it's, you know, Bitcoin's, you know, it's not going, you know, it's here. It's not going away. So it is an area that has to be dealt with. And I think some of the legislation with the de minimis tax, I think to me makes a lot of sense, especially if you're just using, you know, the asset for small purchases.
• 13:27
  And then with regards to, I know that how the revenue recognition and singling out Bitcoin compared to other assets is not fair.
• 13:42
  So I think we're moving towards that direction.
• 13:46
  Unfortunately, I don't know if there's going to be a lot of material movement in the short
• 13:52
  term just because midterms and then we have other areas.
• 13:58
  What I do believe is it does give an opportunity for states to step in in some areas.
• 14:04
  I know that obviously from a tax perspective, you want to have a federal kind of mandate.
• 14:09
  But with regards to Bitcoin across the board, I think there's some opportunities to make
• 14:14
  headway in the states and say the coming year where there may not be a lot of activity or
• 14:20
  opportunity on the federal level yeah we've definitely gotten a lot less announcements
• 14:26
  in all caps from our our boy i'm forgetting his name right now but you guys know i'm talking about
• 14:32
  yeah mr porter yeah yeah mr porter so yeah that was we've looked through an interesting time
• 14:39
  on the regulatory side right there was at the beginning of the trump administration it was like
• 14:43
  every week another state was announcing that they're going to buy bitcoin and it seems like
• 14:49
  a lot of that is fizzled i guess in your in your conversations and what you've seen
• 14:54
  and especially with how things are probably trending on the midterm side i mean are we
• 15:01
  are we like walking right back into uh like a desert time where we're just going to be wandering
• 15:07
  in the desert for 40 years?
• 15:10
  Or do you think that it's bipartisan enough
• 15:14
  on the Bitcoin-specific side
• 15:16
  that we can still make headway,
• 15:19
  even with a divided Congress?
• 15:23
  Yeah, I think there's a lot of different ways
• 15:28
  you can kind of look at that.
• 15:29
  I think from a general, you know,
• 15:32
  given if the midterms obviously if flips in the midterms the head of the regulatory agencies are not going to change at least for the next two years So the SEC CFTC et cetera
• 15:44
  However, there's definitely going to be certainly a focus.
• 15:50
  Maxine Waters heads the financial services from consumer protection.
• 15:57
  I think, and then this is my opinion, right?
• 15:59
  is I think if you look at it from an investment advisor perspective, you're offering Bitcoins,
• 16:07
  you know, or advice to investors, potential investors. Bitcoin's like clearly a commodity
• 16:13
  from that aspect. So it's going to be not directly related by the SEC. In the States,
• 16:20
  obviously, if you're a regulated entity under theirs, you know, they could definitely look into
• 16:25
  that activity. But I think from the altcoin perspective, I think there's a lot more risk,
• 16:32
  right? That there is maybe a flush out of some of these projects. I think from, in my opinion,
• 16:43
  I think there's more bipartisan support on the Bitcoin side. It's obviously been around the
• 16:50
  the longest, it's easier to have that conversation with regards to regulators from a Bitcoin
• 17:01
  perspective.
• 17:06
  Yeah, it's interesting, Mark, because kind of how I see the regulatory compliance landscape
• 17:14
  shaped up.
• 17:15
  And this is specifically from my chair, my point of view.
• 17:19
  But I'm curious on how you kind of tell the story from your point of view,
• 17:23
  because when we look at the federal level, and we try not to use this word,
• 17:28
  but crypto has kind of been like this hot potato.
• 17:32
  It's like, is the SEC going to regulate it?
• 17:34
  Is the CFTC going to regulate it?
• 17:35
  Is this like random altcoin, a security?
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  And so there's all this murkiness that like grabs the headlines
• 17:43
  and what people talk about.
• 17:45
  But what I found is a state regulated RIA and, you know, for its ill wills.
• 17:54
  I think Colorado has been pretty good on this where I was actually really nervous when I got registered if they were going to like pepper me about Bitcoin.
• 18:03
  It's like, hey, this is what I want to do.
• 18:04
  But it's actually been like pretty laxed, you know, I would say from my perspective.
• 18:10
  And so do we kind of have like this disparity between like, okay, flashy headlines, all
• 18:18
  of a sudden certainly at the federal level, but ultimately like when I'm doing my day-to-day
• 18:22
  work and helping with clients, like the state regulators, and I know obviously all the state
• 18:27
  regulators are going to be a little different, but they've actually been like pretty hands
• 18:30
  off.
• 18:31
  Let us do what we want to do.
• 18:32
  You know, don't interfere with like what we're talking to our clients about.
• 18:35
  So is it kind of like the tale of two stories?
• 18:38
  Is there some way you tie this together?
• 18:40
  Like, how are you talking to clients about this?
• 18:43
  Yeah, I think I think from the regulator, from the state side and the SEC, they they have generally come across other firms that are often, you know, that are advising on Bitcoin.
• 18:55
  They're they're more comfortable.
• 18:56
  They understand the asset more.
• 18:58
  They're definitely going to look at from the volatility perspective.
• 19:02
  So, you know, as obviously as an RA, you have that fiduciary responsibility to your clients.
• 19:07
  So the the and as I know that you do, you document that why, you know, that investment in the best interest of the client and the client understands, you know, the risk and the volatility.
• 19:22
  And with that, you know, you're you're acting in your fiduciary capacity.
• 19:27
  And from that perspective, the regulators, you know, they treat they just look at it as another asset class.
• 19:36
  You know, you have bonds, stocks, alternatives. It's kind of in that bucket of, you know, they potentially look at it as a riskier alternative asset.
• 19:47
  But they're going to look at how you allocate, you know, across your clients.
• 19:53
  And then also every client's different, right? So every circumstance comes down to that, like facts and circumstances.
• 19:58
  So I think from that perspective, it's not as scary.
• 20:02
  I think the first conversations that I had with regulators, they kind of they they they push the brakes a lot more.
• 20:10
  So it took a lot longer to get registered.
• 20:12
  And and they kind of they were like, let's maybe we push it down the road a little bit longer and and the federal level will take care of it.
• 20:21
  Now they're kind of taking that responsibility.
• 20:24
  The states are as well as the SEC and CFTC are putting out proposed rules and guidance almost on a daily, weekly basis.
• 20:31
  to help inform the community with regards to the rules of the roads in absence of true legislation like the Clarity Act.
• 20:42
  So I think from a perspective of timely guidance, I think that's...
• 20:50
  Although some people would want to see the Clarity Act pass, I think you're actually seeing more material involvement with the regulators now than you probably would have if the Clarity Act did not pass.
• 21:03
  In the short term, that's, I think, beneficial.
• 21:05
  Obviously, long term, you want to have that legislation to fall back on.
• 21:10
  Thank you.
• 21:40
  funds.com. Yeah, I mean, I'm, I'm curious for the mix of advisors and like fund managers that
• 21:52
  you're speaking with. I mean, are you, since you started, you know, earlier this year, like,
• 21:58
  have you been reaching out to advisors to help in that effort on education? Or are you more
• 22:03
  fielding inbound from people who are saying, Hey, we're, you know, we already understand the basics.
• 22:09
  we're looking to build a product on top of this and we're like, well, why it's doing.
• 22:14
  I'm just kind of curious what that mix is.
• 22:16
  And then especially if you've had conversations with folks who are like, we feel like we're
• 22:21
  being forced to go down this path because clients are pushing us to do so.
• 22:27
  What questions are you running into consistently and how are you communicating things to the
• 22:32
  folks that are like, I don't get Bitcoin, but it seems it won't die.
• 22:36
  And so I have to, I guess I have to learn about it or talk to someone like you about it.
• 22:43
  Yeah, I think my clients kind of sit in two buckets, whether that's that Bitcoin native or they've been working in the space for a number of years, whether it's managing client assets through a pulled investment vehicle or through separately managed accounts.
• 23:01
  So I think in that perspective, their clients are maybe more informed. They're used to, they understand the asset class, the volatility. And then there are some clients that are kind of looking at more traditional that they're looking to add in that asset class.
• 23:19
  And I think that's, it's kind of a different, as you know, from talking to your clients, it's a much different conversation.
• 23:26
  conversation. But I think the majority, you know, from whether it's the hedge fund space or the VC
• 23:34
  or the wealth management space, you know, have been in the space for a number of years, and it
• 23:41
  kind of weathered the storm with regards to the asset classes as a whole. And then you have
• 23:52
  kind of the new larger institutions that I've obviously leaned in like Charles Schwab,
• 23:59
  Fidelity, Morgan Stanley that offer some investment products that offer Bitcoin exposure
• 24:05
  and other exposure that clients can use in addition to like, you know, more,
• 24:10
  you know, holding the actual asset of the underlying asset.
• 24:17
  yeah are you seeing a lot of folks that like go down the rabbit hole and then they're like
• 24:24
  maybe i want to hold it in self-custody versus an etf and and especially on the lending side i know
• 24:31
  i mean why and you could probably talk a lot about this but this whole being able to lend against
• 24:37
  your or take a loan against your bitcoin but still have eyes on where it is from a self-custody
• 24:42
  standpoint um and then maybe at some point we can we can talk about regulations on obviously
• 24:49
  everyone doesn't want regulation on self-custody but after what we saw with cold card from a consumer
• 24:56
  protection standpoint alone right i mean i think that that's probably a conversation that has to be
• 25:01
  had so but i'm curious on the lending side specifically be it you got to hand over all
• 25:07
  all the control versus, hey, can we have some shared control over the asset?
• 25:13
  Yeah, I would say that on the wealth management side, whereas RAs are managing assets,
• 25:21
  in case where they potentially don't have custody of client assets, the assets are held at a qualified custodian or self-custody,
• 25:29
  You know, they that qualified custodian, whether that's Anchorage or whether that's, you know, Coinbase for et cetera, they generally would have the assets.
• 25:41
  And I would say that that's typically on the pulled investment vehicle side is generally pulled investment vehicles.
• 25:49
  Depending on the state, you have to have an annual audit.
• 25:52
  So the audit is looking at the custody and the control with regards to the storage and the custody of those assets So that audit is looking at where those assets are custody
• 26:09
  what's the process to initiate a transaction.
• 26:13
  And getting to the cold card, obviously, I think you both probably know the instance
• 26:18
  probably even a little bit better than me, but I think it definitely kind of opened the eyes
• 26:22
  like with regards to the risk related to self-custody,
• 26:27
  making sure that your clients understand the potential risk.
• 26:33
  And then I think there has been a movement since then
• 26:36
  to kind of multi-sig as well as qualified custodians
• 26:42
  or other custodians.
• 26:44
  But I think there's always going to be a portion of the community
• 26:49
  that chooses to self-custody, right?
• 26:51
  So I think that's not going to change, at least in my opinion.
• 26:58
  And I think there was definitely areas that it opened up from, I guess, a third party kind of due diligence perspective with regards to the wallets and et cetera.
• 27:15
  But I think that's kind of a bump in the road.
• 27:18
  And I think self-custody is going to improve.
• 27:21
  I think cryptology, it has not failed, right?
• 27:27
  It's just some, there's been, there were some areas,
• 27:29
  and I think there was a bug back in what, 2021,
• 27:32
  that just gave the ability that the actual keys that were being,
• 27:40
  it was, you were able to back into that.
• 27:44
  It was not truly random.
• 27:46
  So I think, I don't think AI played a role in this,
• 27:49
  But I think with AI, there's going to be a lot more attempts with regards to trying to crack some of these or infiltrate and have some additional cyber breaches.
• 28:01
  So it just really emphasizes the need for how important from a cyber perspective your controls and security is now.
• 28:12
  and it almost has to exponentially increase over time with,
• 28:15
  with like the increased risk that we see on a, on a, uh,
• 28:20
  almost daily and weekly basis.
• 28:22
  Yeah. Yeah. And just, just to say it for the record, right.
• 28:26
  It was a bug in a specific vendor's software,
• 28:29
  not a bug in Bitcoin core software,
• 28:33
  just for any newbie that's listening to this, like what the heck? Um, so.
• 28:42
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• 28:50
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• 28:57
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• 29:02
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• 29:05
  yeah well i'm curious mark i know you're not a lawyer but just you know having spent a lot of
• 29:15
  time on like the regulatory and compliance breach with the cold card situation itself
• 29:20
  you know maybe we can kind of take this in two parts like do you see any regulatory compliance
• 29:28
  and then if you want to put like your lawyer hat like legal breach on the terms of like
• 29:31
  cold card specifically themselves. And then, you know, when things like this happen and inevitably
• 29:38
  there'll be something else that happens, like what regulatory or compliance protections are in place
• 29:45
  for like the end consumer and then like professionals like engaging with different
• 29:50
  vendors, you know, you know, there is a breach of some sort of whatever, like what are like the
• 29:55
  appropriate courses of actions you should take to address and correct the situation. And then like
• 30:01
  what kind of internal policies and procedures should you have in place to, you know, be able
• 30:06
  to act accordingly? Yeah, I think, you know, when these cases come up, you know, generally,
• 30:15
  it's a reactive response from a regulator, you know, I know this is not the same way, but like
• 30:21
  FTX, etc., when there is a large kind of public event, they're going to kind of look at if there
• 30:29
  is any kind of like first thing is they're going to try to find like retail client harm right like
• 30:35
  were there assets that that you potentially manage that were impacted and clients were impacted and
• 30:42
  obviously they lost money um if there's no if there's no general loss of funds they may kind of
• 30:48
  go for the bigger fish right uh you know for that area so i think you know once they dig in they're
• 30:56
  going to look at, is there a way that you could have reasonably identified the issue?
• 31:02
  So looking at your vendor due diligence program initially and on an ongoing basis reviewing for for example the methodology with regards to the private keys is there ways that you could have identified it In some cases it would have been really hard
• 31:23
  you know, to identify that prior to actually that bug being identified. So in those cases,
• 31:31
  I think the regulators generally understand, but they want to see that,
• 31:36
  A, have you disclosed if you do have clients that have self-custody, do they understand that there is risk of loss of those assets?
• 31:48
  And some of this may come from complaints that come from those clients or customers across the industry.
• 31:56
  And they may say, I thought this was 100% protected.
• 32:01
  I could never lose my assets, which is obviously not the case.
• 32:05
  But, you know, it's coming it's coming down to this like education.
• 32:08
  And I think if you have a reasonable basis to like to identify and vet your vendors and then also adequately disclose the risk to your clients and to your investors.
• 32:21
  Those are the areas that the regulators seem to focus on.
• 32:31
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• 32:56
  Yeah, I mean, it brings up two interesting points.
• 32:59
  I mean, the first one I would say is just like, I think Coldcard would have been in, or CoinKot, I should say, their parent company, like, would have been in a difficult position, even if they had discovered it, right?
• 33:12
  Because they didn't collect emails, apparently, right?
• 33:16
  I think that maybe that's come out to be that they said that, but that was not totally true.
• 33:21
  um so they identify and say they don't have the emails how do you even communicate with
• 33:26
  with your customers that hey that that random number generator yeah they're our only job yeah
• 33:32
  we failed on that so you need to go move your funds you can't say that publicly because then
• 33:37
  everyone then you just uh tip off the bad guys yeah so that's kind of interesting not really a
• 33:42
  question just kind of interesting thought uh the main question would be like with coin kite being
• 33:47
  a Canadian-based company, and I know you deal, like, since Bitcoin and this whole world is so
• 33:53
  international and global, I mean, how do the regulators in the United States even approach
• 33:59
  a situation where the failure and loss of funds was all due to, you know, a company that's outside
• 34:06
  of the borders of the United States, or at least domiciled outside the United States, but has major
• 34:12
  operations in the United States? I'm just curious how they normally would go about that.
• 34:17
  Yeah, I think, you know, I think the, you know, like, I think the FTX is an example where they was it was a BBI, Bermuda, I think it was, but there was obviously a lot of operations in the US.
• 34:32
  You know, when there are those large cases, it kind of identifies the areas of their gaps, right? So I think it does speak to the need to have kind of that legislation and the sharing of information across jurisdictions.
• 34:48
  But I think that they probably are obviously more comfortable with working with U.S.-based companies that are regulated and you get a certain, especially ones that are audited.
• 35:01
  In the absence of that, they're definitely looking at the firm's kind of like, do they have a SOC 2? Are there other SOC reports that they have? They're reviewing, have you reviewed the return of control reports, et cetera, coming back to that due diligence.
• 35:18
  So I think in cases where assets are held at an offshore exchange, for example, that may have lax regulations compared to the US, that's where some of the red flags kind of tip at from the regulator perspective.
• 35:38
  But, you know, since it's that, I mean, the wall is just a hardware. It's not like they're, you're not transacting activities. It's obviously a lower risk, right?
• 35:49
  And I think in regulators, I think there's no per se AML obligation for investment advisors today.
• 36:00
  There was a proposed rule that got finalized.
• 36:02
  I expect that that will probably be pushed forward in the coming years.
• 36:09
  So I think the kind of anti-money laundering, know your customer framework is going to continue to kind of move into what it already is.
• 36:21
  But I think that going to just be and continue to be like a new normal with regards to you know with that kind of tracing of transactions and once the regulators have access to that they
• 36:35
  obviously want to be able to trace back those bad actors or their sanctioned wallets etc
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• 37:14
  Well, let's double click on that a little bit, Mark, because I believe it was Jameson Lopp
• 37:23
  that originally made this argument.
• 37:26
  At least I heard it from him, but founder of Casa, very similar to Unchained.
• 37:30
  We're seeing more and more of these businesses developing, which I think is a good thing,
• 37:35
  developing tools for folks like myself, folks like Jordan to utilize with their clients,
• 37:40
  their clients, you know, the development of self-custody, like all good stuff.
• 37:45
  And Mr. Lopp's case is with all this KYC information, you know,
• 37:51
  and you set up, you know, strike or unchained account,
• 37:54
  and you got to pull out your phone and scan your face.
• 37:56
  And like, I'm a pretty conservative libertarian guy, you know.
• 37:59
  I'm not like a big government folk over here.
• 38:03
  And his main argument is like, dude, you are creating via your regulations,
• 38:09
  like honeypots for bad actors.
• 38:12
  And I mean, it really, really puts a lot of strain
• 38:15
  on the entrepreneurial startup space
• 38:18
  because you have like, I mean,
• 38:21
  like we kind of touched on too, you know,
• 38:22
  with the AI and everybody's scanning
• 38:25
  everybody else's software.
• 38:26
  I mean, you have to have like legal compliance,
• 38:30
  security compliance, like, and not that they,
• 38:32
  you know, shouldn't, but you're just adding
• 38:33
  like a very large burden on them.
• 38:36
  So I do kind of push back against like the KYC argument
• 38:39
  a lot of the times AML argument because it feels like security theater to me and it's actually
• 38:44
  creating more risks and harm do you think I have a leg to stand on there do you kind of see it from
• 38:49
  a different angle yeah I think the um so the there has been like I think of the FinCEN had a
• 38:56
  beneficial ownership uh rule that was rescinded I guess probably the last year or so after the
• 39:02
  administration that required beneficial ownership of basically every U.S. based company
• 39:08
  and talking about a honeypot of information that could be leaked out that you could obviously argue
• 39:15
  that would be the case. So I think there has been movement with regards to understanding
• 39:20
  cases that are like overburdensome, especially for a small entrepreneur, small companies.
• 39:30
  But looking at, you know, looking at where, again, the Clarity Act didn't pass. So obviously,
• 39:38
  Lord knows what it's going to look like when and if it does.
• 39:43
  But they did, to try to get bipartisan support across the board, they did strengthen a lot of the AML KYC piece.
• 39:53
  And that would have, it generally would put the requirement on like the exchange side, you know, and the broker dealer side.
• 40:02
  So it may not go all the way down to like self-custody, wallets, et cetera.
• 40:08
  And so I think there's an understanding of like right size regulation and appears to
• 40:18
  be putting the burden on kind of the higher risk areas, like with regards to where there's
• 40:24
  a lot of transacting, the exchanges, et cetera.
• 40:28
  yeah yeah i mean we've even had some clients that you know they're considering bringing a certain
• 40:37
  part of their business on shore and but in order to do so they'd have to require kyc
• 40:44
  and that's honestly like one of their moats right is we don't you know we don't take your
• 40:51
  information and so for whatever part of the bitcoin network that they're operating in
• 40:56
  they get more customers because they're able to do that. I mean, I saw that you, um, that you do
• 41:03
  like part of your business model is consulting on the anti money laundering stuff and then helping
• 41:10
  companies set up in Bermuda, uh, or BVI. And just kind of curious if you could talk through,
• 41:16
  you know, are you still seeing like a good amount of activity where you have part of your business
• 41:22
  like operating out of that jurisdiction
• 41:25
  versus other parts in the United States or elsewhere
• 41:29
  and how they can all talk to each other,
• 41:32
  transact together, stay within compliance of US law?
• 41:38
  Yeah, I think from my experience
• 41:39
  came in and bvi side is typically on like pulled investment vehicles where those vehicles are
• 41:44
  domiciled in those entities and i think i think there's many reasons why like a hedge fund or
• 41:50
  vc fund would be domiciled there part of that's like tax related um the the actual aml requirements
• 41:58
  there in in some cases are actually more or stricter and more stringent than even the us side
• 42:05
  Obviously, there are certainly a perception that there are additional requirements on if you domicile your funds there than in the US, like from an AML KYC perspective that are stricter.
• 42:25
  I think, you know, from an operating company perspective, yeah, I'm definitely, again, that's not really my wheel.
• 42:33
  I wouldn't go to death and say that that's my wheelhouse.
• 42:35
  But I think it's been very common that the entities have been domiciled offshore with regards to, you know, mitigating some of the U.S. risk.
• 42:46
  And certainly firms have had cases where they chose not to have U.S. customers because it was unclear with regards to where the U.S. regulators were and still are.
• 43:00
  And so I think there is opportunity for jurisdiction review from a lawyer that would kind of look at the pros and cons and obviously your product, your offering, where your clients are, et cetera.
• 43:15
  so I think
• 43:17
  there has been a general trend
• 43:19
  to move on shore for some of these
• 43:21
  companies that did move offshore
• 43:23
  when you
• 43:25
  had a lot of the kind of
• 43:27
  regulation by enforcement
• 43:29
  where you only learned
• 43:31
  about what you should do
• 43:32
  when a new enforcement action
• 43:35
  came through
• 43:36
  and
• 43:39
  but I
• 43:40
  think that trend
• 43:42
  you know
• 43:43
  is going to continue to probably move on shore.
• 43:48
  But I think what's going to put the brakes on a little bit is I think some of the legislation,
• 43:57
  like you said, the tax side, as well as the Clarity Act side,
• 44:00
  they're potentially not going to have a lot of movement in the next six months or a year.
• 44:08
  So I think a lot of the firms that have gone on shore,
• 44:11
  you know they're probably still assessing where the best place is though um that the best place
• 44:17
  for their business um obviously to mitigate the risk and then from a cost perspective um and
• 44:24
  you know so i think it's kind of like a fact again coming back to facts and circumstances
• 44:30
  of your business and where and where where is best suited yeah it's uh it's interesting yeah
• 44:38
  Because we considered for PAX partners kind of doing a dual fund structure,
• 44:46
  that master feeder and having an offshore entity.
• 44:49
  So I was getting into the Cayman weeds a couple months ago.
• 44:53
  I was like, oh, my goodness.
• 44:55
  I was like, yeah, I think, you know, you correct me if I'm wrong here,
• 44:57
  but they have some sort of like global AML system or whatever that they, you know, opted into.
• 45:02
  I was like, wow, this is a real rabbit hole.
• 45:04
  I do want to get your opinion on choke point 1.0, choke point 2.0, and some of the fallout before that because of that.
• 45:15
  But before we do, I want to circle back to one thing you said about fiduciary duty because I've been kind of workshopping this idea and I want to get your take on it.
• 45:24
  I feel like, and I've discussed a lot of them on the pod here, but there's a lot of ill wills, I think, with the traditional wealth management industry.
• 45:32
  And specifically when it comes to Bitcoin, when I do talk to some skeptical, you know, RIAs, you know, my peers in the traditional finance world, it almost seems like they're actually hiding behind.
• 45:45
  This is my opinion. They're hiding behind a misinterpretation of the fiduciary responsibility they have to clients.
• 45:53
  And what I hear a lot is like, yeah, you have bigger shops. Like I think Fidelity is up to like a 10 percent Bitcoin allocation.
• 46:00
  But then when an advisor interprets like their fiduciary duty, they hide behind like one, the word itself.
• 46:07
  I'm not sure they actually understand their fiduciary duty.
• 46:09
  And then to like this broad, overly broad diversification of clients assets.
• 46:16
  So they don't feel like they can ever get like in trouble from a fiduciary standpoint.
• 46:21
  But when I read and interpret the fiduciary standard rules, it's incumbent on me to understand what my client wants, their level of understanding with their portfolio, and then make recommendations from there, what we already talked on.
• 46:38
  So are you seeing any of that Do you sit down with advisors and they regurgitate some BS understanding of fiduciary guidelines and diversification you like dude you totally wrong here Do you think my theory is like total BS and I should just stay in my lane No no I think I think there a lot
• 46:58
  of opinions, you know, from, from, from advisors. So I think, yeah, I think, I think, you know,
• 47:05
  the way that I look at it is, yeah, like the, you have to look at where you, where your client was
• 47:12
  was before you started managing their money, if you've documented all of their net worth,
• 47:21
  their risk tolerance, their time horizon. I think liquidity comes into a big part of that.
• 47:28
  With regards to, in many cases, they hold Bitcoin, maybe they had a pretty high percentage when they
• 47:35
  came to an advisor. And potentially you've trimmed some of that for liquidity purposes.
• 47:40
  But I think the old 60-40 allocation is kind of a little bit out the window.
• 47:49
  And I think even a lot of the traditional advisors will say that.
• 47:53
  I think that from advisors that advise and kind of focus on the Bitcoin space, in my experience, it is obviously, they're going to have probably higher exposure to Bitcoin compared to other traditional advisors, right?
• 48:15
  So maybe some of the Morgan Stanley's or Charles Schwab, they're like 2%, right?
• 48:21
  But some of the clients that you come across or some other advisors that are in the space, maybe they came to you and they have 80% of their assets, 90% of their assets in Bitcoin, right?
• 48:33
  So they're coming to you to look at, I want to manage my wealth long term.
• 48:38
  I believe in this asset class.
• 48:42
  So it comes down to the documentation, any additional education kind of risk related to that.
• 48:49
  And then managing that portfolio based on, you know, those, that individual client circumstances, like when are those kind of liquidity, you know, whether it's college or large expenses that you have to work around.
• 49:05
  So I think with regards to having adequate documentation and a good framework and understanding your clients goes a long way.
• 49:16
  right and the other way the other area where like regulators um may jump in is they have a lot of
• 49:24
  client complaints but if you've done if your clients understand the asset class and they
• 49:30
  understand the ups and downs they are less likely probably to to complain a bit about you personally
• 49:36
  um and how you're managing the clients so i think it it does come that it is a little bit different
• 49:41
  if you're a traditional advisor and you're kind of coming up, getting them off zero.
• 49:47
  And, you know, that is probably a little different conversation.
• 49:52
  But I think the fiduciary definition is broader than, you know,
• 50:00
  potentially what other advisors tell you why.
• 50:02
  So I don't think you're off there.
• 50:04
  All right, great.
• 50:05
  No, thank you.
• 50:06
  I love having my own biases confirmed.
• 50:08
  So that's a win for me on the day.
• 50:10
  I do have one last question in this realm before we finish up the conversation with Chokepoint.
• 50:17
  But I'm part of the Bitcoin Financial Advisors Network.
• 50:21
  And, yeah, we have like a quarterly like brain trust meeting and we share ideas, case studies, etc.
• 50:27
  And a few of those folks were CFPs, in a sense, dropped their CFP designation because they started getting nasty letters from the CFP board about Bitcoin and talking to clients about Bitcoin.
• 50:43
  So I'm just curious if you have run across that, if you have any thoughts and opinions on the map.
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• 51:01
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  sustainhash.com. Yeah, actually, I'm not going to lie, I have not directly heard about that. So,
• 51:31
  you know, a number of financial, a number of advisors, you know, could have CFP, some of them
• 51:36
  could even have a CFA if they were kind of in the asset management business before becoming an
• 51:41
  advisor. Yeah, I don't know if I can.
• 51:45
  I can't directly upon on that because I haven't had that direct experience.
• 51:51
  I do think that that is unfortunate if they're being forced to drop their
• 51:58
  designation just because they have a focus in the Bitcoin space I think that educating the CFP board and understanding the difference between investment advisors There like over 15 there like tens of
• 52:16
  thousands of investment advisors across the US. And some of them are very concentrated,
• 52:22
  especially on the alternative space where, you know, there is cases where,
• 52:28
  and there's some leveraged ETFs that two, three time leveraged ETFs of any asset you can think of.
• 52:34
  Right. So, yeah, I think, and some of those individuals have a CFP or CFA. So, yeah, I don't
• 52:42
  know. I don't know. I have not come across that. It's a, it is unfortunate that if that actually
• 52:48
  is occurring because I think if they understand that individual's business model and their clients,
• 52:56
  they might not come to that same conclusion. Right. Yeah. Interesting.
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• 53:35
  Yeah, so I think, I'm assuming what you're talking about is like choke point one point,
• 53:40
  you know, where like it was like, um,
• 53:44
  it could kind of go back to like the payday lenders, you know,
• 53:48
  companies that were marijuana focus, um, also, um,
• 53:52
  Bitcoin digital asset focus where they were unable to, uh,
• 53:56
  set up like business accounts and really be able to like, uh, act in the,
• 54:00
  in the traditional system and the banking system. And that, I think that, um,
• 54:06
  that was, uh, you know,
• 54:07
  I had a number of like years back that that was real, that they,
• 54:10
  it was hard for them to set up a U S bank accounts, you know,
• 54:15
  integrate with certain vendors because of the, you know,
• 54:21
  where they kind of were what industry they're in or what area they were
• 54:25
  focused in. I think that that I,
• 54:32
  I, I, it does not appear that that issue is,
• 54:36
  has like, has gotten worse.
• 54:39
  I think it's gotten better, generally speaking, that,
• 54:43
  especially I think with you, with regards to at least,
• 54:46
  you talk about Bitcoin specifically,
• 54:48
  many of the large institutions are leaning into, you know, for good,
• 54:53
  you know so I think that's case.
• 54:57
  I think that that the checkpoint 2.0 and 3.0,
• 55:00
  hopefully it's not impacting the Bitcoin community as much as it did say five plus years in the past.
• 55:09
  That's, that's my view, I think. However, I think that,
• 55:13
  that, you know, I think the hard thing is like, for example, if you're, and again, this is not my
• 55:27
  But if you're a bank or a credit union, whatever the case may be, you have you choose like where like who you're in trend, like potentially who you're going to work with.
• 55:37
  And you may not like it comes down to the education. Right. And they may just choose.
• 55:42
  We don't know this risk. We don't really understand the risk. So they just choose to cut it off altogether.
• 55:49
  So I guess it's, you know, that they potentially have that ability.
• 55:55
  However, I know there was like an executive order that they could not do that.
• 56:00
  So I think that they I think institutions are being forced to kind of better understand the risk and those industries and then be able to like regurgitate and discuss with a regulator why they have chose not to do business with a certain company, for example.
• 56:20
  so I think for what that's worth I think there's been some some positive movement to
• 56:26
  on the education front to to not appear to have that choke point but I think you know I'm sure
• 56:36
  some of that still happens today yeah I mean for what it's worth we just had a client got
• 56:41
  debanked um pretty big account and they got debanked from jp morgan chase and and so you know
• 56:51
  i always i mean it's uh it's spicy take but i mean they weren't willing to do business with
• 56:56
  this client but of course they they did business with jeffrey epstein so i think
• 57:01
  But it does create a lot of opportunity at least from my seat for the smaller banks that don have as much capital under management to come in and say well we going to learn about this and we going to create a niche in this environment
• 57:24
  And we'll take on a Bitcoin mining company and do their banking activity with them.
• 57:30
  So it's still kind of a weird world out there.
• 57:35
  If someone wants to go and set up a bank account with Mercury, generally speaking,
• 57:40
  It's like if they're a mining company, maybe just say you're a data center company.
• 57:44
  You know, don't get too specific with the wording there because we've still seen applications be denied just because you even have the word Bitcoin on your website versus, you know, of course, if it's crypto or, you know, some kind of scam altcoin.
• 58:02
  It's like I can understand that.
• 58:04
  I can get behind that.
• 58:05
  But Bitcoin is a totally different story.
• 58:07
  So I think you're right that it's just a complete lack of education or lack of curiosity from the big banks.
• 58:15
  Well, and building on that, Mark, I mean, I totally agree with Jordan.
• 58:21
  It's like, OK, in theory, you know, that free market dynamic should create opportunity for for somebody else.
• 58:26
  But, you know, we have Alan Lane, former CEO of Silvergate, coming out to the summit to talk about his time there.
• 58:33
  He just did, opened up quite a bit on what Bitcoin did and did an episode on his experience.
• 58:40
  And, you know, a lot of this is like post-mortem and understand like by legal decree from the president, which is my understanding, you know, executive orders kind of stop some of these antagonistic practices by the regulators.
• 58:57
  but you know it's not enshrined in laws so you know the next administration could you know
• 59:02
  overturn that but just in understanding this isn't wasn't your direct
• 59:08
  you line of regulations but just you know knowing folks that worked in that industry talking to
• 59:13
  folks like when we see this regulatory overstep like what how do you interpret that situation
• 59:21
  like and what is kind of like you're behind closed doors when you're talking to other
• 59:26
  the regulatory buddies, like what are people saying?
• 59:31
  Yeah, I don't know.
• 59:32
  I do think it was interesting.
• 59:34
  Silvergate was allowed to fail, but none of the other ones were, right?
• 59:38
  So like they, yeah, I mean, and again, this is my opinion, potentially because they were
• 59:46
  crypto focused, they kind of were SVB and obviously they were acquired.
• 59:54
  But, you know, again, I guess I think that comes, unfortunately, based on the, you know, the perception of risk, right, and perception of customers.
• 1:00:04
  um yeah yeah i think that's yeah i mean i think i think that i i agree with you i think that
• 1:00:15
  some of the larger institutions are going to have like they're very like if if you say you're in
• 1:00:21
  this industry then here's all the additional requirements that you're gonna have there's
• 1:00:25
  like there's they built that in their framework and there's no like getting around it so in that
• 1:00:29
  case, it's making it much harder. And it gives that opportunity, like, and that, you know,
• 1:00:34
  from capitalist perspective for smaller banks and credit unions to kind of lean in on the space
• 1:00:40
  and still operate within the regulatory framework and be able to provide, educate themselves on
• 1:00:48
  those industries and provide those services. So, you know, I think that's probably like you said,
• 1:00:53
  the win in this case,
• 1:00:56
  you may not be able to move
• 1:00:58
  some of these larger institutions.
• 1:01:01
  You may be able to push one or two of them
• 1:01:03
  but not across the board.
• 1:01:08
  Interesting.
• 1:01:10
  I appreciate that, Mark.
• 1:01:11
  Do you want to wrap it up now, Jordan?
• 1:01:15
  I was going to let you after my fumble.
• 1:01:19
  Dude, well...
• 1:01:21
  We've done, I've done that like three or four different times.
• 1:01:24
  So I apologize.
• 1:01:26
  Yeah, it's gotta be more than that, but it's fine.
• 1:01:28
  We worked through it anyway, but no, Mark,
• 1:01:31
  thank you for coming on, man.
• 1:01:31
  You're a plethora of information.
• 1:01:33
  Excited to be working with you.
• 1:01:35
  Excited to have you at the summit.
• 1:01:37
  I really appreciate your support and participation
• 1:01:40
  in BFFS land.
• 1:01:41
  But yeah, you know, if folks are interested
• 1:01:43
  in working with you, they want to ask you questions,
• 1:01:45
  pick your brain, kind of navigate the landscape,
• 1:01:47
  how do they get ahold of you?
• 1:01:48
  Yeah, again, really looking forward to
• 1:01:50
  going out to the summit as well
• 1:01:52
  in Denver. It's only about a week
• 1:01:55
  and a half away.
• 1:01:57
  Yeah, so get a hold of me at
• 1:02:01
  cryptoregulatory solutions.com
• 1:02:03
  my link to my socials
• 1:02:07
  and email and phone number
• 1:02:09
  right there. So feel free to reach
• 1:02:11
  out. Again, primarily work with
• 1:02:13
  investment advisors in the space
• 1:02:15
  as well as other
• 1:02:17
  institutions that are
• 1:02:19
  focus in the Bitcoin space, digital asset space.
• 1:02:22
  So, yeah, happy to be aware.
• 1:02:26
  Looking forward to seeing you both here at the summit.
• 1:02:29
  and see where we can go.
• 1:02:32
  Beautiful.
• 1:02:33
  Thanks so much for your time today, Mark.
• 1:02:35
  We'll see you very soon.
• 1:02:35
  Yeah, thanks, Mark.
• 1:02:36
  Thank you.
• 1:02:38
  Have a good one.
• 1:02:44
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• 1:02:46
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• 1:02:48
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• 1:02:51
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• 1:02:53
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• 1:02:55
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• 1:02:57
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• 1:02:58
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• 1:03:04
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• 1:03:09
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• 1:03:13
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• 1:03:21
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• 1:03:25
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• 1:03:28
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