Unchained - Caitlin Long: Why Avanti Will Be a New Kind of Crypto Bank - Ep.216

Starting point is 00:00:00 Hi, everyone. Welcome to Unchained, your no-hype resource for all things crypto. I'm your host, Laura Shin, a journalist with over two decades of experience. I started covering crypto five years ago, and as a senior editor at Forbes, was the first mainstream media reporter to cover cryptocurrency full-time. Subscribe to Unchained on YouTube, where you can watch the videos of me and my guests. Go to YouTube.com slash C-unchained podcast and subscribe today. Building a web application to sell products or services, integrate with Squares robust and secure APIs to easily take payments. Learn more at Square.com slash go slash unchained. Crypto.com is giving away four Teslas. To enter the lucky draw, download the crypto.com app and buy $100 of Bitcoin or more. New crypto.com app users get 0% credit and debit card fees in their first 30 days. Download the crypto.com app now. Today's guest is Caitlin Long, founder and CEO of Avanti Bank.

Starting point is 00:01:03 Welcome, Caitlin. Hey, good morning. Good to be back with you again. You have extensive experience both on Wall Street and in crypto. And I wondered, given your background, how you would characterize the current state of the industry in terms of this trajectory. And what would you expect to happen in terms of crypto's relationship to Wall Street in the coming years? Well, I think we're barely in the first inning. I think we are finally in the first ending of crypto. It's starting to really go mainstream and we're starting to see users use it for mainstream use cases. In terms of its relationships to Wall Street, that is evolving. I still think the two systems are evolving in parallel and not really connecting to each other. So the bridges, that bridge the two are important. And you're definitely now starting to see some of the big banks, come in in terms of Bitcoin custody, but they're not building the platforms themselves.

Starting point is 00:02:00 They're subcontracting out in a subcustodial relationship to crypto-native companies who really know how to do it. And so we have so much to discuss when it gets to the meat of the discussion, but I actually really want to make sure that all the listeners know your backstory because just in researching this, when I was piecing together all the strands of your history, which encompass Wyoming and Wall Street and enterprise blockchain and crypto. it just sort of feels like you were meant to sit at this place where you're sitting right now. So can you just walk us through your story and how you came to be in this position?

Starting point is 00:02:35 Oh, boy. Long and windy road, and I tend not to sit too long in any place. Spent 22 years on Wall Street. In part of that, started three new businesses inside the big banks. So didn't let the grass grow, was an entrepreneur inside big organizations, got the Bitcoin bug dating back to 2012 and thought at the time that we would do a walled garden acceptance of this technology and is sort of an intranet before internet approach among the big banks. And it turned out that the technology is just so fundamentally different. It just didn't fit into the text acts of the big banks. And so ultimately concluded that the open permissionless systems were going to actually grow up independent of the big banks and not inside them. And frankly, the two systems

Starting point is 00:03:30 will exist in parallel, which is exactly what is developing. And now bridges are being built. So like the subcustody contract is for the big banks, that's one bridge. And then what Avanti is doing and the other crypto banks that are fed clearing applicants are creating bridges between the U.S. dollar and crypto assets. So the only detour I didn't cover is Wyoming. I moved back to my native state of Wyoming after more than 25 years on almost 30 years on the East Coast and volunteered for a couple of years,

Starting point is 00:04:09 helping to get commercial laws clarified to clarify the legal status of digital assets. They generally speaking fall in between the buckets. And so we clarified that in Wyoming. So you know in the event there's a dispute that ends up in court what your rights and obligations are as a party to a transaction. And judges have a roadmap to adjudicate it so you don't get crazy decisions all over the place. And then we also set up this new special purpose depository institution charter. That's, I think actually this year going to be copied by Nebraska. A couple of other states have tried to copy it, but it's really complicated and detailed and intricate stuff.

Starting point is 00:04:50 And so it does take a big push to get it done, and it does look like Nebraska will be the fast follower to Wyoming. Great. And can you tell us a little bit more about how it was that you found out about Bitcoin and why you fell in love with that at that time? Well, it dates back to the financial crisis. I did not find it. Brian Bishop, our CTO, was on Satoshi's original email in October of 2009, but I was not. It took me a couple years, a few years. But I started to come across it because I got very curious about.

Starting point is 00:05:20 the mainstream explanation for the financial crisis, I realized that the mortgage problem was the symptom, not the cause. And there was definitely something else going on underlying it, went on a deep dive in alternative schools of economic thought, ranging from MMT at one end to the Austrian school at the other, and a lot in between, just did a lot of reading. And it was through those alternative economic circles that I started to see Bitcoin come up in 2012, finally dove into it in depth in February 2013. Got set up my first wallet. And then, like I said, I thought after, it was actually after I met Ripple in 2014 at

Starting point is 00:06:00 Morgan Stanley, because at the time, we all thought, all of the Wall Streeters thought we would be fired for being involved in Bitcoin. So we kept our heads down. And I was only doing it on my own time and my own dime, you know, after work and on weekends. Then this company called Ripple came in with one of the big hedge funds. and I was pulled into that meeting, and I remember putting my pen down during that meeting and saying, oh, my gosh, this is going to tip. And I was thinking at the time, enterprise blockchain would be the thing that would tip because

Starting point is 00:06:30 somebody figured out how to apply that technology to mainstream payments. It hasn't worked out that way, not as much as I thought back then. And some of us, Jimmy Song is a prominent Bitcoin Core developer, also took a tour through enterprise blockchain, thinking that that was the way it was going to play out. It didn't. And then we independently, there are others who did the same. Independently all came out and came back to decentralized open permissionless systems and are working on the infrastructure in that industry now. Yeah. And we're going to circle back to this in a moment because obviously with the GameStop, Robin Hood stuff that's been in the news, I see more chatter about that. And so I want to ask you about

Starting point is 00:07:09 but we'll actually do that a little bit later. Because one other thing that I wanted to ask about was, I feel like another kind of philosophy that you're known for is, you know, understanding that re-hypothecation or, you know, acceptance of kind of like fractional reserves and traditional banking has been a problem. And that, to me at least, and you can correct me from what I've read of your history, it sort of seems like you just sort of didn't accept that that's the way things should be.

Starting point is 00:07:37 Am I right about that? And if so, why do you think that, you didn't view things that way. It's so interesting you ask it that way because it just struck me when I realized how the system worked. This is just a violation of property rights. Most people think that they own their GameStop stock in their Robin Hood brokerage account, but I think the world is now waking up.

Starting point is 00:07:58 Certainly the Wall Street Betts world has woken up that that's not the case. It's just that Robin Hood owed it to you and they may or may not actually have it in their inventory. And most folks, I think, still don't realize that's the way it works. When you deposit your dollars at a bank, they're not yours. You've lent them to your bank and the bank owes them back to you. So what you really own is an IOU. The same thing's true of your brokerage account.

Starting point is 00:08:23 You know, if you deposit your Apple shares at Schwab, Schwab is the legal owner and they owe it back to you. And then same thing with your Bitcoin. If you deposit it out at an exchange, they're the legal owner and they just owe it you. So you don't really own Bitcoin. You own an I owe you to Bitcoin. And the systems, Wall Street's bookkeeping systems figured out that they can make money off that because the systems are never in perfect sync with each other. That's how the GameStop situation occurs where you can have a stock 138% sold short. In other words, there were 38% more claims to GameStop shares than

Starting point is 00:09:01 there were GameStop shares. We saw that in the Dull Food situation. I've experienced it in my pension business and it just hit me in the gut that this is just wrong. And it's the inaccuracies in the ledger systems of Wall Street generally are not nefarious. They're just a function of bad system design and bad technology and too many layers of intermediaries that are not in sync at the same time. But it definitely has been, shall we say, there are people, there are hedge funds out who figured out how to arb the system, arbitrage of the system and try to double dip in those kinds of situations, it's like a double spend problem in Bitcoin. Yeah, there were hedge funds who double-dipped in the dull food situation. They had sold the shares, and then they went in and filed a claim

Starting point is 00:09:46 for consideration in a lawsuit after the company had been acquired because the brokerage firm statements still show that they own the shares, and they figured they could get away with it. And it's a double-spend problem. And it's fundamentally a bookkeeping problem, and at an even deeper level, it's all about clarity of property rights. And we don't have clear property rights in our financial assets in this country. And the great thing about Bitcoin is it allows you to own your asset outright. You have legal title and you have actual possession of your Bitcoin if you custody your private keys yourself. And just the way you're talking about this, it reminds me of something that I read. I believe it was in the Coin Desk profile of you.

Starting point is 00:10:29 This idea about property rights, is that something that really is in great. in Wyoming's culture. Is that right? Absolutely. In fact, actually, one of the many civil wars that's been fought in the United States was the Johnson County Cattle War. And it was fought between ranchers and who wanted to fence off their property and actually fence in their cattle versus the open range supporters who thought they can they can graze their cattle anywhere. And so the fencing of the West is absolutely one of, we don't call it a civil war, but it was, really, and it was fought in Johnson County, Wyoming over this exact issue. Does a property owner have the right to put up a fence

Starting point is 00:11:14 to keep other people out? And the answer very clearly after that war was yes, and then the West got fenced, and the West definitely changed after that. But we've literally fought a war in Wyoming over that very issue. Yeah, because when I was reading about that, and then reading about how you kind of didn't really seem to accept that this re-hypothecation is the way things should happen. And I just thought, oh, I wonder if, you know, that is why you had that perspective because probably there weren't like a ton of people from Wyoming on Wall Street. And so maybe you could see that in a way that other people couldn't. Maybe, yeah. But there's one really interesting thing that I've been thinking about relating to stable coins,

Starting point is 00:11:58 which is, as you may be following, stable coins have really high velocity. I just looked at updated velocity numbers recently for Tether, and the annualized velocity is 1,247 times for the M1 velocity of Tether, and the M1 velocity of the U.S. dollar is four. Okay, so we're talking just not even in the same zip code. What's going on? Tether's just better technology. All of its problems aside, it's better technology.

Starting point is 00:12:24 It's better, faster, cheaper way to settle a U.S. dollar trade. And so what's happening is you can get velocity through technology. It used to be that you got velocity through leverage. And what I mean by that is in the traditional banking system, the central banks used to, before the securities markets really came along. So I'm talking about up through the 1970s, central banks would inject a dollar of so-called high-powered money monetary base into the system. And then the banks would take it and lend it out through fractional reserve banking,

Starting point is 00:12:56 approximately 10 times. And so you'd have an M2 velocity of 10. So each dollar that was created by the central bank was lent out 10 times. Okay, that's leverage, right? That's how fractional reserve banking works. We got M2 velocity through leverage. Well, now Tether and stablecoin technology is enabling velocity through technology. We don't need that leverage anymore to create velocity in the payment system. And so what's fascinating is that's going to have a big impact as these technologies. As we get faster payments generally, even leaving crypto aside, we're going towards real-time ACH. We're going towards Fed now, which will be a 24-7, 365 replacement for Fed wire that the Fed is putting together. We're speeding up payment settlement cycles. And what that means inherently

Starting point is 00:13:50 is that we don't need that much leverage in the banking system anymore to create velocity. Because technology is going to create the velocity in and of itself. It's going to create some interesting challenges for central banks around the world because things used to settle really slowly. They still do. And now we have technology to settle things quickly. Banks can't afford to be super leveraged and have the traditional fractional reserve model where they take a demand deposit and turn around and lend it out in a mortgage for 30 years. And so there's an inherent mismatch between the assets which are really long duration and the liabilities which are available on demand. And that's how you could get a bank run historically. There's a lot of tools banks have now to

Starting point is 00:14:36 manage that interest rate risk. But I think what's going to happen is all of this is just going to de-leverage the banking system across the board because we don't need to get velocity through leverage anymore. We'll get velocity through technology. It's really a big, important point. Yeah, that is so interesting. Like, do you think, so what in general do you think, what kind of impact do you think that will have on the economy? How will things change in terms of the way, yeah, the way that our financial system grows or the economy grows? Well, I think it's de-leveraging the banks. And we're seeing that already, actually, with the Fed monetizing the debt that it has over the last 15-ish years since the financial crisis, not quite 15,

Starting point is 00:15:18 but literally what the Fed is doing is taking debt off the private financial sector and putting it on its own balance sheet. That's exactly what it has done. And so this is the reason why we haven't seen inflation in CPI yet. We've seen it in other places, but we haven't seen it in CPI yet in the consumer price index because actually the new money the Fed is injecting isn't really new debt. It's basically monetization of old debt. It's swapping from the private sector financial institutions to the Fed. which is a public sector financial institution. So long story short, what it's happening is it's already de-leveraging the banking system.

Starting point is 00:15:54 We're just going to keep seeing more of that. Banks are going to de-leverage because they have to because everything's settling faster. They can't afford to take that much leverage risk. It starts to pose risk to the payment system. And by the way, this has nothing to do with crypto. Pile crypto on top of that. And it just accelerates it all. That's what I really was asking about once.

Starting point is 00:16:14 Because if we're going to start to see orders of magnitude, faster velocity, then what effect do you think that would have on our economy? Well, it's positive for the economy. And by the way, this is part of, you know, maybe part of the reason why we're seeing inflation heating up. The CPI is popping up a little bit. It's obviously related to COVID as well. But there are monetary dynamics.

Starting point is 00:16:38 To quote Milton Friedman, inflation is always an everywhere, a monetary phenomenon. There are monetary dynamics underneath it. And increasing velocity is one of that. It's not showing up in those traditional measures, though, because to go back to the M1 velocity of the U.S. dollar right now is four. It's not coming from those traditional banks. It's coming from the securities markets. It's coming from other sources where velocity is heating up. And we're seeing it in interest rates. We're recording today on a day when the 10-year treasury

Starting point is 00:17:09 is spiking. And it's actually causing some concern in the stock market. So we're going to dive into the Wyoming crypto laws. But before, Before we do that, just one last quick thing about your history that I want to ask about, I did also see that you said that even as far back as spring 2014, major multinational companies were quietly using Bitcoin to execute foreign exchange transactions. And was that just being done experimentally or was that a part of their regular practice? And was this ever publicly announced? And maybe you can't reveal something now because enough time is fast?

Starting point is 00:17:41 No, I can't reveal who they are because they're still doing it. And I know they are because I've talked to them recently. It's small. It tended to be in emerging markets where there were not well-developed banking systems. And corporate treasurers generally don't speak out publicly. You hear on financial media a lot of interviews of hedge fund managers and traders and speculators. But the real power behind the foreign exchange markets is actual movements of money in the corporate world. Real money moving overseas, not just for speculations. It's corporate treasurers who actually control the bulk of those markets, and they don't talk publicly. And they don't have an incentive to talk publicly. I mean, certainly back then, everyone would have been horrified if they understood that, you know, well-known brand-name companies were using it. And so now it's funny. I'm kind of hoping some of them come out and say we've been using it all along.

Starting point is 00:18:37 But just knowing who they are, they're probably just going to keep it quiet. And ultimately, what's going on? It's not an ideological decision. It's just that corporate treasurers have an absolute incentive to find the best, fastest, cheapest, and safest way to move money around the world. And if it happens that in an emerging market, they don't trust the banks or there's no liquidity and Bitcoin was the cheapest way to do it, then they absolutely have an incentive to do it and they've been doing it all along. You'd be floored. How many have been doing it all along. Wow.

Starting point is 00:19:11 Really interesting. I mean, it makes sense, of course. All right. So let's now talk to Wyoming. Let's just talk about how it was that you helped make Wyoming one of the states most welcoming to Bitcoin. Well, it got started when I tried to donate appreciated Bitcoin in the last bull market and realized Wyoming had a bad money transmitter law. I tried to set up an endowment for female engineers at my alma mater undergraduate, the University of Wyoming. And they couldn't accept it because as a Wyoming corporation, nobody would do business with them doing due to the bad money transmitter law in Wyoming. And so we got that. I volunteered because I'd

Starting point is 00:19:52 always kept close ties back home here in Wyoming, even though I was on the East Coast for a long time, a few decades. And so I volunteered to help fix it. I knew I'd been an intern at the legislature in college, so I was at least familiar with it. And I figured if I went back home and rolled up sleeves and sat down and talked and walked legislators through Bitcoin and why it's not scary, that we would be able to get that money transmitter law fixed. And lo and behold, we did that. But a number of legislators said, what else can we do? What else can we do? What else can we do? What else can we do? And then it just, the snowball just picked up. And I knew we had some thorny issues we had to solve in this industry. One of the biggest ones is that the legal status of crypto assets is not clear.

Starting point is 00:20:40 Wyoming was the first state to step forward and clarify that. So again, if you end up in a dispute and a judge is, you end up in court, a judge has a roadmap for adjudicating that dispute now in other states like the cred bankruptcy in Delaware. There's no law in Delaware regarding what digital assets are. And so it's a little bit of a crapshoot because a Delaware judge doesn't have a roadmap for adjudicating that dispute. And then the other big problem that we knew we needed to fix, which may be on a resurgence. again is that the banks were all debanking crypto companies. A lot of startups literally had to close their doors in 2017 because the banks closed their bank accounts in the fall and they didn't have enough time to get a bank account at like Silvergate or signature because they were overwhelmed by everybody trying to get through the door at the end of the year at the same time. And so there were a number dozens actually of examples of startups that testified in Wyoming that losing their bank account caused them to have to close their doors. It's turning out, I posted, I saw a tweet from somebody who had his bank account closed in the UK. I posted because I've been hearing about this

Starting point is 00:21:51 and seeing it in chat channels, I think there might be a resurgence of this. Has any, and I, by the way, I know something I can't share yet because I can't prove it, but there is a resurgence of this going on. And sure enough, guess what? I asked, when I put the tweet out, I asked, is anybody else having very recent experiences with this and a whole bunch of stuff came out? So, This has been a problem for quite a while that the traditional banks don't want to deal with customers who, even individuals who've been customers for 15, 20 years, and they send a payment to a crypto exchange and then the bank closes their account. And there is a reason why it's resurging. Again, I just, I'm trying to get a little bit to the bottom of what's actually going on, but it's

Starting point is 00:22:32 one of these behind the scenes things in the banking industry. And it's not good for the crypto industry overall. And was that Peter McCormack of what Bitcoin did that you're talking about? Yes. And so, but I, like, it seems so counterintuitive because now with the interpretive letters saying that banks can custody crypto assets, you would think that actually now the kind of like taboo against dealing with Bitcoin or other cryptocurrencies is, you know, old. So why do you think? I mean, I know you're, you're still kind of investigating it, but what's your theory? Well, it's a great question. And, And I know the reality is that the OCC is only one of three federal bank regulators. And the FDIC didn't sign on to those letters, to my knowledge.

Starting point is 00:23:20 And the Fed didn't sign on to those letters to my knowledge. They were OCC letters. Usually when the bank regulators move, they move in tandem. But that was not the case. And so when one goes out and makes a major policy change, it doesn't necessarily mean that the other two are on board. and they all have power over the banking system. And so what you really need to watch is what is the FDIC doing and what is the Fed doing? And are they as friendly as the OCC?

Starting point is 00:23:50 And so part of it is just knowing how to navigate this labyrinth. We have a really labyrinth and financial services system because you actually have, you really have five bank regulators. You have the OCC, you have the Fed, of course, which runs the payment system. you have the FDIC, which of course ensures most of the banks in the United States. The OCC is the national bank regulator. But then you've got state regulators. All 50 states have a regulator.

Starting point is 00:24:19 And banks can either be state or federal. And then you've got the consumer, the CFPB, the Consumer Financial Protection Bureau. So all of them, and plus FinCEN in the Treasury Department, I mean, actually, if you start broadening out the definition, the alphabet soup of agencies that actually have regulatory jurisdiction over banks is pretty incredible. And you've got to understand how all those pieces fit together. I've definitely seen a lot of jumping to conclusions in the crypto industry because of reading a headline without fully understanding how all the puzzle pieces fit together to know, is this really actually a sustainable change? Or does this mean that one of the agencies did something without the other agencies being on board? And we'll know, we'll know over time.

Starting point is 00:25:06 One of the interesting things that came out that I haven't seen anyone talking about is that the banking trade association sent a letter to the OCC. This is public demanding that because the OCC made a major policy change without putting it out for public comment, two days before they granted Anchorage, the OCC Trust Bank charter, that the charter's invalid. And the same thing with Protago. On the Protago charter, what's interesting is that that was granted after the regulatory moratorium in the Biden administration. So what you have now is the traditional banks challenging what was done by the OCC.

Starting point is 00:25:46 Will those challenges work? I don't know. But there are some substantive issues there that are procedural issues probably is a better way to say it. When the OCC made that major policy change, should that have been put out? for public comment. It's really funny because it's the shoe on the other foot. The crypto industry, when FinCEN put out a major policy change at the end of the Trump administration, without having much of a comment period, there was a huge outcry. And when the OCC did it in the opposite direction in a way that was favorable to the crypto industry, there was no outcry. And so, you know,

Starting point is 00:26:24 we'll see how the process plays out. And very much it all depends on what the new OCC. OCC head will do. But where I'm going is on this whole notion of, you know, seeing more evidence that people are having bank accounts closed just for sending wires or ACH payments to a crypto exchange, there is something going on. And it's, and it's not the OCC that's doing it. It's one of the other agencies. The scorebed app here with trusted stats and real-time sports news. Yeah, hey, who should I take in the Boston game? Well, statistically speaking.

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Starting point is 00:27:34 Conditions apply. Okay, I guess we'll have to keep an eye on that and see what happens. And just to clarify, so this isn't talking about the original interpretive letter saying that they can custody digital assets. It's about the bank charter. Okay. Right. It's about regulatory exams for the existing banks. What happens is, you know, the regulators will typically never say,

Starting point is 00:27:59 you can't do this unless it's a violation of the Bank Secrecy Act. What they'll say is, I want information on your activities in this area. And in the regulatory exam, if that's deemed high risk, then it hits you in your safety and soundness rating. And if you get hit in your safety and soundness rating, it's called the Camels score. Reputation risk is part of that. And so what happens is just by a regulator asking questions of the banks, there's kind of, it's an indirect way for the regulators to say, we really don't want the banks to be doing this. And so the banks naturally will step back and say, well, I don't want my capital charge to go up. I don't want my reputation risk score to go down. I don't want to have challenges in my audit. And so now I'm going to go through

Starting point is 00:28:43 my entire book of business and see who has sent a wire to a crypto exchange and close their account because it's just not worth it to take the risk servicing those customers. Luckily, that's not every bank. But it does appear that, especially I saw a number in the Twitter thread, a number of people came forward seemingly with Bank of America experiences where Bank of America actually asked the customers to confirm that they were not a money transmitter. And so that's definitely coming from their compliance department, for sure. Wow. All right. Well, before we move on from this, one last thing is earlier when you were talking about some of the changes that you got implemented in Wyoming. One that, and I don't know if you were kind of alluding this to this obliquely, but it was so

Starting point is 00:29:29 fascinating to me when I read about it, you were able to get past a law that prohibits judges from compelling disclosure of private cryptographic keys. Can you tell us more about that law and why you felt that was important? Well, that one didn't pass yet. It's actually coming up this year. Oh, got it. Okay. When? Yeah. Yeah. We did get a free speech protection for developers passed. Oh, okay. So that the developers aren't liable in the state of Wyoming. for open source code that they write that's used by someone else in a crime unless the code was actually malicious. So it's designed to help prevent developers from being held responsible for putting something out there that they didn't necessarily foresee that could be used

Starting point is 00:30:14 nefariously. But we didn't get the other one passed yet. Of course, you know, law enforcement is not necessarily supportive of that last year. That bill didn't go through. But it's coming up again. And that's the whole idea of that there is something special about a private cryptographic key. It is actually not just a password. It is actually the asset. And therefore, if you can compel a private cryptographic key, then everything related to that private cryptographic key, even if it's not, even if it's more, say it's a divorce settlement and you can compel disclosure of the key. and let's say that the Bitcoin was going to be split 50-50 between the divorcing parties, but the court now has access to the whole thing.

Starting point is 00:31:01 And the court is not set up to keep a private key private. And there's nothing that can be done around it. And as you know, once a private key is disclosed, it is permanently not useful anymore. There may be forks and air drops that may come in the law. the future that are now no longer secure. There are a lot of things in the future that you don't know will be able to trace back to your private keys. As I've rolled my own private keys over time, I've kept my old devices because you just never know. In my case, they're secure, but you just never know when those old private keys that are no longer actually securing any of my coins

Starting point is 00:31:41 will actually be useful again because there might have been an airdrop or a fork or something like that. And who knows what's coming in the future? We don't know. You just private keys are in a category of their own, and we're trying to get that one through so that they can't be compelled in civil litigation. The Judiciary Committee was pretty strong that they still want to allow compelled disclosure in criminal litigation, though. All right. Yeah, that one was so philosophically interesting to me. So we'll have to keep an eye on that. All right. So in a moment, we're going to talk about Avanti Bank and Ovet and all kinds of other things. But first a quick word from the sponsors who make this show possible.

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Starting point is 00:33:31 Visit square.com slash go slash unchained. Back to my conversation with Caitlin Long. So later this year, you are going to be launching Avanti Bank. How did you come up with the idea for it? Well, it gets back at what we were just talking about before the break on solving a real problem for the industry, which is access to the U.S. dollar payment system. And having been a financial services regulatory person, I've done a lot of work in and around life insurance companies on ERISA in my career and reinsurance rules. So it was more insurance focus than banking focus. But it's not that difficult once you get the skill set to really dive deeply.

Starting point is 00:34:13 and I dove deeply to try to figure out how do we actually keep it so that banks in the United States can't debank the crypto industry in that same way that they did in mass in 2017. And I learned that was in reaction to regulatory pressure that the banks were getting. It's the same. It wasn't explicit. It was never announced, but it was implicit pressure. And the banks looked at it and said, I just don't want the hassle of dealing with somebody who's in the crypto industry, thank goodness the ones that did dug in and said, I'm going to take that

Starting point is 00:34:47 extra risk and extra hassle because I can service customers and earn a good return for their shareholders doing that. And specifically, that was the Silver Gates and signatures of the world. But that's why you saw specialization among the banks, because most banks just figured it's just not worth it to take that extra regulatory hassle. I'll just close these accounts. And then they all ended up in a small number of banks and now we've got, you know, a single point of failure risk for the industry because there's so much concentration among these few banks that have been very successful. So we knew we needed to solve that problem and we created a new type of bank charter that was specifically designed to solve that problem and designed for providing custody services around digital assets.

Starting point is 00:35:31 And from our conversation earlier, obviously I'm sure there are a lot of ways that Avanti will function differently from other types of banks. What are the principles? What are the principles? you've been following in developing your crypto bank? Well, it follows the principles of the charter. And Nebraska, I think, is going to be a fast follower. So we're going to have company pretty soon. They literally have almost exactly word for word the same legislation as Wyoming passed. And so what are the principles?

Starting point is 00:36:02 One is they're non-lending banks. Why are they non-lending banks? Because the FDIC was not at the time interested in insurance. banks that handle digital assets. That's part of the reason why it's been such a slow process. The Swiss banks actually not only can provide custody services for digital assets, but they can actually own them and hold them and trade them. Not even the Wyoming Speedy Banks can do that. So you have other major countries whose banking systems and bank regulators are much more welcoming to crypto than the U.S. And that's been an FDIC point. So the Wyoming Speedy Bank,

Starting point is 00:36:40 can get FDIC insurance, but they're not required to. And so therefore, to the extent that the FDIC has issues with crypto, it's just not relevant for the Wyoming Speedy Banks. So that's one. But as a result of that, these are non-lending banks, because if there's no insurance, then the natural extension of that is, well, then you can't take the kind of asset risk that a bank typically takes. You can't lend. And so that's, that's, that's, that's just the inherent nature of the, of the charter. And it's inherent in the business model. It does happen to, uh, very strongly align with my strong commitment to property rights. Because, uh, while a dollar deposit at Avanti is, is going to be an IOU. That's the way the financial system works. It at least is backed 100% with high

Starting point is 00:37:34 quality liquid assets. And so Avanti is not a lending bank. It's not taking the typical credit and interest rate risk, doing maturity transformation, taking a demand deposit and turning it into a mortgage loan that a typical bank would do. Avanti's not doing those things.

Starting point is 00:37:50 And that's a function of the bank charter. But it does philosophically align with this, again, this commitment to property rights. We also have specifically in the trust area. So just to clarify, the Wyoming Speedy Banks cannot take deposits of Bitcoin. We can hold Bitcoin in trust. That may sound like a distinction without a

Starting point is 00:38:10 difference, but it's a big difference because banks can only take U.S. dollar deposits. And if they're a clearing bank, they get to get access to the Fed, that's where that distinction makes a huge difference. You have to be a depository institution to become a U.S. dollar clearing bank. The OCC trust banks are not depository institutions. The Wyoming Speedy Banks are, so we actually are held to a much higher standard, which is part of the reason why it's taking longer for us to get through the process as well. But we'll be able to do more when we actually open. So that all very much philosophically aligns with the whole approach of these banks. We should go back to the structure of banks that we had before the modern banking system arose and assets were all bearer assets. And that is,

Starting point is 00:38:59 banks were merely service providers. They were not counterparties. And we can't quite go back to that because of the way the Fed system works. So yes, your dollar deposits are an IOU. But when you put your Bitcoin on deposit in the trust department, that's not an IOU. In Wyoming, we are just keeping it safe for you as a service provider. We are not your counterparty. You retain legal title to the asset. It works the same way under the same law as a coat check or a valet parking.

Starting point is 00:39:32 arrangement. You don't turn over title to your car when you park it in a garage. You just give the safekeeper temporary possession of it. And that's the structure we have in Wyoming. It's very different than the structure of securities custody. And this is the concept that's legally called bailment. And this is sort of how you're fulfilling the not your keys, not your coins, ethos. Okay. That's right. Yeah. Which I. Yeah, we may be in temporary possession of the keys, but we don't actually own legal title. We're splitting that. legal title and who possesses the keys because they don't have to be the same thing. You can still get the legal title. You can still have legal title to the asset, even if someone

Starting point is 00:40:13 is temporarily safe keeping the private keys for you. And there's another principle that you've been advocating for, which is no co-mingling of funds. And why is that important? What are the problems that can stem from commingling customer funds and digital assets? Well, this is so interesting because I read the New York Attorney General settlement yesterday with tether, and this was one of the things that they really were going after. They have to prove that the funds are not commingled. When there's not, you know, light shining on financial institutions, they tend to want to commingle everything because it reduces, it allows them to take more risk,

Starting point is 00:40:48 shall we say, sometimes undo risk and putting their customers' assets at risk more than their customers understand, right? We saw that in the credit bankruptcy, the bankruptcy of a Bitcoin lender, or cred. They were commingling their assets with their customers' assets and doing all kinds of things. And there was no disclosure. And of course, as it typically comes out when intermediaries in this industry go bankrupt, it turns out that they were insolvent for a long time before they finally went bankrupt. And that was the case with cred. Yeah. So one of the most important things about solvency, again, it's a commitment to property rights. It's a commitment to fundamental solvency is that no commingling is absolutely a requirement of that. If you're going to commingle,

Starting point is 00:41:33 you have to tell the customers, they have to have clear disclosures of the risk. You can't throw a word that is not understood by most, like rehypification into a contract and have everybody sign the contract not knowing what it means. Those words that obfuscate what's really going on are very common in traditional financial services terms of service, but not in Wyoming. We actually have a requirement under Wyoming law to give plain English terms of service and really explain what the risks are. I like that. Yeah. I feel like that's why a lot of people listen to that. Well, I've heard from my listeners, they listen to the show because, you know, we, well, at least I try as much as possible to always explain all the terms. So I also wondered, you know, Avanti Bank is going to serve institutionally.

Starting point is 00:42:22 investors. So what kinds of problems do you see Avanti solving for them? And I was wondering, like, what kind of money you're seeing on the sidelines now while institutions like Avanti are, you know, preparing to launch? Well, there's a lot of interest. We've been deluged. We're in the thousands now of customer inquiries. It's more than 2,000 customer inquiries, most of which are not going to, you know, actually become customers. It's a lot of people who are individuals and, like, like you said, we're serving businesses first. The compliance, and the reason for that, a lot of people ask us, why can't I open an account at Avanti?

Starting point is 00:43:00 The compliance requirements to serve individuals are many multiples of the compliance requirements to serve businesses. So that's why we're starting with businesses first. But what problems are we solving? The big one in the crypto industry is one that most folks probably don't really understand because it has to do with the way that U.S. dollar payment systems work. when you send an ACH payment, which is the most common form of payment by far in U.S. dollars, it can be reversed by the consumer for 90 days.

Starting point is 00:43:31 And so let's say that you're a Coinbase or a Cracken or a BitTrex or a Binance and you sell a Bitcoin to a customer and you accept an ACH payment for it, they might take that Bitcoin off platform and then turn around and reverse the ACH payment and then the service providers out both sides of that trade. That's a huge risk issue. And it's simply a function of the way the U.S. dollar payment system works. It doesn't match in timing and in reversibility to the crypto assets. Crypto assets settle in minutes with irreversibility. U.S. dollar payments can settle sometimes in days with absolute reverseability for up to 90 days, right? So those two things are fundamentally different. And those are the kinds of things that we as a bank are working to solve. We'll be offering different alternatives

Starting point is 00:44:25 that can really help the crypto industry solve that fundamental risk problem. Yeah, it reminds you what you were saying earlier about how with enterprise blockchain, you realize that the way financial institutions work is just like fundamentally different. And anyway, we can get more into that later because I do still want to talk a little bit about GameStop, et cetera, but we're going to do it after Avanti and Ovid. So for Avanti, how will you decide which crypto assets you'll offer? Well, we've announced that we're starting with in Avit, we're starting with the liquid side chain of Bitcoin as well as Ethereum.

Starting point is 00:44:57 So those are the two most common, by far the most secure because they're the proof of work right now for Ethereum anyway, blockchains and by far the biggest network effects, by far. Others are interesting. We may add them over time. we're not committed to just those. But because that's where we'll be issuing Avit, we will over time be offering custody services in those assets as well.

Starting point is 00:45:22 And have you figured out any kind of standards by which you'll judge whether or not to add something new or is that still being developed? It's a good question. It's all Brian Bishop's decision. I will not interfere with somebody who receives Satoshi's original email in 2009. You know, it's interesting. We call ourselves a tech platform. with a bank company, or a tech company with a bank platform, bank charter, rather. And it really is true.

Starting point is 00:45:49 Brian is on the board, and I am not a technologist. I know, I don't know enough to make those decisions and those decisions are absolutely his. And I'll take his recommendations. So we're going to service our customers. Of course, if there's huge demand for something new, we will, we will put it on the platform. We are a customer-driven entity. We are not. not a sell side-driven entity. A lot of the exchanges and service providers in the crypto industry have really more served the sell side, so to speak. And by that I mean the platforms who wanted their coins listed and were willing to pay exchanges to get their coins listed. We won't do that and we won't accept that from any of the platforms. It's a customer-driven decision,

Starting point is 00:46:37 not a provider-driven decision. It's by-side rather than sell-side that we are focused on. And so just to give a sense of who your customers will be, I'm expecting crypto companies, but then also, like, it seems like you would also serve institutions that are interested in getting into crypto. Is that right? Absolutely, yes. And if you look at who our team is, all of us have worked in regulated financial services in the past, including a few. There are three of the five of us who are Morgan Stanley Alums, and one who I specifically recruited our chief operating officers, FHM go to work with me because we covered corporate treasurers together. So yes, we are actually working on some things for traditional financial services as well as for the corporate treasury

Starting point is 00:47:24 world. Oh, yeah, I'm sure, especially that. Did you speak at the micro strategy event or? I did not. Well, I'm not invited to. Maybe next year. All right. So you have called Avit, which is the new coin that will be issued by Avanti, quote, bank money that happens to be issued on a blockchain. So from what I've gleaned, it looks like it might be some kind of new stable coin, not exactly pegged to the U.S. dollar, but it will be some kind of stable coin that gets around the problems that consumers face with existing stable coins. Can you give us an outline of what it looks like?

Starting point is 00:47:59 Well, I can't say much about it. You'll learn a lot more when a white paper comes out a little bit later. What existing problems with stable coins do you see that could be resolved? Yeah, the biggest ones are legal and accounting and tax. They are not friendly in either, in any of those three disciplines. From a legal perspective, like I said earlier, crypto assets fall through the buckets of traditional assets. Are they commodities, are they securities? Are they property? Are they money? Right. And so when it's issued by a bank, you know exactly what it is. And the structure that we've chosen is different. And the details around

Starting point is 00:48:37 that. We filed a patent for that. The details around that will come out. And as a result of that, there are accounting and tax implications for that. That's pretty much all I can say. But I can talk about the problems. I alluded earlier that the terms of service from some of the other, some of the stable coins don't actually, they actually have a disclaimer that we're not sure that transactions in the stable coins are legally enforceable anywhere in the world. And USCC is the one that actually has that in its terms of service. I don't mean to single them out because I think it's true of all of them. They don't fit in existing legal buckets. And so you don't know under commercial law what their real treatment is in the event that you get into a dispute. And they're just being

Starting point is 00:49:20 responsible and warning people about that. But as you can imagine in the institutional world, when the lawyers go and look at something like that and say, I don't know if this is legally enforceable, boy, that keeps most of them away, even though they'd love to participate because of the payments system benefits that they'd get. Same thing with the accounting. There was a lot made of the accounting for Bitcoin, which is really ugly and needs to get fixed. But accounting for stable coins also is not as favorable as you might think, depending upon the facts and circumstances of how the coin is set up. Most likely it's an investment, which has to get marked to market through the balance sheet or a receivable, but it's not a cash equivalent. And so,

Starting point is 00:50:07 So most businesses really care about having a cash equivalent. A bank deposit is a cash equivalent. It's not cash. Cash is physical dollar bills. Most of what in U.S. Gap financial statements for publicly traded companies is reported as cash is actually a cash equivalent. Usually it says cash and cash equivalence on a balance sheet line item.

Starting point is 00:50:27 But you cannot, from what I'm hearing from the accountants, necessarily treat a stable coin as a cash equivalent. And Michael Saylor is definitely an account. exception to the rule. The other companies really do care about that because that's how credit analysts look at their balance sheet. That's how banks understand the liquidity profile of the business. They'll look at the cash line item and investments are not deemed to be liquid enough to be considered cash. And if they're not presented as cash under accounting standards, then it's then then it limits the usefulness of those. So I said about to specifically,

Starting point is 00:51:07 create a structure that is true to the technology, the open permissionless back-end systems, but solve those structural problems. It's just an example of where the innovation happened driven by the technology and it wasn't backwards compatible with what the users really needed. But yet, look at how successful they've been in spite of that. If we can actually get them to be backwards compatible to what the users, a different group of users really need, the users, i.e., who are not using stablecoins today, but would love to be able to have access to that technology, that's what we're trying to solve.

Starting point is 00:51:42 Yeah, yeah, just when you were describing that and then thinking about what we were saying earlier about how corporate treasurers move huge amounts. I was just like, whoa, you know, I don't know what you've created, but I'm very excited to see it because if it does, you know, what you're saying it does, then I really think it would be huge. Well, it's going to take time, though. I am definitely cautious that corporate treasurer, it's just like, you know, big banks. They don't move fast. And there's a lot of inertia. In order to switch systems or to switch to

Starting point is 00:52:14 something new, the switching costs really have to be justified by substantial increases in efficiency. A lot of people have been trying to solve some of these same problems in the payment system for a long time. They all fundamentally trace back to inefficiencies in ACH and FedWire. But that's the best that that's available for U.S. dollars right now to the mainstream users who have to report under U.S. Gap and really do have to pay attention to the geography on their balance sheet of where their cash is. They can't put a lot of cash into something like Bitcoin or investments or receivables. They want it in cash equivalence. And so, yeah, that's what we're working for. Okay. Yeah. Yeah. I'm really glad you brought this up because I have been trying to learn more

Starting point is 00:52:58 about how it affects accounting when companies put Bitcoin on their balance sheets. It's ugly. For one I can tell. And just out of curiosity, is Avik going to launch when Avanti launches, or do you expect that that will happen later? We'll have announcements about that a little later. It's coming. Okay. So let's circle back now to the GameStop thing.

Starting point is 00:53:20 What do you think was the core problem that happened there? Well, there were a lot of core problems. But the fundamental one is that GameStop was 100. 38% sold short. What does that mean? It means that there were 38% more claims to GameStop shares than there were actual GameStop shares. So Wall Street's accounting systems went Haywire and created more supply of GameStop shares than there were actual supply. And that artificial supply, of course, suppressed the price of GameStop shares. So I actually think the fundamental problem had nothing to do with Robin Hood. That was a secondary problem. It's kind of like the mortgage problem in 2007.

Starting point is 00:54:01 That was a symptom, not the cause. Robin Hood was a symptom, not the cause. The cause, the fundamental cause was GameStop stock should never have been allowed to be sold 138% short. And the real legitimate owners of GameStop stock had their pockets picked as a result of that. They had the price suppressed because anytime you increase the supply of something artificially all-als-equal, it's going to suppress the price. Think back to your supply demand curves. You push the supply curve out to the right. It pushes the price down, right? That's what happened to GameStop stock. And the Wall Street Betts folks figured it out and realized that they could fight back and did. But the fact is that that situation would never have arisen had GameStop not been sold 138 percent

Starting point is 00:54:50 short in the first place. And then what about the settlement time of two days? How do you feel like that? Like, do you feel like, because some people have been saying, particularly Chad Cascavilla, who was on my podcast recently, he was talking about that. Do you feel like if that were eliminated then and by blockchain technology that, you know, he's, see, this is actually why I wanted to talk about your experience at Sympian because he has this, you know, Paxos settlement service, or not he, but the company. It's a private permission chain for stock trading. And given your experience, I kind of wondered, like, do you feel like that might go somewhere

Starting point is 00:55:29 or do you feel like that probably won't? Sure. And I wish them well. Absolutely. There's a lot of innovation happening in this area. And I do believe that Gary Gensler at the SEC, the new SEC likely commissioner, if he has confirmed, he's been officially nominated by Biden. He's a former. MIT cryptocurrency teacher, professor. And so he's obviously very familiar with this technology. And here comes this whole GameStop thing that you know is going to be, you know, is going to make his confirmation hearing, you know, a CNBC news story. And he's going to be asked about it. And what is he going to do about it? And one of the questions is going to be, are you going

Starting point is 00:56:11 into greenlight blockchain versions of securities? And absolutely, Paxos has been working on this for years. It takes a long time to get inroads in some of these infrastructure plays. And absolutely hats off to everybody who is trying. He's absolutely trying to solve the same problem that I've been trying to solve for years. Part of the reason why I'm focusing a little bit more on payments is in part because one of the reasons I think we've never gone faster than T plus two in security settlement. The big reason is that too many people are making money off securities lending in that two-day period. they don't want to close it down. But this is exactly what causes the game stop type problems, right?

Starting point is 00:56:51 But the other reason is that U.S. dollars settle really slowly. And if we can actually get faster U.S. dollar settlement, I think that's going to drag the securities industry into faster security settlement, too. So Chad and I are working on the same problem from different angles. And absolutely, I would expect to meet and hopefully work with them. Oh, interesting. Future announcement of it impacts. So blah, blah, blah.

Starting point is 00:57:18 No, nothing now. You know, what's fun about being in the position that we're in is literally we're frenemies with everybody in the industry. We may be competing with them in certain areas, but we're also going to be in a position where we can actually help them solve their problems too. Right. And so, you know, I'm not trying to either get you to criticize a competitor or anything. But I am still just curious about this idea that, you know, as you were saying, when you

Starting point is 00:57:44 worked in traditional finances, you felt like the tech stack was just. is so completely different. And the mindset was so completely different around kind of like closed source and then versus open source and all these things. And so I just did wonder like in general, like, do you think that means it is not likely that these kinds of problems that we saw with GameStop and Robin Hood would be solved with blockchain technology? Or do you think that potentially it could be? Oh, I think they absolutely will be. I think it's really hard to get to get decentralized stock trading platforms because by nature, a security has an issuer. And so by nature of the fact that there's an issuer, it really is tough to be decentralized.

Starting point is 00:58:23 I mean, we've seen it. The SEC has implied that Ethereum, even though it had an issuer, became decentralized. But I don't think securities, even for the largest companies, you know, the giants like Apple, I don't think they'll ever be sufficiently decentralized to take the issuer out of the equation. And, you know, keep in mind it for corporates, things like dividend payments and corporate actions like mergers and acquisitions, stock buybacks, those kinds of things, are inherently issuer-focused functions. And so absolutely, I think that that is more conducive to private blockchain systems. However, one of the interesting things that I learned about

Starting point is 00:59:07 the tech stacks of the big banks is they're just all very centralized. and layered. They're designed for a delayed net settlement system with multiple intermediaries. And even private permissioned blockchains are decentralized a lot more than that. They are set up for something closer to real-time gross settlement as opposed to delayed net settlement, but they're really not that, they're not, they're, they are still pretty fundamentally different. So the point I was making isn't necessarily that the text acts are so different that it's permissioned versus permission lists, it has to do with the degree of centralization and the degree of the layers of intermediaries and all the netting that happens. That's the fundamental system

Starting point is 00:59:52 difference that even permissioned blockchains were running into. They just weren't supplementation of existing systems. They were rip and replace. And for a company to rip and replace entire systems, I mean, the Australian stock exchange is doing it. Look how long it's taken for them to do it because they basically had to rebuild it from scratch. These are not incremental upgrades. Well, okay. All right. Well, so we will see how this all plays out.

Starting point is 01:00:20 But certainly I do think that this has put a spotlight on the potential for blockchain technology. But I do sometimes also think, oh, just the open system is moving so much quicker. So anyway, all right. It absolutely is for good reason. Yeah. Yeah. All right. So switching gears, with your background heading up Morgan Stanley's pensions group,

Starting point is 01:00:39 I was curious when you thought we'll start to see pensions investing in. Well, no, I got, when I wrote this guy, I realized we had one or two that did. Right. We've had it. Well, a number of them have through their venture capital allocations. So Pomp's firm, for example, I think he announced there was a fire, fireman's pension fund in Virginia, as I recall, that was one of the first ones. We've seen endowments invest. A lot of endowments have invested through their venture capital arms.

Starting point is 01:01:07 We're starting to see endowments actually directly on. own crypto. I don't know much about pensions. I don't know a lot of examples of the pensions directly owning crypto. Mostly they're doing it through either a VC fund or a or some sort of a fund structure like even GVTC. And so what hurdles do you think we'll need to overcome before we'll start to see that happen where they own crypto directly and in a big way? Well, the biggest hurdle is operational. Asset managers are not set up to custody their own assets. And a lot of that has to do with the Investment Company Act and Investment Advisors Act of 1940, two different acts that were passed after the Great Depression in response to fraud that was taking

Starting point is 01:01:51 place where asset managers were custodying customers' assets and then making off with them. So there's been a fundamental approach to separate asset management decisions from custody. And that's why you have the SEC custody rule. Now, Bitcoin is not a security, but what has happened is, that as best practice, a lot of asset managers will apply the same standards for non-securities because they have to do it for securities anyway. And so if something's a commodity, they may as well just use a third-party custodian. They didn't build up their custody capabilities internally. And that's the biggest hurdle is getting true institutional,

Starting point is 01:02:34 qualified custodians that meet ERISA standards. And that's a higher level of service and higher level of legal protections than is generally available right now. One of, for example, the things I like to point to is there's a reason why the big securities custodians are banks with Fed accounts. State Street is technically a trust company, but it was grandfathered in so long ago. They all have Fed clearing capabilities. They are full depository institutions.

Starting point is 01:02:59 Trust companies are not. And it was the best that was available. state chartered trust companies were the, that was the best that was available to the crypto industry until last year. When the speedy banks came along, we are depository institutions. And then the OCC trust bank charter is not depository institutions, but it is a step above a state chartered trust bank. All right. So I know Avanti is launching later this year. You have tweeted that Avanti will bring together strange bedfellows. So I wondered if you wanted to elaborate a little bit more on that. I give us a sneak preview of what we could expect and when from Avanti.

Starting point is 01:03:36 Well, we're sitting at the bridge of the traditional financial services industry and the crypto industry. And so even already our shareholders who have supported us in our early stages are an eclectic mix of Bitcoin OGs, so to speak, and the traditional financial services world. And so, yes, everyone should expect to see that. We have to live in that traditional world. And it is really important that our executives, our board, and our shareholders understand that traditional world and come from there. But of course, we also have very crypto-committed folks, too. And it creates some, you know, interesting fault lines because the banking world is very regimented and very rules-based. And the crypto world is the opposite of that. And so it just,

Starting point is 01:04:28 it creates strange bedfellows, yes. All right. And so maybe there will be a launch like in the summer or when do you think? Yeah, we haven't put out a specific date yet. All right. Well, we'll just. It's coming, though. We'll just have to. The light is at the end of the tunnel. Yes. Great, great. Well, congratulations. Early, early congratulations. Thank you. So where can people learn more about you and Avanti? On Twitter, I just joined Clubhouse a few weeks ago, too. I've been fairly active on that as well. And then obviously avontibank.com.

Starting point is 01:05:00 Perfect. All right. Well, thank you so much for coming on Unchained. Yeah, appreciate it. Good to see you again, Laura. Thank you. Thanks so much for joining us today. To learn more about Caitlin and Avanti, check out the show notes for this episode. Don't forget. You can now watch video recordings of the shows on the Unchained YouTube channel. Go to YouTube.com slash CUNCH-Up Unchained is produced by me, Laura Shin, with all from Anthony Yun, Daniel Ness, Mark Murdoch, Dan Edelbeck, and the team at CLK transcription. Thanks for listening. Thank you.

Unchained - Caitlin Long: Why Avanti Will Be a New Kind of Crypto Bank - Ep.216

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