Epicenter - Learn about Crypto, Blockchain, Ethereum, Bitcoin and Distributed Technologies - Mike Pieciak: NASAA – A “To The Moon” Approach to Regulating Crypto

Episode Date: April 30, 2019

We're joined by Mike Pieciak, President of the NASAA. Not to be confused with the space agency, the North American Securities Administrators Association brings together state, provincial, and federal securities regulators in Canada, Mexico, and the United States. This relatively unknown organization helps align the financial regulation policies of over 50 agencies across North America and coordinates enforcement action in cross-border cases. In 2018, the NASAA launched “Operation Cryptosweep” in which over 200 ICOs and cryptocurrency-related investment products were investigated for potential investor fraud. Topics covered in this episode: Mike's background as a lawyer and the Commissioner of the Vermont Department of Financial Regulation What is the NASAA, it's goals, members and jurisdiction The story of “Operation Cryptosweep” and what came out of that action Mike's thoughts on the future of blockchain regulation How regulation might apply in the context of transnational projects which are nation state-invariant The United State's restrictive securities laws in the context of Defi and security tokens Vermont's attempt to attract blockchain projects, and the “Blockchain-Based LCC” Vermont DFR's pilot project in Captive Insurance What Mike hopes to achieve during his one-year term as president of the NASAA Episode links: NASAA Operation Cryptosweep NASAA Reminds Investors to Approach ICOs with Caution Get in the Know About ICOs (video) Vermont Governor Signs Bill Clearing Way for Blockchain Companies Captive Insurance Blockchain Pilot Press Release Vermont Department of Financial Regulation Mike Pieciak (@mspieciak) on Twitter Sponsors: Azure: Deploy enterprise-ready consortium blockchain networks that scale in just a few clicks - http://aka.ms/epicenter This episode is hosted by Sebastien Couture & Friederike Ernst. Show notes and listening options: epicenter.tv/285

This is Epicenter, Episode 285 with guest, Mike Peachiac. This episode of Epicenter is brought to you by Microsoft Azure. Do you have an idea for a blockchain app but are worried about the time and cost it will take to develop? The new Azure blockchain dev kit is a free download that brings together the tools you need to get your first app running in less than 30 minutes. Learn more at a.kia.m.s. slash epicenter. Hi, welcome to Epicenter. My name is Sebastian Kutu. And my name is Frederica Ernst.

So today we're speaking with Mike Peachiac. Mike Peachak is the president of NASA. And so we wanted to speak tonight because they're planning on taking cryptocurrency to the moon. No, actually that's, so NASA in this case is the North American Securities Administration's Association. And so it's a regulatory body, actually it's more of an association of regulatory bodies that includes every state level and provincial level financial regulator in the US and Canada, as well as Mexico,

and the federal level securities regulators. So it's an organization that not a lot of people have heard about probably, but that came to light in the crypto space about a year ago when they launched Operation CryptoSweep, which sent cease and desist letters to over 200 ICOs that were deemed to be fraudulent. And so we want to speak with Mike about NASA as an organization, because it's not very well known in this space, but also to understand his position and the association's position with regards to regulation in the crypto space.

And I was actually quite impressed and pleasantly surprised to learn that at least this association has a pretty positive view of blockchain and ICO in general and are really just trying to go after fraudulent projects. Mike is also the commission of financial regulation in Vermont, and it seems a lot of good things come out of Vermont. So they recently pioneered the Dow LLC, the blockchain-based LLC with a new legal framework, which we will also talk about. And of course, as Mike also mentions, Ben and Jerry's is also from Vermont. Yes, and so that's at least one reason to go there. So you had an announcement you wanted to mention that you're going to a conference soon.

Oh, yes. I'm going to consensus in New York in May. So I'll be there May 12 to 16. I have a talk on the 13th. So find me if you want to talk to me. Great. I will not be there. But have fun. So without further delay, here's our interview with Mike Pichack. Hi. So we're here today with Mike Petiak. Mike is the commissioner of the Vermont Department of Financial Regulations and the president of the North American Securities Administration's Association. Mike, thanks for joining us today. Yeah, no, my pleasure. Thanks for having me. It's a pleasure to be here and happy to participate in the podcast. Great. So tell us a bit about your background. So you've been in

financial regulation for some time as the commissioner of the Vermont DFR. Sorry. What did you come from and how did you get involved in this position? Yeah, sure. So happy to talk about that. I grew up in Vermont and always had wanted, had an interest in going to law school and being interested in a legal career. Also, I had always been interested in policy, policy development, politics, things of that nature. So I did go to law school and I did start off my legal career working in a major law firm in New York City where I was focusing on a lot of merger and acquisition deals, a lot of international companies that were, you know, doing business transactions. And the thing that first

got me interested in securities laws was not really, you know, the work that we were doing in connection with those MNA transactions, those work that we were doing in connection with the SEC with those transactions. It was really non-equity crowdfunding. So it was the kickstaters of the world, the indigogos of the world. I remember being in New York City and hearing about some really interesting Kickstarter crowdfunding campaigns and some really interesting Indiegogo crowdfunding campaigns and was looking into some of the products and to some of the companies. And I thought to myself, boy, this would be really fun to invest in these products. At the time, I understood that to be the whole concept that you can invest in these projects with a little dollar amount and then,

you know, you could see them grow. And lo and behold, I sort of all of a sudden became aware of the very protective in some ways, a framework that exists around a smaller upstart offerings, localized offerings, basically the crowdfunding offerings. So I got really interested in, you know, how do you, what is this framework, why does it exist? And then is it appropriate for the way that businesses want to raise capital in the 21st century, particularly businesses that would be prime for localized crowdfunding or national or international crowdfunding. So I got really interested in those issues. I came back to Vermont because the deputy commissioner position opened up of our securities division. And I certainly saw an opportunity to

come back and work on those issues, which I did. We created a couple of different crowdfunding exemptions for Vermont. We also worked with the SEC to make their regulations more modern in terms of being able to offer products over the internet within a single state so that you were in compliance with the federal securities laws. And Vermont has always had this tradition of localized investing, sort of crowdsourced investing. Ben & Jerry's, which is one of our most well-known brands, started from a Vermont-only offering. They raised $750,000 from about 3,000 Vermonters in the early 80s. And that allowed... them to expand their production facility that allowed them to widen their distribution network.

And the next year they did a national IPO. So that was really a success story that started with the ability of neighbors, of consumers, of products, of friends and family, being able to legally invest small amounts of money, but legally invest into a startup business. So that was really what intrigued me that crowdfunding movement to get involved in regulation. Then about three years ago I became the commissioner of our department. So we as a department oversee the securities industry, the banking industry, and then also the insurance industry as well, and a subset of insurance called captive insurance, which Vermont is actually an international leader. And we have about half of the Fortune 100 companies have a captive insurance company based here in Vermont.

18 of the Dow Jones Industrial 30 companies have a captive based here in Vermont. So we have a rich tradition generally in insurance, but specifically in captive insurance world. And many of those captive insurance companies are experimenting with various blockchain projects. So that got me interested more, certainly in the space that we're going to talk about today. But so did the concept of an ICO. I mean, the ICO sort of, to me, is sort of an outshute of this crowdfunding movement that in some ways that you could have a project, have an idea. And instead of doing it, through the federal crowdfunding regime that was created, you could get the same type of bang for your buck by doing an ICO and raising a tremendous amount of money, as you certainly

know, some of these ICOs have achieved in an extraordinarily short period of time. So in some ways, I became interested in this space also as a capital formation tool and how this might be a new way for tech businesses, for startup businesses to raise a consistent. considerable money, again, in the period of time that's much less than a traditional roadshow through an IPO or other means that currently exist. Well, that's super interesting, and we'll get into the potential of blockchain-based projects and fundraising a little bit later. You're also the president of NASA, which is not what it sounds like. Can you tell us a little bit about NASA, what it stands for? And

what it does. Yeah, I'd be happy to. And, you know, everybody has their own funny story, but mine was, I came and worked here at the department for, you know, my first week. And we were talking about crowdfunding regulations. And somebody in the meeting said, well, you know, so and so used to work at NASA. And this is his position on the regulation. And I thought to myself, wow, like, I guess that's impressive that this guy used to work for, you know, the space agency. What does it have to do with financial services of regulation? So then, I had my introduction to our NASA, the North American Securities Administrators Association. So NASA is a membership association. It's made up of all of the jurisdictions in the United

States. So the 50 states plus the District of Columbia, plus some of the United States territories. Puerto Rico is a member. But then we also have members from Canada, the providences and territories in Canada and Mexico as well. So all in all, there are 67. jurisdiction members that make up the NASA community. We are celebrating as an organization, our 100th anniversary this year in 2019. So we're founded 100 years ago in Kansas. And the reason that NASA was founded, the reason that state securities regulators were founded, was that during that time period, there was a lot of fraud occurring in the central part of the country in America's Heartland in Kansas and Iowa and other parts of the mid-Atlantic and mid-Western states.

And unfortunately, you know, people were coming from the East Coast and providing great investment promises and great expectations of returns to these farmers that really didn't know any better. And really, they were just fly-by-night fraudsters taking people's hard-earned money, taking their life savings, and then vanishing without a trace. So NASA and state securities regulators were founded on the concept that people that are going to sell investments in our jurisdiction, in our state, should be registered with a central regulatory body, in this case, the Department of Financial Regulation, and that their product should be vetted by some means to determine its legitimacy. And then also that the individual is selling the product. So the brokers, the dealers, the investment advisors should similarly have impeccable.

backgrounds in terms of being honest people, having sufficient education and knowledge, to be able to guide these people in their investments. You know, handling your life savings, handling your investments is a really obviously critical, a critically important item to many families, all families really, but many people in the United States and worldwide. It means how much you're going to be able to spend on your next home or how much you're going to be able to help your children go to college, what your retirement is going to be like once you leave the professional workforce. So all of these things are really determined on how smart you are and investing throughout your career. So certainly we want people that are honest and knowledgeable selling good products

to our constituents and providing them good investment advice. So at the heart of it, that's why state securities regulators were founded. We were founded decades before the SEC, and NASA was found decades before the SEC. We were the quintessential cops on the beat, if you will, within all of these local jurisdictions trying to ensure that the capital markets were clean and safe so that the American economy could succeed. So now, today, I mentioned NASA as a membership association. So the The main purpose that NASA serves now is really getting these various jurisdictions in three different countries to come together and work together on model policy, model law, model regulation.

So we have a deliberative process where various project groups, we have a corporate finance project group, an enforcement project group, a broker-dealer project group, an investment advisor project group, and then also an investor education group. And they all work on policy to try to improve the marketplace, to try to keep up with technological changes, try to keep up with the change in these various financial services industries. And then we pass these models within NASA as a body. And then each individual jurisdiction goes back to its legislature or its legislative body and implements these model rules so that we have uniformity among the, 67 different jurisdictions acting on separate cases in a separate way, but that we have a uniform sort of playbook that we're all working from. Okay, so most of these regulatory bodies are actually quite independent in their local jurisdictions, but rely on sort of the guidance

that comes from these working groups to implement policy locally. Is that? Yeah, that's exactly. Yeah, That's exactly right. We try to have a lot of internal discussion at NASA among this policy. We try to get consensus so that if there is disagreement, it gets ironed out at that level so that people do go back and implement these regulations. We also hear from industry and consumer stakeholders during our process so that we get the full understanding of the pros and the cons of various policies. But at the end of the day, NASA as an association, it does have a corporate office. It does have staff. It does provide a lot of services to our members. But our members are the autonomous, independent regulatory authorities that at the end of the day have to decide to take an

enforcement action, have to decide to implement a policy or pass a model regulation. So at the end of the day, each jurisdiction like Vermont maintains its regulatory authority. How many people work at NASA? So it's an interesting question. The NASA corporate office has about 20, 25 people that work in corporate office, but we're really driven by our membership. So we have about 400 people that are on volunteer committees in those various categories that I mentioned. So all in all, you know, there's about four to 500 state securities regulators, staff people, and corporate office members that are working to staff the NASA organization, staff the resources that we're providing back to our jurisdictions and also helping us develop the model regulations that I mentioned

and expand our message out beyond state securities regulators so that we, you know, are a known quantity within the financial services world. This episode of Epicenter is brought to you by Microsoft and the Azure Blockchain Workbench. Getting your blockchain from the whiteboard to production can be a big undertaking. And something as simple as connecting your blockchain to IoT devices or existing ERP systems is a project in itself. Well, the folks at Microsoft had you covered. You already know about the Azure blockchain workbench

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And be sure to follow them on Twitter at MSFT blockchain. We'd like to thank Microsoft and Apple. for their supportive epicenter. So I actually learned about NASA when someone mentioned that that you guys were involved in the takedown of Jordan Belfort, you know, the infamous Wolf of Wall Street.

Can you tell us a little bit of just briefly about that? And I think this relates to, you know, your enforcement power and what kind of law enforcement bodies you rely on. in order to coordinate, you know, countrywide or like continent-wide, in this case, action? So, yeah, the Jordan Belford, the Straton-Okmont case is a great example of NASA working together in a multi-state enforcement action to bring an enforcement action

that doesn't just impact one jurisdiction or two jurisdictions, but really the national scope in terms of its impact. So NASA has a multi-enforcement mechanism where all of the states, together will act against an individual or an entity and the Stratton-Okman example is certainly one of those where we were able to get a national settlement using NASA as the mechanism to do that certainly in the 1990s and 2000s beyond Stratton-Okman and the very publicized Wolf of Wall Street there were certainly other cases related to auction rate securities, the prudential settlement some of these settlements totaled in the billions of dollars

I mean, these were really large, impactful settlements that NASA was able to achieve. And in many ways, although we have, you know, we regulate the industry in different ways, certainly when we're acting together through enforcement means, in some ways is when we as state regulators are the strongest in doing some of our best work. So protecting the investment public. But again, at the same time, all enforcement actions certainly are derived for going after bad actors. But by going after those bad actors, we are also helping the integrity of our capital market system so that you and I and everybody that's listening has confidence that they can

invest money in the United States, in a business, and they are not, they might be investing in a business that will go defunct. They might make wrong business decisions. They might go bankrupt, but that it's not a business that's going to steal their money. That is an important element of a free market, you know, a capitalist system that we have in the United States, that there is some confidence that there's legitimacy in the capital markets and within the businesses and the advisory firms that work within that space. Basically, NASA launched Operation CryptoSweep about a year ago. So between May and August 2018, NASA investigated 200 crypto projects, mostly for securities

violations and it's resulted in 50 plus enforcement actions. It was in the news somewhat last year. Can you tell us the story and maybe give us an update? Yeah, no, be happy to. So, you know, the operation crypto sweep was again taken out of the sort of NASA multi-jurisdictional playbook. It basically tried, instead of each individual state trying to bring enforcement actions against these cryptocurrency, ICOs that were operating within many jurisdictions, if not all jurisdictions. There was a collective effort to work together to leverage each other's staffs and resources so that, for example, Vermont and New Hampshire weren't working on an investigation against the same ICO, the same cryptocurrency, that we would decide which

state was going to handle which matter. And then in that way, we could look at a much broader spectrum of cases and bring a much broader number of enforcement cases rather than us not coordinating with each other. So again, this was a classic example of state regulators working well together, working through this multi-jurisdictional process to get some results. So the main reason that, again, we saw this as an opportunity for state regulators and an opportunity to protect the marketplace was because so much of the ICO activity, I mean, you see a report from 2017 that suggests, you know, 70, 80% of the activity had some fraudulent element to it or was in some way illegitimate. Either the project just, you know, wasn't going anywhere. They didn't invest any

resources in developing what they said they were going to develop. So with that being the backdrop, we thought we could play an important role in helping this space innovate, helping the space grow and develop by taking out the clearly bad actors that were promising, you know, 100% investment return, 70% investment return. They were promising that you would get all your money, guaranteed, no risk. So these are the classic red flags and fraud that we see, whether it's cryptocurrency or whether it's someone coming to your grandmother's door and knocking and trying to sell or something. These are the hallmarks of fraud that, you know, again, are timeless in some way, regardless of the mechanism that's being used to try to perpetrate it. And they,

again, that was in the backdrop of the big run-up in the price of Bitcoin through 2017. So at the end of 2017, when everyone, you know, was sort of in this manic phase about Bitcoin and buying and was too late and what other ICOs are out there that I can buy, you know, there was a lot of fever around, let's get in on the next best thing. And there may very well be the next best thing out there. And there very well may be good investments to be made or good opportunities to be. had. But there are also, unfortunately, a lot of criminals, a lot of fraudsters and bad actors that were trying to take advantage of that mania, trying to take advantage of that hype, and simply

trying to steal people's money. They weren't trying to do any legitimate projects. So in that way, we really, I think, as an organization, have played a helpful role in weeding out some of the bad actors and trying to clarify, you know, those that are attempting to comply with the securities laws or in fact are complying with the securities laws. Okay. So I think when a lot of people see regulatory bodies or government agencies come out with, you know, either advisories on crypto projects or in this case, actual, you know, enforcement, I think the sentiment for a lot of people is, you know, here we go, another regulatory body,

trying to insert power over our innovative space where we're just trying to innovate and do all kinds of interesting things. But it sounds like that wasn't really the case. The case was like, okay, here's some actual frauds. Like, I mean, we in the crypto space, I think we're amongst the first to be able to notice these and specifically like having a podcast. We were just bombarded with requests for people to come on the show. And like, we see these projects like, this is clearly a fraud. Like, this is a Ponzi scheme or... Feel free to refer those to us if you'd like. Sure.

I've got an inbox full of them. I don't know if any of them are still around, but yeah. So, like, we see these things. And, you know, I think in our eyes, it's quite obvious which ones are frauds and which ones are the most more reputable projects. Now, whether or not those are complying with securities regulations as an end of the story. But it sounds in this case, NASA was actually just doing what it's meant to do is protect investors and go after those that were actually frauds.

That's exactly right. I mean, I as a regulator, and I think every regulator, whether they're at the federal level, at the state level and insurance and banking, I mean, you really have two core balancing principles as part of your mission. One is to protect investors or protect consumers. And the other is to ensure that the capital markets or that the products that are out there, that there is innovation occurring, that there is efficiency in those marketplaces, that there is innovation in those marketplaces, that those markets are robust and strong.

Because if you really are focusing too much on the investor protection element, it's really at the end of the day to the detriment of those investors, because they're going to have more expensive products, they're going to have less innovation, they're going to have less choice, they're going to have less available to them. Then if you focus too much on the other side of that prong, if you focus too much on the innovation and focus too much on on the on the on the robustness of the marketplace then you're going to see bad actors come in you're going to see fraudulent deals come in and those bad apples are going to destroy the trust and the legitimacy of that capital market so you really need to have

those two elements in mind and you really need to balance them and have a good perspective to allow innovation to occur but at the same time think about what new innovation means to invest and how do they need to be protected? I know the SEC has set up a cyber unit within its agency, and I think NASA and the SEC have a very similar mindset. We see basically three buckets of companies, three buckets of ICOs, if you will. There's those that are just the outright frauds. There are those that are trying to comply with securities laws,

or maybe they're not even aware that there are such a thing as securities laws, but their white papers are trying to be transparent. They're trying to provide detail about their project. They have a legitimate project. And then there's a final bucket which, you know, is doing the belt and suspenders and following all of the regulations and all of the requirements. And our focus, you know, our interest is in going after that first bucket, the bad actors, in helping that middle bucket understand the securities laws

and helping them comply with the regime so that they can offer their product. and then just monitoring that last bucket. So we really don't have an interest in trying to stifle innovation by going after, you know, these people in the middle that maybe are forgetting to file a notice filing or forgetting, you know, in some cases they might even be doing something that is more severe, but again, unintentionally. So it's not an attempt to play gotcha regulation, but it's really trying to educate and help them get into compliance.

I think that's an important role that we play. How are these projects brought to your attention? So do you join as really scummy telegram groups? Well, I'll tell you some of the obvious ones, because I think probably I'm not giving away any state secrets by saying this. But there's certainly, you know, you can monitor Reddit, you can monitor Craigslist, you can monitor various, you know, sites out there that are going to be places where Vermonters and other citizens are going,

and trying to find more information out about the newest ICO, the newest cryptocurrency. So those are really effective ways of just beating back some of the nonsense that's out there. So that's certainly A number one. At the end of the day, we really do get a lot of our cases through complaints. So investors that are harmed will be complaining to us. Unfortunately, that's more of a reactive method because at that point, that means someone has been out there selling something for quite a period of time. The investor has been dragged along for some period of time.

And then finally, they realize that they're probably involved in a fraud or they're not getting their money back. And that could be three or four years after they made the investment. Right. In the case of the ICO busts, I mean, you know, these projects were raising money and you guys went after them. I mean, this crypto sweep occurred just around the end of it. you must have been monitoring quite a few projects and actively monitoring the space to figure out which of these projects were fraudulent. Did you have any clear criteria that you were looking for here? Yeah, so you're absolutely right. And so in this space, we were trying to be more proactive in monitoring and taking action quickly.

So really, you know, first and foremost, we tried to understand if the company was registered anywhere, if they had had any conversations with securities regulators. That was just sort of a baseline question. It wasn't something that decided if we did an enforcement action. But then we were looking for, again, these hallmarks of fraud were there next bit? Was there a promise that this was risk-free? Was there a promise that this was a guarantee? How far along in developing the project were they? Was it really just sort of a pie in the sky idea?

Or was it something that could actually be operationalized through the investments that they were seeking? Again, did they promise outsized returns? So were they saying you can get 50, 60, 60, 70% return on your investment. These are things we would be looking for if we were just in the traditional sort of Ponzi scheme, you know, type of fraud. And we saw the same exact things here in the ICO space, people that were overpromising and were unable to deliver. And we can detect, you know, we can pretty easily sort of understand those red flags. And then we would go in and subpoena the companies for information. And then based on that, we would decide,

you know, do we need to bring an enforcement action or not? You know, we mentioned that we had 200 investigations. You know, I know we had investigations here in Vermont, and we would, you know, if you'd send a subpoena, the company very well might just all of a sudden fold up shop. But in other cases, we had to go out and bring an enforcement action, which we did from a number of different states, Texas being one of the big leaders, North Carolina as well, against some of the actors out there that, you know, either disputed that they were not acting inappropriately or fraudulently or against some of the people that we thought were the more egregious situations that we had to take action against. And how many enforcement actions has this resulted? And how many do, I mean, basically this was one big sweep, but I assume you also do this on an

ongoing basis. So how much of your time do you actually spend with crypto scams? And can you put some numbers on how many you bring enforcement actions against? Yeah, sure, happy to. Many people are in jail, actually. Well, the jail takes some more time. But there are some of our, so our membership has various authorities. Some of them do have criminal jurisdiction.

And, you know, they very well could bring criminal charges. But because we were proactive, in all honesty, for example, the cases that we brought in Vermont did not yet have any investors in Vermont. So by acting proactively, we believe we prevented a lot of people from losing their money, where if we had sat back, you know, these more of the scammy type ICOs would have, unfortunately, raised some money and then either failed to deliver or outright left with the proceeds. But to answer your question, you know, we had about 200 investigations during the first six months of Operation CryptoSuite, 50 enforcement action.

actions. That number, I think, is now almost double in the enforcement actions. I think it's closer to 100. So that's a pretty significant number when you think about the type of due diligence that we have to do in bringing an enforcement action and the fact that this operation crypto sweep, although certainly a point in time effort, it continues. And that has only been about a year and a half or 18 months where it's really been in earnest in terms of investigating these matters. So that's a pretty significant amount of cases to have brought in that period of time. So moving on now to the broader topic of regulation in the blockchain and crypto space. First, what do you see as the main innovation that blockchain, and more specifically,

I think we should focus the conversation, at least at this part, on permissionless networks, you know, public networks like Ethereum, Bitcoin and others. What's the main innovation that you see here with regards to securities law? And how do you think it sort of changes the focus or changes how one should look at these regulations in the future? Yeah. I mean, I think you've hit the key issue as it relates to financial services or global finance or even international business is how do permissionless blockchains enable, how do companies operationalize concepts on a permissionless blockchain? What are the projects that are able to meet problems that these financial service companies or these

international firms are facing? And to date, in all honesty, there have been hurdles that companies have not quite been able to get over. In the financial services space, I think there are a lot of discussions and a lot of concerns around the concept of privacy. So in a public, fully transparent, permissionless blockchain, how does a bank or an insurance company, a securities firm, do the transactions make the accounting that it needs to make, and at the same time protect the identity of a transaction, protect the identity of a transaction, protect the identity potentially of the individuals or any of the other sensitive business information that needs to be protected and in some ways it could even you know it could just be the fact

that the transaction is happening and that people could from that determine who the who the various participants are and then take advantage of that some way in the public investment arena so i think that that concept is something that people are still struggling with you certainly see private blockchains be utilized in financial transactions. Just today I was reading about a French lender that was issuing bonds via blockchain. At first, there was some discussion that this was going to be a public blockchain, but then they had to clarify that it was really the French lender issuing the bonds to a subsidiary of itself. So it was a private blockchain transaction. So we continue to try

to see examples of it in this in this public space but again there's they're struggling a little bit with those with that first question and a couple of more questions that i'll mention but just a note on that transaction i just mentioned the thing that's that's pretty interesting to me is that the credit rating agency that rated the bonds when they took into account that the blockchain was used They gave that as a credit positive element. And basically what that means is they looked favorably on that. And the reason they looked favorably is they said it provided greater transparency for the transaction. So, you know, that cuts a little bit against the privacy element that the credit rating agency saw that as a benefit.

And then they also said that it was going to cut down on mistakes. It was going to cut down on, you know, human error, that it was going to make it more accountable. and better from that perspective. So that's an interesting development, certainly, when thinking about, you know, other players that are operating in this space that businesses need to take account for, like regulators, credit agencies, banks, and the like. There's also been a lot of discussion in this permissionless block chain space, certainly in the insurance community among interoperability. So how will various public blockchains connect with each other and interact with each other. And there's some companies out there that are trying to provide a solution to this.

And that's one area where, and I know you've had guests recently on your podcast that have talked about this. So that's one area where I'm certainly personally interested in how does that develop. I know industry is interested in how that develops because I think that probably solves a lot of the questions that people have about what does this look like in five years. There's one company I know that's trying to make an attempt at this called Cordo Enterprises, and they have made plays in the financial services space and in the insurance space. They have one interesting insurance play that Ernst & Young and a company called Guard Life are attempting.

It's a very discreet type of insurance, but it's four marine vessels, so four big ships. And this same point that I'm going to make can apply to any insurance transaction for the most part. But they see the process as being inefficient because there is the thing that they are insuring, the boat. There is the owner of the boat. There is an insurance broker that's brokering the insurance. And then there is an insurance company that's providing the insurance. Then there is a reinsurance broker that's working with the reinsurance company. And then there's the reinsurance company providing the reinsurance.

Maybe there's even another layer on top of that, depending on how far they go on the reinsurance side. So they view that as being an inefficient streamline, not a streamline, but an inefficient process. And also when you have a process like that, similar to the bond example I gave, it invites inefficiency and it invites human error. So Ernst & Young has created with Cordia a blockchain solution that would allow a new vessel that, that comes into somebody's possession to be entered into this distributed ledger program and immediately be underwritten for the criteria that they have plugged in, for that contract to have been immediately issued, and then for the reinsurance underwriting to occur almost simultaneously,

and for that policy also to be issued. So that's one example of trying to allow for a permissionless, public blockchain to be incorporated into financial services. But again, that interoperability remains a question. And then the other thing I hear, and I'd be interested in your thoughts on this as well. But I was just recently at a insurance panel with the NAIC, the National Association of Insurance Commissioners. And there was discussion about the scalability of permissionless or public blockchains and whether the speed of transactions that need to happen in financial services will be able to be achieved through a permissionless blockchain.

They were talking about how their current databases and privateless blockchain potentially could complete thousands of transactions in the same amount of time that a public blockchain might only be able to complete a dozen or so of those transactions. So I've heard a lot of discussion around the scalability issue, how much can, how quickly can these transactions be verified and implemented? And then the flip side of that, too, is what is the cost of that, both in terms of dollars and energy consumption as well. Somebody mentioned that I think it's the country of Iceland that spends more money on mining Bitcoin than it does on all energy consumption. through their entire households in the entire country, which was kind of an interesting fact. I don't know if that's been verified or not.

But I think it does bring a point that, you know, how do you account for that scalability in terms of the speed and then also in terms of the secondary impact of energy consumption and the cost of that, both in terms of financial cost and also in terms of environmental cost. You make very interesting points. So I think there's a couple of things here that I'd like to talk about for sure. So one being the interoperability, the other being scaling, and the third being the energy consumption that comes from the proof of work mining that's currently going on in Bitcoin and Ethereum and also many other chains.

The one thing that I want to talk about first is privacy. So you talked about privacy in the very beginning. I mean, while it's completely true that Ethereum and Bitcoin, in terms of privacy are terrible because everything is out there, there are now technologies that preserve privacy, right? So I don't know whether you know about zero knowledge proof or things like Zcash, where you can have shielded transactions where it's no longer public knowledge, who does what.

How do you feel about these? Yeah, and I'm not familiar with those particular companies, but I am familiar with some that I think are aligning the same type of concept. I think the one I mentioned, Cora Enterprises, is working on similar items where basically, if you're doing a deal, two parties are doing a deal that a competitor, third party wouldn't have the information about your deal stored on their network if they were operating in a public distributed ledger network, so that they are protecting the information in that way. And I think that's a good advancement because, although, again, it's not that the business world or financial service world doesn't want to be transparent, but that there is certainly information, sensitive information, business information that individuals want to keep private.

Certainly, you see this with SEC filings. I mean, people need to make confidential filings with the SEC all the time because they don't want. that information to become public before it needs to be public or at the appropriate time. And they don't want people to manipulate the stock market because of they've gotten non-public information. So certainly those are, I think, are good advancements on a global perspective and able to protect the sensitivity of transactions and the sensitivity of this information. And then the next question, of course, on the privacy piece is personal privacy. and personal information. And, you know, certainly, you know, on the one hand, in all honesty,

you know, the current ways that corporate entities and financial services firms are protecting folks' identity is lacking. I mean, there have been a number of cybersecurity breaches that have been quite well known throughout the last three or four or five years. Companies certainly are doing everything they can do. I think most of them, at least the good actors, in protecting privacy and the confidentiality of individuals' information. But you can't, in the current structure, you can't prevent it. You're just trying to mitigate it, minimize it, and then respond to it when it happens. So, you know, if a distributed ledger technology does have some hope in securing our networks to an even greater degree, that equally would be a good development. But I just,

I personally continue to wait and see what will come about that on both of those points in terms of individual privacy and on the sensitivity or privacy, if you will, of transactions generally. I would like to come back to a point you made in the very beginning about crowdfunding because I also think that is a tremendous benefit to blockchain technology. And you said that you became interested in crowdfunding in the times of, Indigo GoFundMe and Kickstarter. And I would like to add and maybe discuss that while in traditional crowd funding campaigns, you actually fund a product, right?

So basically you buy, say, a super cool, I don't know, hoodie or something that you that you really want because it has 20 functionalities. I think the one that was like the best was that one that was the cooler, that was maybe also a radio or something, or stereo. Yes. So something like that. And you pay, say, $70 for the promise that if they manage to build them,

they will ship you one first for these $70. But they only sell you the product. They don't sell you a share in the company. So basically, if this company becomes fantastically successful, you as someone who actually funded the development do not benefit from that. And I think we have seen this time and time again, For instance, in the Oculus Rift case, I don't know whether you're familiar with this. So basically people crowdfunded this VR headset and got a fairly lacking prototype.

The company was sold for several billion dollars to, I think, Facebook. The founder cashed out. And support for the things that had already been delivered was phased out. So the people who actually kickstarted this in the best sense, they didn't actually have any part in the success that this company had in the end. And with ICOs in the best case, you become a stakeholder in that company and you benefit from the future successes. Yeah, no, I think that's right. I mean, that's why I see this connection between crowdfunding and the ICO space and how it can be, you know, in many ways, you know, there's been some amount of crowdfunding in the equity crowdfunding space at the federal level. But I don't think it's been as great as many of us or the SEC or those in that space may have anticipated.

And it's interesting because at that same time when federal crowdfunding finally had the rules finalized and it was allowed, this concept of the initial coin offering. or the initial token offering came in at the same time. And all of a sudden, you had businesses that could raise capital, not just from the United States, but internationally, in a way that, again, was in some ways more efficient. In some ways, they were not doing it in compliance with regulations, which made it more efficient, but that they were able to do it more quickly and more efficiently

in terms of the mechanism of raising the money. So it is quite a fascinating and interesting. concept and I do agree with you you know in terms of the non-equity crowdfunding the Oculus Rift case I remember I talk about it quite frequently because I think if I remember right the headsets were three or four hundred dollars something in that range and if that three or four hundred dollars had instead been an equity investment you know they would have gotten you know 67 to 70 thousand dollars of return on that investment so that would be you know quite substantial and

instead, like I say, you know, many people were waiting by the mailbox for their check to come in, not appreciating that they had bought the product and not invested in the company. So I do think there is great value in giving people, normal people and people like us, I mean, people that are not investment banks that are not pension funds, that are not hedge funds that are not extraordinarily wealthy individuals that get the private deals that are going on and are the first ones to get in on the IPOs that are going on within the New York Stock Exchange and others, but to give every day investing public an opportunity to get in on some of these opportunities at the very earliest stages.

That is, I think, a tremendous upside to crowdfunding and then also to ICOs. So I mentioned earlier that balance between, you know, invest between facilitating capital and facilitating investment and then also investor protection. And the rub is that although these are exciting opportunities for the businesses and for the investors that get in with the business at the ground floor, putting aside the fraud, putting aside any of bad actors, you know, startup companies, you know, for every Oculus Rift, there is probably 10 to 20 companies that have, you know, fallen on their face and the investment went nowhere. So, you know, it's up to us a little bit to teach the traditional concepts of financial literacy to understand that you need to do some due diligence on the business.

You need to not put more money than you can put in that business, assuming that you lose everything in terms of your investment. You don't put more than you can afford to lose. Make sure you have a diversified portfolio. So certainly, you know, in terms of advances in what you're talking about, when you get to a place where you're starting to have a fund that is investing in various ICOs so that you can achieve that immediate diversification or an ETF. I know there's a number of ETS that are trying to get licensed or regulated on the New York Stock Exchange. When you get to that next level, that also will, you know, be a positive development,

both for businesses and for investor protection. Yeah, that's a good point. But to come back on Frederica's point, that when, when you look at this, this Oculus Rift story, it looks a lot more, it has a lot more of the same characteristics as a fraud in the security space where like there was a promise that it would deliver this product, but in the end, the product was never delivered and, you know, people were disappointed maybe. So of course, the amount invested and the wasn't as much as say you would maybe put in an ICU and the outcome expectation wasn't maybe the same. But in a sense, people were promised

something and in the end they didn't receive it. And I don't know if crowdfunding regulation actually takes that into account or not. So if just in a general consumer sense, if a business is promising you something and then they don't deliver, every state attorney general would have the ability to bring a consumer action against that company. And some attorneys generals did, in fact, bring actions against businesses on Kickstarter and other non-equity platforms that did not failed to deliver because just to your point, just because it's a $300 product versus $300 investment, if they took that money making false promises, they should be certainly held accountable. I'd like to move on to another point, which is the transnational aspect of blockchain.

So blockchain projects and the teams themselves are often transnational. So a lot of teams working in the space have remote workers and the projects themselves are targeted and can, potentially be attractive to people from all around the world. But security's regulation itself is a very national or state level type of activity. How do you circle that peg or square that circle and make those two fit together in a way that you can have innovation and I think to some extent have these organizations that are truly global and also have regulation that protects investors. Yeah, it's a it's a great question. It's both a practical question and a theoretical question almost in one. And I have a couple of different ways that I want to answer it. I first want to give a

very specific example as it relates to Operation CryptoSweep and some of the enforcement actions that state securities regulators are bringing. So to your point that, you know, both the good and the bad, but focusing on the bad, ICOs are international. You know, when we are bringing an action, and it turns out that the individuals are located not just outside of our jurisdiction, meaning our state or our providence in Canada, but they're outside of our country. They're over in a country or a territory that maybe we've never even heard of on the map, and we have to look it up. And how do you enforce a subpoena against that person or that entity that's far outside of our jurisdiction. Even the SEC has challenges with that. Even the Department of Justice have

challenges with that in terms of enforcing subpoenas and then enforcing legal actions against individuals that are operating outside of the United States. So that's a really practical issue that we're now confronting in a way that really in some ways we've never confronted before because there certainly was the Internet and there certainly made communication effortless around the globe. But you hadn't seen on such a large scale the ability to make investments in companies that really were not, they weren't corporate international, multinational companies that were trading on the New York Stock Exchange, but operating everywhere in the world. These were companies that were coming out of ICOs and cryptocurrencies that were coming

out of nowhere and blockchain projects coming out of nowhere that are able to operate anywhere in the world and in many ways do. So we are confronting that real sort of jurisdictional limitation. To your point, just about, you know, how do you develop a policy around that worldwide infrastructure? Certainly incumbent companies struggle with that. I mean, to be frank, I mean, companies have to deal with the United States and its securities laws, the United States and its privacy laws, the European Union and its new regime relating to the United States. And the privacy and its securities laws and certainly in Asia, their laws and can be even considerably different and even the approaches that these countries are taking. So that's something

that international companies certainly have to struggle with and they have the resources and the ability to navigate that. But a lot of startup companies, a lot of new projects might struggle pretty severely with that. And it could certainly stifle and prevent innovation. So I think So what's the solution? Yeah. So there's just one historical note. You know, in the United States, when somebody did a national IPO, nowadays you go to the SEC and they register your offering and then you offer it nationally.

It used to be that you actually had to bring that offering to each of the individual states in the United States and get it approved. And if it wasn't approved in Vermont, you could do your IPO in the other 49 states, but not in Vermont. So you basically had 51 regulators if you take the 50 states and the SEC approving an IPO. And then in 2000, sorry, in 1996, much to the chagrin of state regulators, but they, federal Congress passed something called NISMEA. It was basically a national improve the markets act. And the intent was to take the state securities regulators out of that decision and put that authority with the SEC because it was a national offering.

It wasn't localized it. It did have an impact on a local jurisdiction, but it was a much broader national scope in terms of its impact. And a national regulator should be the one with primary authority over that. So my point in telling you that historical anecdote is, you know, could you see a situation many years down the road where an international, multinational securities offering is being regulated by some body that, you know, is overseeing by multiple member. country, nation members. And maybe that's a solution, you know, if you're trying to think, again, on the theoretical side. But certainly first steps to get there. There's certainly two concrete first steps to get there, I think. One is that individual jurisdictions have to wrestle with this and wrestle with the guidance that should be provided. So the SEC recently put

out a framework for ICOs. That was a helpful first step. But then on the national level, the international level, the SEC, NASA, other regulators internationally need to start working and communicating with each other in a more concrete way. We certainly have organizations that have facilitated that interaction in the past, but more so now than ever is the need for national regulators to interact with each other because it's no longer a United States issues, no longer a Canadian issue, it's a worldwide issue, whether you're talking about blockchain development, ICOs, cybersecurity issues. These are really matters that are impacting a business anywhere in the globe by anybody anywhere in the globe. So we really need to start

facilitating better communication. So those are sort of two concrete steps. Better formalize your guidance within your jurisdiction and then work to harmonize the that guidance with other international regulatory bodies. Despite the fact that in principle, these steps that are being developed by blockchain companies would be usable all over the globe, many companies have actually chosen to geo-block the US in orders to not get in a sticky situation with US securities laws. So US security laws are seen as much more.

more restrictive in many terms compared to other jurisdictions. Do you think that in itself stifles innovation? Yeah, it certainly can, certainly can stifle innovation. And I do have just a couple of reactions to that. First and foremost is, you know, even as a state regulator, I've been surprised by how open the SEC is to having conversations with cryptocurrency, ICO, blockchain products that impact the securities marketplace or implement or, you know, they have an involvement in the securities marketplace. They have been very open and interested. They have a fintech group at the SEC that has had individual meetings with companies that has provided them guidance, both in terms of a guidance that is individualized and also for

companies generally that are operating in that space. State securities regulators similarly are certainly open to hearing new ideas and new projects. So certainly my first piece of advice to those companies is to engage with the regulators here in the United States to make sure that you fully understand the avenues that are available to you to get either registered or to get an exemption from registration. They're basically at the very broadest levels, three different categories that an investment can fall into. It can be a registered offering, which means you go through the full registration process

at the SEC or at the state level. Or there can be an exemption from registration. So, you know, the SEC and the states have found that certain transactions don't need to be fully regulated by a body here in the United States. Or the joke is that the rest of the third category, category are all illegal transactions. And, you know, I think it just illustrates the point that folks should think about how do you get into compliance either from either from registering. And I do agree that registration process is largely for companies that are more mature, that have a more sophisticated, you know, sort of footprint in offering.

And it costs a lot of money. It costs money to get professionals, attorneys, accountants, investment bankers. So that is certainly an opportunity that does not present itself to everybody, particularly startup companies. And then if it's not through a registration process, what are the exemptions that are available to this community? And largely, this circles back a little bit to a point we had earlier, largely those exemptions that are available are private exemptions, meaning that you can sell to wealthy individuals to accredited investors. but largely Main Street investors are shut off from that opportunity. So there have been discussions at the SEC recently, and we've been engaged with them on this,

to change the definition of an accredited investor, to broaden it so that different categories of people come into that definition. And certainly that's something on a personal level that I've been supportive of, particularly younger people. they might not have developed the assets to become an accredited investor. They might not have the income yet to become an accredited investor, but they have sufficient knowledge to make them a sophisticated investor. And certainly the SEC should think about that and can you allow people to make investments in these private offerings if they have sufficient knowledge and expertise. And I would suggest that you should look to allowing them to do that.

But at the same time, you should try to protect and mitigate the amount of money that could be lost. So maybe you put an investment cap on those type of individuals that they could only invest, you know, $25,000 a year, $50,000 a year, whatever it might be. So to answer your point, you know, the U.S. laws can be complex as they exist now. It's hard to get a token offering into the hands of a Main Street investor. but it is possible and there are other exemptions that people are trying out in an effort to do that. So I do encourage any projects to sit down with a regulator to try to get more information, to try to work with them, to see how you could structure your deal to make that plausible. But at the same time, there's certainly more work that needs to happen on our side of the equation,

on our side of the ledger as regulators to think about what's the approach. appropriate balance to allow folks to get into this marketplace as investors while still making sure they have a level of protection and don't lose their entire retirement or life savings in an investment that goes south. Yeah, I think that's a decent approach to look at investors more on the basis of sophisticated or non-sophisticated rather than wealthy or non-wealthy. Because in today's day and age, I think probably this wasn't the case before. Obviously, it wasn't the case before.

Maybe this is why these laws were implemented. Today, people have access to an abundance of resources that allow them to become highly knowledgeable and gain a sophisticated amount of knowledge about things like ICOs, things like investing in these types of projects. that didn't happen, didn't, you know, exist before. And so I think that changes the landscape. And I think that the European approach to this, Frederick and I both being in Europe,

is a nuanced approach to that where, you know, when you open an investment bank account, for instance, you know, you get asked a lot of questions about your level of sophistication. And of course, any investment product has to come with a perspective, and like all these guidelines and what the investment entails, etc. So since we're coming, you know, towards the end of our show here, I'd like to talk about Vermont's more specifically.

And, you know, Vermont has positioned itself as a place that I'd like to attract blockchain companies. One interesting thing that I learned right before this podcast is that Vermont has was in the process of implementing a blockchain-based LLC. that would allow DOWs to have some sort of a corporate status. Tell us a bit more about what's going on in Vermont and about this BD LLC. Yeah, happy to talk about the blockchain LLC. And that was one.

We had a bill last session in our legislature. This was one element of that bill that I really did get interested in and excited in because oftentimes, particularly with regulators, but legislators, you know, we need to try to see some of the practical applications of some of these laws or even some of these blockchain projects. We want to see, you know, how does this get employed? How does it make people's lives better? How does it save money? And this blockchain LLC was one where I did see it solving a quite legitimate problem or confusion in the corporate world, which is, you know, when you have all of these various players that are operating in a token, offering or in a cryptocurrency. You know, what is the legal relationship between these participants? You know, are they someone that's helping mine public blockchain? Are they an independent contractor?

Are they an employee? Are they a shareholder? Are they, you know, whatever? And I think you could make theoretical and legal arguments as to what they might be or what they might not be. But what the blockchain LLC was attempting to do was give a legal entity and a legal friend. for the companies, for the projects rather, to decide what those legal relationships would be for themselves. So there's certain parameters that they have to fall within, like any corporate entity. But really, it provides much greater level of flexibility for them to legally define the relationships of all of the various players in a public blockchain. So again, this was a little bit theoretical, but again, trying to make it more operational and more practical. We have had, I think, just about a half dozen to maybe just close to 10 blockchain LLCs that have filed with the Secretary of State's office here in Vermont over the last six months.

So there has been some interest. We will at the appropriate time. I think it's a year out, take stock of who has been availing. themselves of this new entity, how is it working in practice, and then how might it need to be improved upon, or what other features do we need to think about adding to it? But at the heart of it, again, the concept was to allow the projects to define these legal relationships, which otherwise are unique and undefined and ambiguous, so that they are providing themselves some level of certainty as they operate. Very cool. And,

absolutely needed in this space. Vermont also announced a pilot project in captive insurance. For our listenership, could you first explain very briefly what captive insurance is and talk a little bit about this project? Yes, happy to. And yeah, captive insurance, what is it as a question that we get asked pretty often? So the 30-second summary is that it's a formalized mechanism of self-insuring. So you, all of us on this podcast, if we needed auto insurance or homeowners insurance, we would go to one of the big insurance companies and purchase that policy from an independent third party. Large corporate entities, however, might not find it to be the most cost efficient to go

to AIG or some other large Lloyds of London travelers, some other large insurance companies to purchase their insurance. Instead, they might decide to form their own insurance company internal to their company, and that's essentially what a captive insurance company is. They can better control their risk. They can better manage the risk. They can have immediate access to the reinsurance markets. So at the end of the day, it ends up costing them less money to have a formalized,

self-insured insurance company within their corporate structure rather than buying the insurance from a third-party insurance company. So as I mentioned, Vermont, you know, we are really the gold standard when it comes to captive insurance. We have about 600 of these companies in our state. They write about $30 billion of premium through these 600 companies in Vermont. So a very large marketplace. And the reason why we thought this pilot project with the Secretary of State relating to blockchain technology was useful in this space is because those 600 companies belong to really large international companies that are familiar with distributed ledger technology,

familiar with its upsides, trying their own pilot programs within their companies. So they have a level of interest in participating in a similar pilot. And then from our perspective, you know, what it really accomplishes. And again, I'll get back to this concept that, you know, I really am trying to appreciate the academic and theoretical nature of a lot of the discussion that I've had with many people, in this space, but trying to bring it back to a practical and operational concept and idea. And for me, this is a really small first step that Vermont can take as it relates to the way that government operates to better understand the technology.

And not just myself, but our staff here at the department, the staff at the Secretary of State's office here in Vermont, that on a granular level individual staff members here in state government can get more familiar with the technology, that companies can file. Basically, what the pilot would do is allow new captive insurance companies to file with us, their corporate registration documents, their annual filings and the like through a distributed ledger rather than the traditional paper or online filing. And again, I don't think we're going to get a tremendous amount of great efficiencies. I don't think this is going to be the greatest thing that any state government or the industry has ever done.

But what is really going to do in a practical level, again, get us more familiar with the technology and then allow us to identify areas where we can scale up. So the Secretary of State handles thousands and thousands of filings. Is there ways where they can use private or public blockchain in a way that makes their operation more efficient? From a regulatory standpoint, are there ways that we can use the technology to make the way that we take in information or the way that we regulate the marketplace? can we make it more efficient? Can we make it more transparent? Can we make it more accurate? Those are all of the answers that we're hoping to get out of this pilot project.

So we're very excited about it. We're one of the first, if not the first, insurance departments in the country to actually step out and try to take on their own distributed ledger pilot program. So again, we're very excited about the prospect of making. an incremental step and then seeing where that will take us. Great. That's really fascinating. And so finally, I'd like to ask you a little bit about your goals as president of NASA. What do you hope to achieve here? You've been with your organization now for, I think, just over six months?

Yeah, that's exactly right. We're halfway through my presidential term. Okay, so okay, so presidential terms are quite short then. Now, what do you hope to have achieved during this short time? Yeah, sure. So you're absolutely right. I mean, you can't achieve much during a single year. So really what you have to do is make sure that you start early, you lay the groundwork for any initiatives that you have early,

and that you develop initiatives that those that are going to follow you are going to be interested in continuing on. So personally, what I hope to achieve, I'm the first millennial president of NASA. We wanted to have more focus on millennial issues as it relates to investing and as it relates to retirement savings and the like. So basically, as you probably familiar with, millennials are saddled with student loan debt. They're delaying decisions that are the traditional hallmarks of adulthood, like purchasing homes, having children, saving for retirement.

And it really in some ways is causing many different social impacts than people are, I think, even appreciating or realizing. Certainly, states like Vermont, you're seeing millennials have to leave the state to get jobs that are higher paying to pay off that student loan debt. That's having a direct and immediate impact on our economy. And then you're seeing, again, young folks that are just starting out or folks that are in the middle part or early part of their career, you know, having nothing safe for retirement. and that's going to be a considerable issue when they don't have time on their side anymore and they're getting closer to retirement age. So highlighting those types of issues is one of the things I really wanted to accomplish as NASA president, get that conversation started, and to get policymakers in Congress at the

SEC and at the states more focused on millennial issues as it relates to financial services. Great. Well, that's very encouraging. Well, thank you for. for joining us on our podcast today, and good luck for the rest of your term. Well, thank you. It's been my pleasure. I really do appreciate it, and I do congratulate you as well for sticking with this podcast. I understand you guys have been doing it now for five years, and every week. That is something that's really difficult to keep up with and to do. So I applaud you for your perseverance and focus on these issues that are really important issues. Thank you.

Well, thank you. Thanks a lot. It has been five years, and it's not always easy, but we try to keep up. All right. Thank you, Michael. Thank you. Thank you for joining us on this week's episode. We release new episodes every week. You can find and subscribe to the show on iTunes, Spotify, YouTube, SoundCloud, or wherever you listen to podcasts.

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