Commentary on FSOC’s Annual Report: Respecfully, It Missed Something Big

June 29, 2016 / pwsadmin / Comments Off

The Financial Stability Oversight Council (FSOC) released its annual report on the health of the U.S. financial system on June 21, 2016. I believe it diagnosed many issues correctly, but missed an opportunity to encourage a key innovation that would give the FSOC what it repeatedly said it needs in the report: better data.

That innovation? It’s called “blockchain” or “distributed ledger technology.”

I write this post as a 22-year Wall Street veteran who’s seen a lot. I’ve worked directly for the co-CEOs of a global bank and had signing responsibility for the financial statements of regulated subsidiaries at various points. So I understand the issues on FSOC’s plate and respect the difficulty of its task. Oh, and I’m a blockchain “veteran” too—as much as that’s possible with nascent technology!

The FSOC report repeatedly called for better and faster disclosure of information that could enable regulators to assess systemic risk more effectively. Yet, instead of recommending that FSOC members explore whether blockchain technology can answer these calls for better data (as their brethren in the UK, Europe, China and Japan have done), the FSOC relegated blockchains to the second to the last page of the report (page 127 of 128).

The report’s discussion of blockchains highlighted that they may enable transactions to occur without trusted third parties, may “significantly improve efficiency by replacing manually intensive reconciliation processes and reduce risks associated with trading, clearing, settlement, and custody services.” FSOC then focused on the risks that participants and regulators would need to monitor, including operational vulnerabilities “that may not become apparent until they are deployed at scale,” and to the potential for “fraud executed through collusion among a significant fraction of participants in the system.”

But the FSOC report did not mention the possibility that blockchains can provide the improved disclosure for which its report made repeated calls.

In this post I hope to help regulators understand why blockchains can achieve this, and more. I wrote this post primarily for an experienced audience in the financial services regulatory field. For those not familiar with the jargon, the FSOC report has helpful background and a glossary (available here). As always, I provide no investment advice on this blog and you should refer to important disclosures here.

BACKGROUND ABOUT THE FSOC REPORT

For readers not familiar with FSOC, the Dodd-Frank legislation created it (1) to identify risks to financial stability of the U.S., (2) to promote market discipline by eliminating expectations that the U.S. government will bail anyone out in the event of failure, and (3) to respond to emerging threats. FSOC is an inter-agency council meant to coordinate efforts of the many different regulators of the U.S. financial system, including the U.S. Treasury, the Federal Reserve, OCC, SEC, FDIC, CFTC, state insurance regulators and other agencies.

The report, in addition to assessing risks in the financial system, among other things, is required to make recommendations “to enhance the integrity, efficiency, competitiveness, and stability of United States financial markets, to promote market discipline, and to maintain investor confidence.”

FSOC’S REPORT SUMMARIZED IN JUST THREE WORDS: “NEED BETTER DATA”

The executive summary of the FSOC report called 10 separate times for better access to information about the financial sector, citing the need for “improved collection of data,” “enhanced reporting and disclosure,” “improved transparency,” and more work to resolve “data gaps.” The executive summary then addressed developments in distributed ledger technology (a.k.a. blockchain), without mentioning the possibility that blockchain could solve all of these specific needs for better information.

ISSUES IDENTIFIED BY FSOC AND POTENTIAL BLOCKCHAIN SOLUTIONS

I’ll examine issues in the order listed by the FSOC report—with the exception of cybersecurity, which I’ll handle last. FSOC listed cybersecurity first, but I’ll address it last—truly saving the best (but most dense) discussion for last. Otherwise this blog post mirrors the FSOC report’s numbering, which begins at section 3.2 for those following the report side-by-side.

3.2 Risks Associated with Asset Management Products and Activities

In my opinion the FSOC got this right, properly identifying this as the top risk to the financial system after cybersecurity. I haven’t been afraid to criticize the financial industry by admitting no one really knows how leveraged the financial system is, but I’ve also defended the industry against its critics by affirming that the industry wants improved visibility into systemic leverage more than anyone else. So why hasn’t this been fixed? Answer: it’s an information problem. Let’s dig into FSOC’s specific assessment, and I’ll describe how blockchain can solve many of these information problems.

FSOC broke this topic into (i) liquidity and redemption, (ii) leverage, (iii) operational functions, (iv) securities lending and (v) resolvability and transition planning.

Liquidity and redemption risk: The liquidity and redemption risks of pooled investment vehicles, such as mutual funds and exchange-traded products, are fundamentally issues of what I’d characterize as “asset-liability mismatches.” It has always inherently been risky to allow daily liquidity in mutual funds and ETFs when the assets underlying them settle in T+3 days (or sometimes many more). Blockchains (1) could alleviate this inherent risk by permitting transparent, real-time monitoring of these vehicles and their underlying assets, or (2) could fix the problem altogether if the securities settlement system eventually moves to real-time settlement. There’s no technological reason why securities settlement is still T+3 days. This stopped being a technological problem years ago, but it has not been fixed because of legacy roadblocks (most notably, payment system latency and the interest of some securities lending participants in keeping the delay). Blockchains could eventually solve all of this, permitting transactions to settle instantly by enabling true delivery-versus-payment—thereby resolving the liquidity and redemption risks identified by FSOC.
Leverage risk: FSOC called out the leverage of hedge funds and collective investment funds as a risk, noting that, “While reporting on Form PF has increased transparency, it does not provide complete information…on the risk exposures of hedge fund leverage.” It also noted, “no single regulator has all the information necessary to evaluate the complete risk profiles of hedge funds.” FSOC called for better data aggregation and an assessment of the sufficiency of current data disclosure requirements. Blockchains could solve this by giving regulators a complete and real-time view into the financial system’s leverage, including into that of all major counterparties.
Operational risk: FSOC reviewed and will continue to analyze whether disruption or failure of a service provider, or provision of a flawed service, could transmit risk to the financial system. This is a broad topic, but it’s clear to me that many such service providers do pose systemic risk—which raises the question whether a more simplified market structure would solve many of the issues FSOC identifies. For example, one of the reasons why it takes 3 days for a securities trade to settle (or multiple days for an overseas payment to settle) is that the security (or payment) must pass through multiple institutions along the way—all of whom have leveraged balance sheets and could fail. Insecurities, the market structure is broker/dealer → custodian → central securities depository, or in payments the market structure is bank → correspondent bank → central bank. Such market structures evolved for historical reasons (e.g., paper contracts, telecommunications/network limitations, computer processing power)—most of which no longer apply today—and they introduce counterparty risk where it need not exist. Were we to design a system from scratch, it would not look like ours does today! Blockchain offers the potential for real-time settlement of securities trades and payments, whereby such service providers would not necessarily disappear but could transform their business models into fee-based rather than spread-based (i.e., client assets travel through their balance sheet) and thereby eliminating counterparty risk where it would not otherwise exist. Blockchains can automate the services of many of today’s service providers and reduce their contribution to systemic risk, including central securities depositories, custodians, clearinghouses, central counterparties (CCPs), exchanges, broker/dealers, transfer agents, trustees, servicers, asset representation reviewers and myriad other specialized service providers across different financial markets. Again, these institutions need not disappear—for example, there will always be a role for someone to structure a securities transaction or match buyers with sellers—but such services can be provided without involving leveraged balance sheets to which client assets are unnecessarily exposed.
Securities lending risk: For me this is a big one, and I’m glad to see FSOC agrees! FSOC split it into two parts, covering asset managers in this sub-section and repo markets in a separate sub-section later. I’ll follow FSOC’s ordering and handle them separately.FSOC said, “Without comprehensive information on securities lending activities across the financial system, regulators cannot fully assess the severity of potential risks to financial stability in this area.” I applaud FSOC for saying this! Such information does not exist—and we know this because, until blockchains came along, the technology simply did not exist to monitor these markets in real-time. FSOC called for greater transparency and enhanced and regular data collection and reporting among a wider array of lenders and borrowers in securities lending markets, plus better coordination foreign counterparts (because “current estimates suggest that half of global securities lending activities take place outside of the United States”). Again, blockchain might solve all of these needs!
And I would pose further questions for FSOC to consider in this area (with apologies that this paragraph uses so much industry jargon). (a) Since custodians often hold securities in omnibus accounts, how can asset managers really know and audit whether their securities lending programs always comply with stated restrictions? (b) How can asset managers know whether their counterparties rehypothecate the collateral they lend? (c) How long are collateral chains, really? (d) Is the practice of “easy-to-borrow” lists really regulatory compliant? (e) Given market opacity, how can fiduciaries of ERISA plans know that they’re receiving “no less than adequate consideration” for the securities lending programs of ERISA plans—and is it even possible to answer this question if “hard-to-borrow” securities are not auctioned separately? Blockchains would resolve these market tensions by giving all parties true visibility and control over where their assets are at all times. Regulators would gain the monitoring tools they sorely need. But there’s more. Blockchains offer the promise of self-custody of securities on a cost-effective and secure basis, which has not been possible until now. Fiduciary asset managers—especially pension funds and insurance companies—should welcome the potential to self-custody their securities, which would reduce costs, counterparty and operational exposures that are needlessly incurred under today’s system. As a principle, fiduciaries could have true control over where and how securities are lent. Blockchains can offer this huge improvement over the status quo.
Resolvability and transition planning: blockchains would facilitate resolution of a failed asset manager or investment vehicle because regulators would have real-time transparency into its positions.

3.3 Capital, Liquidity and Resolution

FSOC notes that depository institutions have meaningfully increased capital levels and liquidity buffers, and I applaud these moves. The financial system is still too leveraged, in my opinion, and outside of the FSOC report it seems regulators still agree this is the case. The large stock price reactions of the biggest banks to the Brexit vote would seem to support that view, as does the fact that in April the Fed and FDIC notified five of eight of the largest, most complex bank holding companies that their so-called “living wills” were deficient.

The FSOC report recommended that the Fed finalize rules for minimum capital requirements for the U.S.’s global systemically important banks (U.S. G-SIBs) and large foreign banks (FBOs) operating in the United States, and that the agencies “take appropriate action” to handle the living will statuses of large banks.

Again, blockchains could provide real-time transparency into the true risks of all financial institutions, and this would facilitate resolution of failed depository institutions. Tracking of risk across multiple legal entities and jurisdictions is a challenge even for the banks’ risk departments themselves, much less regulators, and the “living will” regulatory process gives banks clear cost and capital incentives to deploy IT solutions that can transparently aggregate risk reporting in real-time.

3.4 Central Counterparties

In this section, FSOC maintains that central counterparties (CCPs) are “key to the effective functioning of a number of markets.” Here, I would respectfully question whether this is always true—especially for cases in which the CCP adds counterparty risk where it would not otherwise exist. A blockchain would obviate the need for central counterparties to use their balance sheets, because there would be no need for clearing in a world in which trades settle instantaneously (delivery-versus-payment). CCPs would not necessarily disappear in a blockchain world—they would probably still provide value-added services, but client assets would no longer touch their balance sheets and therefore their systemic risk would be much, much smaller. Here’s how I would conceive of possible services CCPs could provide in a blockchain world: administering the blockchain, setting its standards, handling permissioning/entry and exit of participants, acting as arbiter of disputes, providing big data analytics, and much more.

3.5 Reforms of Wholesale Funding Markets

Repo markets: The FSOC report lauds regulators’ progress at reducing counterparty risk, especially in tri-party repo markets, but notes more work is needed. I concur! Securities financing transactions—which include both repo and securities lending—are where blockchains can most significantly help regulators do their jobs better, and where they’re most sorely needed, in my view.No one knows how leveraged the financial system really is, because it’s simply not possible for anyone—much less regulators—to measure true systemic exposure at any given moment.
Through a process called “rehypothecation,” market players their re-use securities as collateral over, and over, and over again, multiple times a day, to create credit. Multiple parties’ financial statements therefore report that they own the very same asset at the same time. They have IOUs from each other to pay back that asset—hence, a chain of counterparty exposure that’s hard to track. Although improving, there’s still little visibility into how long these “collateral chains” are. No one has had perfect visibility into the industry’s leverage because it was technologically impossible—until blockchains came along—to back out this double counting and aggregate the true exposures of multiple trading portfolios on a real-time basis.Blockchains would help FSOC accomplish its goal of finally bringing “the settlement of GCF (general collateral finance) repo transactions in line with post-crisis reforms.”I hope FSOC ultimately welcomes blockchains as tools that can finally provide true visibility into the positions of all players—especially into repo, securities lending and derivatives where that visibility is so needed. Blockchains do this by immutably recording every transaction, tracking the chain of collateral custody, and facilitating a quick liquidation of collateral in the event of a failure (because all of the data would be stored within the blockchain itself).
Money Market Mutual Funds (MMMFs) and Other Cash Management Vehicles: the FSOC report discussed recent reforms designed to make these less susceptible to potentially destabilizing runs. While I laud these reforms—especially the requirement that the net asset values of prime MMMFs track the actual value of underlying assets—I note that a blockchain-based world, in which trades settle at the exact moment of transaction, “run risks” for these short-term investment vehicles would be largely mitigated.

3.6 Reforms Relating to Reference Rates

To address weaknesses in certain key market benchmarks—especially the continued reliance on LIBOR—the FSOC report recommended that Alternative Reference Rates Committee (ARRC) identify alternative, near risk-free rates. FSOC noted the goal of well-governed benchmarks that are “anchored in observable transactions and resilient against attempted manipulation.” Blockchains can assist in achieving both goals, since the transactions and prices would be transparent to regulators. Blockchains are especially useful for creating an agreed source of reference data, precisely because transactions are transparent and immutable—so data pertaining to these transactions would be readable directly from an easily auditable ledger rather than self-reported (sometimes subjectively so). I believe market participants would welcome having an immutable transaction history upon which to base such critical benchmarks and analytics.

3.7 Data Quality, Collection and Sharing

Nowhere else can blockchains help regulators more than in the areas of data quality, collection and sharing. I’m broken record on this point!

This section of FSOC’s report began, “Addressing data needs for the analysis of potential threats to financial stability remains an important priority of the Council…” It then broke the section into several sub-sections.

Securities financing data: covered in Section 3.2 above.
Legal entity identifier: FSOC wants broad adoption of legal entity identifiers to facilitate its analysis of complex financial institutions. Several blockchain-based identity platforms would provide exactly this, and I agree that regulators urgently need this information.
Mortgage data standards: FSOC also wants broad adoption of a universal loan identifier, in addition to a legal entity identifier, in regulatory reporting. FSOC further wants its members to facilitate adoption and use of standards in mortgage data. Today, when loans are packaged into securitization pools it can be difficult to track them—still true 8 years after the financial crisis. Were mortgage loans directly issued on a blockchain, the use of identifiers would be solved by definition and market standards would be implemented as part of adoption of the new technology. More on mortgages in section 3.8 below.
Derivatives data: FSOC recommends continued work on harmonization of global derivatives data reporting, which—I can attest from experience—varies widely from country to country. Again, in a blockchain world this would happen as part of the standards-setting process in adopting the new technology.
Insurance data: FSOC called for more transparency for captive reinsurance transactions. I agree that GAAP financial statement disclosures on this topic are sparse. I can’t yet envision a role for blockchains in this specific instance, but do believe blockchains will impact the sale, distribution and structure of insurance products broadly.
Pension data: as with insurance data, blockchains are likely to come later to the pensions sector, after being applied to higher-priority use cases first. In pensions, blockchains are likely to help most with administration—in fact, far more pension records are still sitting in warehouses, waiting to be digitized, than most of us would believe. I do concur with the FSOC report’s recommendation that pension regulators improve the “quality and depth of disclosure of pension financial statements.” In light of the huge and growing size of some pension deficits amid the low interest rate environment, FSOC is right to worry about pensions as a systemic risk. Differences between accounting standards for public and private sector pension liabilities are vast because GASB and FASB rules differ widely—especially regarding liability discount rates, as FSOC noted on page 89 of the report. Within the public sector, little is disclosed about the nature of inflation indexation of pension liabilities—a highly valuable option typical of public sector pensions that causes their liabilities to grow faster than their private-sector counterparts. Within the private sector, the range of accounting practices for selecting AA-corporate discount rates and mortality assumptions is also surprisingly wide.

3.8 Housing Finance Reform

The FSOC report understandably focused on Fannie Mae and Freddie Mac (the GSEs), and FSOC reaffirmed its “view that housing finance reform legislation is needed to create a more sustainable system” and to take steps “to encourage private capital to play a larger role in the housing finance system.” The FSOC report didn’t highlight the area of mortgage finance in which blockchains can really help: improving recordkeeping and servicing of mortgage loans. In a blockchain world, deeds, mortgages and liens would be recorded and transferred via a blockchain, not in paper form. This “dematerialization” of records would facilitate securitization issuance and servicing, as investors would have real-time transparency into the cash flows of the individual mortgages that back securitizations—instead of waiting for monthly remittance reports. Disputes would be resolved more quickly. The foreclosure process would be smoother. Mortgage servicing would still have a human element, of course, but would be fairer and more transparent to both sides.

While full conversion to a blockchain world will take years, I see the Delaware Blockchain Initiative as an important first step to dematerialization of corporate registrations, liens, mortgages, UCC filings, deeds, and much of the paper involved in securities issuance.

Something Else Worth Discussing

I noticed something later in FSOC’s report worth discussing, which pertains to the drying up of bond market liquidity. FSOC alluded to the issue in Section 3.10, looking at the impact of market structure changes on Treasury bond market liquidity specifically—but liquidity has dried up across the broader bond market too.

There are many reasons for this, likely the biggest of which is higher capital requirements that have caused securities dealers to reduce the inventory of bonds they hold to facilitate customer flows.

When reading page 65 of the FSOC report, I drew an analogy to the bond market liquidity issue. On page 65 FSOC discussed the improvement in swap market liquidity since 2014, when swap execution facilities (SEFs) came into the picture. The analogy between swaps and bonds is far from perfect, of course, but the bond and swap markets shared something until 2014 (when the swap market began migrating to SEFs): they were both over-the-counter (OTC) markets. Two characteristics of OTC markets, in my experience, inherently limit their liquidity—(1) opacity in price discovery, and (2) participants assume the risk of settlement failure between the moment of trade execution and settlement (which, for securities, is T+3 days).

On page 65, FSOC examined the improvement in swap market liquidity when it moved to SEFs, which improved price transparency and competition and reduced counterparty risk. FSOC said, “A recent study by the Bank of England finds a positive link between SEF trading (both voluntary and mandatory) and a significant improvement in liquidity, in particular for USD-denominated interest rate swaps which are most affected by the SEF mandate. The study postulates that the increases in volume and market liquidity result from enhanced transparency and the reduced search costs provided by the SEFs. The associated reduction in execution costs associated with SEF trading is economically significant.”

Blockchains, in my opinion, would boost bond market liquidity for the same two reasons SEFs did for swaps. Blockchains could reduce or eliminate counterparty risk (by speeding up settlement, potentially to the exact moment of execution (delivery-versus-payment)—thus obviating the need for assets to travel through the balance sheet of an intermediary, such as an SEF, exchange or other central clearinghouse, before settlement). And further, blockchains could facilitate electronic bond trading at the pre-trade juncture, just as SEFs did for swaps—helping price discovery by enabling participants to send anonymous request-for-quote queries to owners of bonds (to facilitate the search for buyers and sellers), and possibly even incorporating matching engines into the blockchain itself.

I believe withdrawal of dealer liquidity is the spark that finally makes the bond market ready for electronic trading, which has had several fits and starts but hasn’t happened yet because dealer inventories had kept markets functioning. It’s fortuitous that the advent of blockchain technology is happening just as dealer liquidity has dried up.

No other market is more poised for transition to an institutional peer-to-peer, dematerialized (i.e., not paper), electronic model than the bond market, in my opinion. Most of the bonds that will be outstanding in 10 years haven’t been issued yet, and so the bond market could adopt blockchains for new issues only without retrofitting legacy infrastructure for securities already issued.

New bonds could be issued directly onto a blockchain and live natively there—existing in dematerialized form from inception to maturity, with everything in between (trading, payments of interest and principal, calls, tender offers, exchanges, securitization, remittance reporting, etc.) happening directly on a blockchain. Again, the Delaware Blockchain Initiative is a critical step in making this legally possible, as corporate actions, mortgages, liens, UCC filings, and other items should soon be able to be recognized legally on a blockchain (in lieu of paper). Some these options should be production-ready later this year, with more to follow in 2017. I would encourage FSOC to dig into what this means, and am happy to engage in a direct dialogue!

I’ll omit discussion of the last two recommendation sections of the FSOC report (3.9 “Risk Management in an Environment of Low Interest Rates and Rising Asset Price Volatility” and 3.10 “Changes in Financial Market Structure and Implications for Financial Stability”) since I don’t see much application for blockchains to either topic.

3.1 Cybersecurity (saving the best for last!)

Finally, let’s turn back to cybersecurity, the top issue in the FSOC report. I agree it should be FSOC’s #1 priority. Yet I’d also rank cybersecurity as blockchain’s best attribute. Owing to the technical nature of this discussion, which may lose some readers, I elected to handle it last.

The laws of math have proven a lot more tamper-proof than the laws of man!

Blockchain, as an IT security model, is superior relative to the model of current financial infrastructure. On a blockchain data is decentralized, can be fully encrypted, and can be used as the statement of record for all state changes in the lifecycle of an asset. Additionally, data is replicated throughout a network, making it far more resilient and making hacking attacks far more unlikely and costly. By contrast, today most data is fragmented, inaccessible, unencrypted and stored behind perimeters that have proven too easy to penetrate, unfortunately. Fragmented architectures inherently have attack surfaces that are wide and multiple points of failure that are too vulnerable to attack.

To understand the four corners of what’s possible, I would encourage FSOC to study the superior IT security attributes of blockchain’s most visible standard, bitcoin. Please, set aside what you’ve read about bitcoin and focus specifically on its design as IT architecture. It has a great deal to teach about cybersecurity.

Bitcoin’s blockchain has survived for 7 years, completely open and exposed to the 24/7/365 war zone of Internet security, without a single successful attack on its ledger. Many sophisticated adversaries have tried unsuccessfully to steal its hacker’s bounty, which is now worth about $10 billion. So far, attackers have succeeded only in hacking applications built on top of its protocol, rather than the data itself.

It’s informative to dig into why Bitcoin’s cybersecurity has proven so strong. The magnitude of computational power required to break the Bitcoin blockchain—or even to re-write the history of this morning—is so staggering that it’s unlikely to happen. And bitcoin visibly grows more robust nearly every day. You can track the growing computational power of its network here, which as of this writing stands at 19,205,707.43 PetaFLOPS (a measure of computer performance). This towers over the world’s fastest supercomputer, China’s new Sunway TaihuLight, which runs at a comparatively miniscule 93 PetaFLOPS.

A critical, intertwined design feature reinforces bitcoin’s defenses against hackers. It’s called “difficulty,” which is how hard it is to perform the calculations required to add a block to Bitcoin’s blockchain. Bitcoin’s protocol automatically adjusts its “difficulty” to keep block calculation times to ten minutes, so as more computer power (hashpower) comes into Bitcoin’s network, its difficulty rises.

Because of this “difficulty” feature, even if a bad actor were able to gather up enough computational power to attack the Bitcoin network (including a so-called “51% attack”), it would not succeed in altering more than a few blocks on Bitcoin’s blockchain (i.e., a few hours of its history). The amount of computational power required to steal bitcoins from the blocks added yesterday, much less those of last month or last year, is pretty much unfathomable.

It is precisely because of this lopsided upside/downside calculus—requiring an awesome amount of cost and computing power to gain so little—that no hacker has succeeded in breaking the Bitcoin blockchain.

And then there’s this. As of this writing, 5,730 nodes keep a watchful eye over the bitcoin network, located all around the world. From a cybersecurity perspective, this is powerful—all nodes have strong financial incentives to protect the network from attack, and all nodes maintain a complete backup copy. Each node is itself a complete business continuity plan.

Can you think of a more secure IT system than what I’ve just described? I cannot. Can any bank say that the financial reward from a successful attack on its infrastructure is small? Recent history has unfortunately proven otherwise.

To understand the cybersecurity benefits of blockchains, whose IT ancestry is bitcoin, I would encourage FSOC to study why bitcoin has proven so resistant to cyberattack, and whether any—or all—of its attributes might be applied to improve the cybersecurity of the U.S. financial system. Most of the financial institutions regulated by FSOC are studying this very question, and rightfully so.

SUMMARY

The FSOC report correctly identified the most critical and pressing information gaps that pose systemic risk to the financial system. No one really knows how leveraged the financial system is. Yet, the report missed connecting the dots about the new tool that might finally give them the information they need to assess that very risk: blockchains.

I recognize and respect, more than most, the near-impossible job of financial regulators in tracking the highly complex and inter-connected global financial system. Regulators have made great strides since the financial crisis. But I believe the system is still too leveraged and opaque. There’s more work to do.

I reiterate my open call to senior regulators to help educate you about the potential of blockchain technology to benefit all participants in the financial ecosystem. Blockchains are not easily grasped in one setting, and I encourage all regulatory influencers to dive in and engage with us in the industry! We have more common ground than you’d think!