Unchained - DEX in the City: How the SEC’s Crypto Task Force Is Rebuilding Trust with Builders

Episode Date: April 8, 2026

Will SEC guidance stick around if the administration changes? Commissioner Peirce and Sumeera Younis of the Crypto Task Force answer. Thanks to our sponsors! * Citrea — Bitcoin changed how money... works. Citrea changes how Bitcoin scales. Trust-minimized BTC on a fully programmable platform with native stablecoin CTUSD. Get started at citrea.xyz/unchained * Ether.fi — 15% cash back on groceries, restaurants, and rideshares. 3% on everything else. Borrow against holdings at 4% or less. Earn up to 8% APY. Go to ether.fi/unchained. * Multichain Advisors — Emerging technology growth firm with $50B+ in enterprise value created for 80+ clients. TGEs, go-to-market, BD, capital markets advisory, and more. Visit multichainadv.com. The SEC’s Crypto Task Force has spent over a year rebuilding a relationship the industry feared was broken for good. Commissioner Hester Peirce and task force Chief of Operations Sumeera Younis explain how the SEC prioritizes crypto policy questions, why tokenization leads the agenda, and what happens to this guidance when the administration changes.  They tackle the gap between large players shaping policy and small builders who want clear instructions, reveal how the SEC and CFTC coordinate to prevent jurisdictional conflicts, and argue that smart contracts and AI could reinvent securities disclosure. Hosts: ⁠⁠⁠⁠⁠⁠⁠Katherine Kirkpatrick Bos, General Counsel at StarkWare. Previously held senior legal roles across DeFi and centralized exchanges. ⁠⁠⁠⁠⁠⁠⁠Jessi Brooks⁠⁠⁠⁠⁠⁠⁠, General Counsel at Ribbit Capital ⁠⁠⁠⁠⁠⁠⁠⁠TuongVy Le⁠, General Counsel at Veda Guests: ⁠⁠⁠⁠ Commissioner Hester Peirce, U.S. Securities and Exchange Commission Sumeera Younis, Chief of Operations, SEC Crypto Task Force Learn more about your ad choices. Visit megaphone.fm/adchoices

Transcript
Discussion (0)
Starting point is 00:00:00 Hi, all, and welcome to Decks in the City, where the wallets are cold and the takes are hot. First, we have Jesse, Web3 prosecutor turned Web3 protector at Ribbett Capital, and V from the SEC to Web3. And I'm your host, Catherine KK, fluent in Tradfai and Conversant in Deep Tech over at Starkware. We have an incredibly special conversation today and two incredible guests, including Commissioner Hester Perce and the Chief of operations of the Crypto Task Force, Sumera Unis. We are so thrilled to have them on. But before we get going, remember, we're lawyers, but we're not your lawyers. So nothing you hear on decks in the city is legal or financial advice and it doesn't create an attorney-client relationship. For the fine print, as always, check Unchained Crypto.com. Before we continue, here's a word
Starting point is 00:00:50 from our sponsors that make this show possible. Bitcoin changed how money works. Satrea changes how Bitcoin scales. With a trust minimized BTC and native stable coin, CTUSD, Citraia enables Bitcoin capital markets with lending, privacy, Bitcoin yield, and more. Get started at Citraia.xyz slash unchained. EtherFi is giving Unchained listeners 15% cash back on food and ride apps, and that's on top of the 3% you get on everything else. Your bank is charging you to use your own money. I switched. Go to Ether.Fi slash Unchained to claim your discount. Multi-Chain Advisors is an emerging technology growth firm that has helped create 50 plus billion dollars in enterprise value for 80-plus clients over the past four years.
Starting point is 00:01:38 They're the partner to help navigate markets. Build real traction today at multi-chain ADV.com. And we're back. So as I mentioned, we are just thrilled to have two very special guests today from the Securities and Exchange Commission. Sumera Eunice, who is chief of operations of the Crypto Task Force, and Commissioner Hester First, who will be joining us momentarily. This is actually perfect because one of the reasons we started this pod is to amplify female voices in crypto. Obviously, Sumera and Commissioner First are not specific to crypto. The SEC does a lot of other things outside of crypto, as the three of us know. However, it's wonderful to know and to acknowledge that there are a whole host of very powerful, brilliant women across the private sector, but also across the public sector and
Starting point is 00:02:33 within the government. So it's really fantastic to hear their insights occasionally. And I will also say as general counsel in this space, it's important to have transparency in an open line of communication with your regulators as market participants. And even if crypto is not regulated by the SEC are parts of crypto, it's important to understand how regulators think. So let's start with Sumera. One of the things that we feel like is really important to cover at the start and that our listeners want to know is, let's be honest, what does the task force, what does the SEC's crypto task force actually do day to day?
Starting point is 00:03:15 Like what are your focus areas? How many submissions have you reviewed? Give us more insights about what your days look like. Thanks so much for having me on. And before I begin, I just want to give the SEC disclaimer. Anything I say today does not represent the views of the commission, the chair, the other commissioners, or the staff. There are my personal views made in my capacity as chief of operations of the Crypto Task Force. So speaking of the Crypto Task Force, what do we do?
Starting point is 00:03:43 We do a lot. It's been quite busy since we've launched. It's been over a year now. But as you know, we hit the floor running. And ever since then, it has been kind of a real deal. real fire hose of an experiment. Initially, when we first launched, one of the prime imperatives was to rebuild trust with the industry.
Starting point is 00:04:05 We were coming out of a climate where we really had an environment where people did not want to talk to us. And I think to do good regulation, you need to have that open channel communications. And so we work really hard to develop that. We went through the round tables, you were on one of our round tables, and this was a way for people to get back in the building
Starting point is 00:04:25 to start having some of the foundational conversations we needed to have in the space. Moving forward after we kind of reestablish that trust and that communication line, we issued guidance in areas that we felt didn't need further action from Congress or more significant rolemaking. You know, we called it low-hanging fruit. What are things that we can clarify instantly
Starting point is 00:04:48 that we know there is clarity on? And so we issued different statements from the staff. And now we're in this phase, where we are thinking about long-term robust actions that we can take that will be durable, you know, as administrations change or as developers build that they can rely on. And one of the best things that we can do in that space
Starting point is 00:05:07 is have rulemakings that address places there are still gaps or uncertainty. And so the staff is hard at work on doing that. The task force was closely with the staff, but our day to day in the beginning was just lots of meetings, lots of engagement, reviewing, you know, the hundreds of written input submissions that we received to Commissioner versus initial request for comment. And now we're really in the pens down part we're reviewing, rolemaking drafts, where that's possible.
Starting point is 00:05:36 We're working on commission statements, you know, things along those lines. So a lot more time just with our screens and reviewing documents and writing. You're doing a lot of work. Like you're working very hard and we're seeing the results of that. You know, we're seeing the guidance. We're seeing the commentary from the commission, which is fantastic, especially because you're right. Like, prior to this SEC administration, there was a lack of engagement because there was a pervasive fear of engagement,
Starting point is 00:06:05 which is, as I think we all know and understand is, is not a good way to operate. It's not good for anyone. I mean, it's not good for trad by. It's not good for crypto. So I love seeing that open dialogue. And I also need to say, as an aside, one of the reasons I knew I immediately liked Sumer, is when I was at the commission, you know, prior to the financial surveillance and privacy roundtable, we were having lunch and there was no diet Coke available.
Starting point is 00:06:35 And people who know me know that I need my one-a-day fridge cigarette. I was going to say, I thought we call them fridge cigarette. And Sumera was kind enough to direct me to a vending machine to facilitate that. And fantastic. We have Commissioner Persse, who has just. joined us as well. So not at all. It all happens to the best of us.
Starting point is 00:07:04 What powerhouse is on this call? We're so happy to have you both. It's amazing. We are so thrilled to have you both. And Sumera was just talking more about the how the crypto asset task force or the crypto task force operates day to day. But one of the questions, you mentioned the round tables. We mentioned the round tables.
Starting point is 00:07:24 I love the round tables because it really underscores your on transparency and engagement with the industry. What's the internal process for turning a roundtable or thinking about those conversations and thinking about that content and turning that into or considering that in actual guidance? So I'll direct that one to Commissioner Perth. Sure, and I should say before I begin,
Starting point is 00:07:49 that my views or my own views as a commissioner, not necessarily those of the SEC or my fellow commissioners. So you're asking about the process for taking what we learn at a roundtable or at roundtables and converting it to guidance? Exactly. I mean, it's just one input, a very helpful one. I find it really helpful when you have multiple people interacting with each other, you know, in response to the same questions and the same conversation. So it's definitely one useful input. The written input that we're getting is also helpful.
Starting point is 00:08:23 and then all the meetings that we're having. So I think it's just a combination of those things. I go back and watch the round tables again because I feel like there's a lot. And so I want to know whether I'm missing anything. And so I feel like that's, you know, it's just an input into the process, basically. Yeah, and I will say I know as Commissioner Perth says, we revisit them, it's difficult right in the moment to digest everything, to think about follow-up questions. And the beauty of them is we have published them all on our Crypto Task Force website.
Starting point is 00:08:58 So folks can go back and look at areas that are a particular interest to them. I know the staff does this. And I think that's a really important point to note. When staff is now in the process of rulemaking, they have that as a really great resource to use. They can go listen to those conversations. And then they know subject matter experts that they can reach out to that, you know, we did curate for those roundtables. And we were speaking about AI earlier before we started. I was going to say, how to use AI for that analysis?
Starting point is 00:09:27 I didn't know this until very recently, but I can literally, this was in a public website, not in our internal systems, but I can ask it, like, what was KK's main point? What is you most concerned about on this issue? And then tell me the two people of the strongest views on this and what their main points were. And I was able to like really look at that. And then it gives you the timestamps, right? So then I can go later and look at that or re-listen to it. Because sometimes I was like, I know somebody has brought up this point.
Starting point is 00:09:56 I really liked how they approached it. But if I was just left to my own devices, that's gone into a black hole forever. Now with both the fact that we have them available for future viewing, but that we can engage in it in a way that I think is unprecedented, really superpowers the impact of those round tables or any other dialogue that we're engaged in.
Starting point is 00:10:16 That's amazing. Actually, before everyone joined, we were talking about the multitude of uses for AI for efficiency purposes, everything from me using it to help my husband, serve as head coach of our son's baseball team, to distilling large quantities of information in a more efficient manner. So that brings us to another question, you know, for both of you, either or there's so much going on in crypto. And, you know, one of the things that we've always said on this podcast is the difficulty in regulating the space is that there's a lot of apples and
Starting point is 00:10:48 oranges, you know, NFTs and tokenized securities and L2s. How do you prioritize the multitude of issues that are arising right now, you know, that may or may not ultimately come under the jurisdiction of the commission? Well, I mean, I think it's certainly difficult. And we're not making everyone happy with how we prioritize. But I think we had to start out by sort of just figuring out what we could say was outside of our jurisdiction and then move to the things that are inside the jurisdiction and then work on issues that are particularly technically or legally challenging there. And so, you know, you will see rulemaking coming and I think that just takes longer too. So it's sometimes it's a question of what, you know, what we can do quickly versus what will take a little bit longer as well.
Starting point is 00:11:48 So, but you know, we want one of the big areas that's been of interest has been tokenization of securities. And that's an area where it's clearly within our remit, it touches on a lot of different things. And so we're thinking about a lot of issues related to that. And then the issues that we had seen come up during the roundtables and even before the Crypto Task Force started, there are a lot of questions about a lot of things. So we kind of had a priority list, I guess, going in, but we're also always. always looking for input on how to set that priority list. Sumera, I don't know if you have anything to add on that since you're in it day to day.
Starting point is 00:12:27 Yeah, definitely, I think the organization that we had on the onset of the CTF was really helpful in terms of what we'd already heard and thinking what answers can we provide quickly. Moving forward though, engagement from industry is so important. We're going to hopefully get congressional direction and then we have so many conversations
Starting point is 00:12:46 and themes appear, right? So if we hear from three, five, nine practitioners, the same issue or question, then we know that this is something that the market demands an answer for right now. What can we do? Can we answer it or is it something we need to contemplate in the rulemaking process?
Starting point is 00:13:03 But that external input is really important to us and it really has helped direct it. And then we have no action request or as their exempted requests come in and those also help guide us in terms of what are the real issues that need answer And that helps direct us as well. But I think sometimes I will hear in offline conversations the same issue coming up and again and again.
Starting point is 00:13:29 And I say you need to formally come in. You know, you'll hear about people on sidebars and conferences speaking about it. You'll hear about it on podcasts again and again, but no one is engaging the building on it. When that doesn't happen, it's difficult for us to justify prioritizing that when we have so many live issues before us. So if there is something that you consistently are facing as a practitioner or in the industry, then it's important that you actually reach out to the building and make that hurt to us in a formal way as well. It doesn't have to be obviously something. It can be a call.
Starting point is 00:14:02 It can be an email. It doesn't need to be something super specific. Yeah. I think that's a really good piece of advice. I wanted to ask something sort of related to, you know, all the work you're doing and now you're deciding what to prioritize. So I wasn't at the SEC as a staff attorney. Most of that time was in the enforcement division. But for like the last nine months of my time there,
Starting point is 00:14:24 I was Chief Counsel of the Legislative Affairs Office. And one of the coolest parts of that job was being able to provide technical assistance to Congress on draft legislation that they were working through or considering. So my question is, you know, we know that Congress has been working, on the Clarity Act for a while now. But like you said, right, the market needs guidance, the market needs rules. So it's not like the SEC can just, you know, stand by and wait for that.
Starting point is 00:14:57 Has it been really challenging to sort of think about where you want to move forward, knowing that, you know, this is pending in Congress. There are still a lot of life and some very controversial issues that Congress is trying to work through. Like how do you balance that and how do you coordinate with Congress to make sure that, you know, what you're doing is aligned with what you think they're going to do? I imagine that. I think that we have authority, and Congress wanted us to use the authority that we already have. And so part of that is easy. And I think part of it is just saying to people, hey, some of this stuff is not actually in our jurisdiction. If you want it to be in someone else's jurisdiction, maybe it already is,
Starting point is 00:15:42 but if you want it explicitly to be in our jurisdiction or someone else, as you're going to, you know, Congress needs to know that, that that's an area where if they want to fill a gap, there's a gap there. And then, I mean, I think what we're doing is generally aligned with what we know what Congress is trying to do. We've all seen drafts of the Clarity Act, so we know kind of what's in order. And we do know some of the issues that are particularly sensitive. I think what we're doing just helps inform that broader congressional effort, and we're certainly not trying to step on any toes.
Starting point is 00:16:19 They have the pen when it comes to writing the law, and we will do what they say that we should do. But I think the steps that we're taking both independently and then together with the CFTC are going to do a really nice job at laying the groundwork for joint rulemaking and other cooperation with the CFTC so that we can get what. whatever they want us to put in place online faster. You guys. Oh, no, go for it. I was going to say we're definitely sensitive to Congress's intentions here.
Starting point is 00:16:53 We've seen the different iterations of the Clarity Act. And so knowing that, we can also move forward, knowing we're not necessarily working in a space that there may be great area. And we would have to change our work or approach as a result of clarity. Luckily, you guys open the floodgates and people seemingly have responded with a host of different inputs. You know, the submissions you were talking about the roundtable, obviously. I know you made an exhaustive effort to go around the country and meet with different teams, sort of prioritizing the smaller teams. That's a lot.
Starting point is 00:17:27 Thank gosh for AI to help out, but also your guys' experience in brains. I wonder, are you, and, you know, as crypto has grown, we're realizing it's not a monolith anymore. there's going to be coalitions that build up within it and people with different opinions on what to prioritize. Like, have you seen different goals and priorities from the smaller teams versus the larger teams? And how do you think about that interaction as you move forward? I mean, for small teams, it's just really difficult because they can't afford lawyers.
Starting point is 00:18:01 And frankly, if they get lawyers, they're, you know, without some guidance from the SEC, there's not a lot that lawyers can tell them about how to move forward. And their funding is running out, right? So their timeline is just so much more constrained. So I feel like there's definitely, I mean, a frustration from the smaller projects that I get. In terms of what they want, I mean, I think they would just like us to tell them what to do
Starting point is 00:18:33 so that they could just build their stuff. And the larger market participants in this market, I think, are more eager to shape the policy because they have the bandwidth to work on shaping it. So it's more like small guys tell us what to do and we'll figure out how to do it. And the bigger guys are saying, hey, we have some really good ideas about how you should do things. So that's what I would say is the difference I've noticed. I don't know, Samira, what you've seen.
Starting point is 00:19:08 Yeah, and those two things are actually, they work well together, right? We have resources with players who are either legacy players or have been around and they have deeper pockets. So they can invest in some like the legal analysis or the advocacy work. And then we have smaller teams who can actually leverage the results of that work.
Starting point is 00:19:28 For us, it's been really, really important to create a framework which small builders can rely on and they can access the capital markets through and that's something we've been sensitive to throughout this process. We don't want to create an environment in which you need seven or eight figures just to put your foot in the door. I think that's really criminal and we want to avoid that. So a lot of the guidance we put out, we really try to make it broadly applicable so anyone can rely on it. As we move forward to rulemaking, we're very thoughtful about how is this going to impact everyone on the spectrum. So crypto on the road was a great way to get out there.
Starting point is 00:20:05 But even without that, without that sort of program, everyone should know we do have an open door policy. You don't need a special access pass to access your regulator. We have a crypto task force website, which has a meeting request page. Anyone can request a meeting with us. We don't want this to be a situation in which a handful of law firms or a handful of entities
Starting point is 00:20:28 are the ones who have access. We want to hear from anyone who have. has like a serious developed idea in this area, you know, and I do pride ourselves in having been accessible. You don't want to meet with us, you can submit written, but we want to hear both people who have concerns about the approach we might be taking. So we've not ever tried to be in an echo chamber
Starting point is 00:20:49 of just hearing from one voice, and we've tried, you know, pretty aggressively to make pathways open for any person. I love that and I, oh, sorry, B, I was just going to mention really quickly, I have a good friend who's a founder of a very small company. And a couple of years ago, he responded to Commissioner Persis' tweet when you were in Chicago at some point and had a meeting. And he was just kind of stunned.
Starting point is 00:21:13 He said, I can't believe she responded. And we met and had coffee. And I was like, this is how it should work. Like, and it's a very American concept to have that access and engagement intellectually with your regulators. So I really, you know, want to take a moment just to say thank you for, you know, kind of walking the walk and talking to talk about having that, you know,
Starting point is 00:21:37 communication and transparency. Well, I appreciate that, although I will tell you that not everyone. It's about being the West night. Yeah. Is that? Not everyone is that positive about the prospect. I was just saying, I got a nice response the other day
Starting point is 00:21:57 saying, like, why would anyone ever want to meet with you? And I was like, well, then you don't have You don't have to. You're mostly beloved, Commissioner First. So I'll say that. I think it's pretty universal. Yeah. I just had a quick follow-up question for what Samira was just saying.
Starting point is 00:22:19 So, you know, I think making sure that you're, that the door is open for conversations with both, you know, small startup teams, but also more established companies is really important. But I wonder if you think about that also. in the context of, you know, you guys are thinking about coming up with compliance pathways, right? So if you're a token issuer, for instance, like it shouldn't cost you $2 million. And again, a team of like seven lawyers to launch your token or to register in some other way. So I wonder if you think about that in terms of like creating pathways for crypto to come into compliance. Yeah, absolutely. I mean, I think that's one of the things that we're working on with our rulemaking is to, you know,
Starting point is 00:22:59 let the regulation be proportionate to the amount of money that you're raising. Because once you start raising large amounts of money, it's, I think, reasonable to say, hey, you know, you ought to be able to pay a lawyer with some of this and figure out how to make sure you're getting the disclosure right. But they're great Asians. And I think that's not only true in crypto. That's across the board. We do try to look at the side. of the entity and the size of the fundraise and try to have things be reasonable in relation to that size. Yeah.
Starting point is 00:23:40 Yeah. That's right. Definitely reasonable more than anything else. You're right. Like there needs to be some degree of ownership when you scale and, you know, when you have a deep pocket to pay the lawyers. One thing I just want... I certainly don't want the large projects to spend all their time, all their time
Starting point is 00:23:59 and money on lawyers either. No. No. But I think we can get to a good point where, at least certainly a better point than where we've been, I hope. Samara, you were going to say something. Yeah, I was going to say we've been trying to be very mindful of that in our proposal drafting, but, you know, it's really important to reiterate that we need feedback on those proposals. So there are questions and if it isn't workable, that's the time to really let us know. The rulemaking teams are always open to engagement as well.
Starting point is 00:24:31 You can continue to leverage us as well as a resource, but at that point you're really going to want to work closely with the rulemaking teams and give them input on where it's not workable for every part of that spectrum, right? And that doesn't require you answering every letter, every question that is in a proposing release or, you know, if you have a very specific issue, you should feel free to send that into us. It doesn't have to be a formal letter. It can be an email. It will be publicly posted if it's a comment on a rulemaking. But that then enables other people to say, hey, yeah, I also have that concern or I have that problem. And so it doesn't have to be a big exercise. Just if you see
Starting point is 00:25:14 something you don't like, tell us. If you see something like, you can tell us that too. I'll tell you the good stuff and not just the bad stuff. Yeah. So really quick before we move on to a different topic. I wanted to double click on one aspect of the legislation piece and only because I don't know if others have observed this, but for the past year or so at every crypto conference, particularly the ones that skew institutional, there's been almost a singular focus on three topics, you know, tokenization, including tokenized security, payments, and sable coins with maybe privacy as the next conversation as you talk about markets moving on chain. And obviously, there's been a real focus and discussion on the stable coin yield question as it pertains to
Starting point is 00:26:02 legislation. So you too alluded to how you kind of support and communicate with legislators through this process. But how have you kind of served in this process or surrounding that question specifically? Is it more of kind of an educational discussion as to when that question raises, you know, securities-oriented risk? or has there been more specific engagement on the stable coin yield question in particular? I mean, the stable coin yield question is really outside of our purview. I think that there's a lot of interesting stuff happening with tokenized money market funds, and I suspect that those yield conversations may shed some more attention on money market funds.
Starting point is 00:26:53 But again, we've taken the position, which is consistent with the statute that those stable coins are not securities, and so they're not within our remit. Fantastic. And I think that line drawing has been one of the best aspects of the kind of guidance that we've seen so far. And it's been very thoughtful, frankly. And it brings us to another aspect of all of this is something that the G. see talk about a lot is disclosures, right? And I think, Jesse, you wanted to ask something specific on that topic. Yeah, Commissioner, you mentioned disclosure. So I thought we could go down for a second. You know, there's the worldview out there, which I think many on this call hold that people when given good information can make their own choices, right? But, you know, in crypto, how that looks can be very, very different because the velocity of information is just at a different level, but there's also
Starting point is 00:27:54 transparency. So I guess I would I would love to throw it to you guys on any ideas about like what does good information I have quotes going up look like in crypto and does it look different than it does in traditional financial markets. I mean first of all I would say the market shouldn't wait for the regulators to tell them what good information is like if there's stuff that you think people need you know people should be asking for that information. I just I find it, and I think there are some now private sector efforts at sitting down and thinking about what information would you want from a token project if you're buying the token. And those have been very helpful and informative to us too as we think about these issues.
Starting point is 00:28:41 But I think it is a different set of information than you might want if you're just buying a share of a company. And so I think people need to be thoughtful about that. And then as we see problems arise, that should help us think too about what the disclosure disclosure should look like to surface those problems earlier for people. But I think, you know, it's always important for anyone buying an asset, not to buy it unless she has the information that she needs to feel comfortable buying that asset. For some people, that's going to be more information than other people.
Starting point is 00:29:16 And I always say, don't worry if you miss out on buying this asset, there will be others. So I really, part of the, you know, the part of me that says people can be responsible from themselves means that people really do have to do some work or find someone to help them do that work for them. They don't have to do it themselves. But, and that we have a role to play in that as a regulator, but it's not the end all and be all rule. But Sumera's worked on disclosure regulation before, so she probably has strong views. on this. I do. I have pretty strong views on disclosure. You know, most of my career, I've worked on disclosures. All for. Writing prospectuses and then reviewing them while working on the, in the Disclosure Review Office and Investment Management. For crypto, just like any other area, you know,
Starting point is 00:30:08 the foundational disclosure questions are consistent. So the federal securities laws approach, I think overall has been good. As Commissioner Perce was saying, what does an investor need to know to make a decision about whether an investment is appropriate for them or attractive to them. And we want to continue to provide that information for crypto-related products. And one of the things that we've seen, I think, historically, just because there hasn't been a regulatory framework around it, is this information asymmetry problem that disclosure tries to solve is especially heightened in a market where there's no requirements, right, at this point. And Commissioner's first's point is you don't need to wait for,
Starting point is 00:30:48 for regulation to have best practices in place. As somebody who's offering something, you want the investor to be able to make an informed choice, whether the government tells you to or not, because then you're going to be able to give the consumer, like meet their expectations of what they're purchasing. And so I think that's just a good practice. And we have seen good private sector solutions developing around this and teams have come in and spoken to us about that. And I think there's been some good work.
Starting point is 00:31:15 Of course, we will have guidance in this area. ultimately. The other thing about disclosure that's really exciting to me when we see the utilization of smart contracts and other technology is one of the biggest criticisms of the disclosure regime that we live in right now is that the amount of information is not digestible to the common person. Not only is it not digestible, it's not accessible, right? It's not written in a language that as a common retail investor will easily be able to appreciate. So with smart contracts, you can definitely make a better disclosure framework. And I'm really curious to see people will come in and push for that or advocate for that
Starting point is 00:31:55 and how we'll address that in our rulemaking. But layer disclosure using AI to work through all of the different disclosures, making it interactive, what opportunities are there to tailor investment products for a consumer? And I think some of the smart contract demos we've seen have really illustrated exciting stuff. So I'm really geekish about that. I love to talk to any team who's been thinking about disclosure and see what they've been building. You're very safe to nerd out on this podcast. Like we are all.
Starting point is 00:32:25 And I often joke that on your language point, I often joke that people think I'm smarter than I am because I speak multiple languages. Like I speak lawyer and I speak crypto tech. But you're right. Those languages are intimidating to the average retail consumer 100%. So I know V has a question and we're going to shift topics in a minute. But because we're at our halfway point, I want to take a minute and hear one more word from our sponsors that make this podcast possible. Bitcoin changed how money works. Citraea changes how Bitcoin scales.
Starting point is 00:32:56 Satrea uses Bitcoin as both the settlement and data availability layer. As Bitcoin's application layer, Satrea enables the first trust minimized BTC on a fully programmable platform and a native stable coin for Bitcoin, CTUSD. Citraea offers Bitcoin capital markets with lending, privacy, payments, Bitcoin yield, trading, and predictions. Citraea expands Bitcoin's utility without sacrificing its security. Citraia Mainnet is live. Get started at Citraea.xyZ slash unchained. Etherfi is giving unchained listeners 15% cash back on ride shares, groceries, and restaurants right now, which honestly is kind of wild for a card like this.
Starting point is 00:33:46 On top of that, I'm getting 3% cash back on every single transaction, using my actual crypto. No conversion fees, no nonsense. My bank never once did that. And it goes beyond just spending. You can borrow against your holdings at 4% or less, which is super useful if you don't want to sell your assets. You can also earn on all major assets, up to 8% APY, just by holding.
Starting point is 00:34:07 And moving money is just easy. No hidden transfer fees, no friction. It just works globally. If you want to check it out, go to ether. Dot fI slash Unchained to claim your offer. That's Ether.com slash Unchained. Multi-Chain Advisors is an emerging technology growth firm that has helped create over $50 billion in enterprise value
Starting point is 00:34:27 for more than 80 clients, like Pith, Moon Pay Commerce, and Wormhole. They've worked with some of the largest and most impactful companies in the space. They're the partner you want when you're navigating markets and trying to break out from the noise. They help navigate TGEs, go. go-to-market BD and Partnerships, Capital Markets Advisory, PR, Media Placements, KLA Activations, and more, driving execution from launch to scale. Their results are measurable. To learn more and start building real traction today, visit multi-chain adv.com. And we're back talking about how some of us
Starting point is 00:35:04 still like to read things on paper. So there is your elder millennial perspective from some of us. But I'm going to turn it over to B, who is going to ask our SEC visitors a couple different questions. I still read all my books like paperback early. I tried the digital iPad for a while. I was like, no thanks. The smell and feel of the book is. There's nothing like it. There's no substitute.
Starting point is 00:35:29 So shifting gears just for a second. We wanted to talk to you about the CFTC SECHRC Harmonization Initiative in the MOU that was recently. announced. It's funny because, so I work at VEDA and we were going to make a submission with recommendations around how to modernize the custody rule. We were just going to submit it to the SEC originally and then do a separate one to the CFTC at some later point. And then you guys announced the MOU. And so we went back and we like revised our letter and just decided to do like a submission jointly. And I was like, this is so much more efficient because the safeguarding objectives of both like the SEC's custody rule and the CFTC's like customer property segregation
Starting point is 00:36:17 requirements are basically identical. So I think that makes a lot of sense. But one question we had was, what happens if the two agencies disagree about something, like how to classify a token, for example? Like do you guys, have you thought about how you would resolve those sorts of disputes? I mean, I think right now we're both looking at it as a very necessary process to have in place because I think we've both seen in the past. If you don't have some sort of process where you're talking to each other routinely, you can get into a situation where one agency thinks that something is in its jurisdiction and then the product is out there and the other agency says, hey, wait a minute, I don't want that product
Starting point is 00:37:01 to be out there because I think it's in my jurisdiction. And that's really disruptive to the market. So I think the thing about these two chairman is they're both very committed to sensible approaches and they're not territorial in the sense that they don't feel they need to have everything within their jurisdiction. Back in the day, I worked with Brian Quintens, who was then as CFTC Commissioner on harmonization around security-based swaps and swaps, which are two regimes that came out of Dodd-Frank. I think it was very evident at the time. He was great to work with, but I think it was evident at the time that having a more formal mechanism in place could be helpful just to build those habits going forward. And that's where I think, you know, is there going to be a formal dispute resolution mechanism? I mean, maybe you could go, you could take your case and bring it to a neutral third party if you wanted. But I think there's there's real commitment at the top to build just habits of saying, you know, at some point,
Starting point is 00:38:03 someone is just going to have to say, okay, we'll stand down. Maybe you can have an agreement where we get some information about a product, but we don't necessarily have the primary regulatory authority for that product. So that's how I kind of see it working out. And I just don't want to be in a world where we're both taking outward facing positions that conflict because that's really confusing to people. So be- I'm so happy we're past that because I remember, you know, in the previous administration, I was chief legal officer of a spot exchange where we were listing only five assets,
Starting point is 00:38:39 but it was very difficult when the SEC was taking one position. And we also had a DCM and a DCO. So our regulator was taking a different position. So I'm heartened by the fact that we are past that. I love to see the coordination and kind of communication between the two agencies. I think that's, you know, I really want to applaud both the CFTC and the SEC for that kind of ongoing. growing cooperation. But this is the moment too for people to help us with that and bring us issues that they see that are arising where there is or has been a conflict in the past and help us to figure out how to work through those. Yeah, when I was in house, you know, I was dealing with both agencies as well and there are issues around duplicative reporting or other things that are redundancies. And so you see that as an external practitioner, but internally too, we have inefficiencies that I hope that's
Starting point is 00:39:33 this closer relationship will help solve both for cost-effective measures that we can take moving forward but then knowledge sharing right we know that in this area especially there are limited minds that have really spent a lot of time and so if we can share our intellectual um capital too that's a great thing right now we're in like an ideal environment right share sea lake has joined on new project crypto him and share atkins have a great relationships we are not always going to be in an environment where the two chairs are as closely aligned or have such a great personal relationship and professional relationship as this. And what we always want to be thinking of when we're thinking about protecting our institutions
Starting point is 00:40:15 is what does this look like in a different environment? What are other steps that we can take that the legacy of the work and the foundation we're laying for this partnership is kept? And one of those things is you can't rely just on two people, right? we're having a lot of cross-agency staff engagement as well, making sure that people at the SECC can talk to their CFTC counterparts and build those relationships because staff is going to outlast administrations in most cases and you want to make sure that on the staff level, you also have that harmonization effort and cooperation. And I think right now we're able to leverage that
Starting point is 00:40:54 opportunity. You know, unless you've worked in government or very closely with government, I don't know if you fully appreciate how hard it is to get agencies to work together. And so there's a lot of conversations about collaboration or harmonization. You know, at DeoJ, we talked to Treasury a lot and vice versa. But actually seeing it happen is a pretty wow moment. So I'm glad to see that you're thinking about it, not just at the, you know, top tiers, but also at the staff level that will definitely continue on. We'll hopefully continue on as the,
Starting point is 00:41:29 ecosystem continues to develop as well. And speaking of continuing on, like this, we want to talk for a few minutes about your legacies, but continuing on raises an important question. Now, both the CFTC and the SEC have referenced the term future proofing on a number of occasions. And this is obviously an area of extreme angst for crypto, to be honest, in that I think a lot of the GCs are considering, okay, this is fantastic, we have something to work with, but in three years, everything could change. And this is not a political or a partisan question to be clear. I think the three of us all share the opinion that this industry should not be partisan. This is about the technology. It's more just about the long-term strategic sustainability of the guidance that's
Starting point is 00:42:20 being produced. As you know, even commission level guidance can be changed by a new and different Commission. How do you think about that as you operate, kind of how do you think about executing future-proofing mechanically? I mean, one thing is to do rulemaking, which certainly sits, it's more difficult to to depart from a rule. And then legislation is the best durability. So we hope for that. But I guess, Yes, the other thing I would say, and I say this a lot, but I think it really is an important message, the more people are actually using your products and services, the harder it will be for any new administration to change.
Starting point is 00:43:08 And so this is the moment where you should be really trying to build stuff. You know, time flies, right? And I knew that if the administration changed, there was going to be a short window to get stuff done. And, you know, in retrospect, would I have like to have a full package of rules and guidance documents and things ready to go? Sure. But partly I needed to get the input from people. And that really wasn't going to come until there was a real prospect of actually putting some of this stuff in place. So we are working as fast as we can, but people on the outside need to be using this time wisely to build useful stuff, stuff that people want to keep around.
Starting point is 00:43:53 Absolutely. And honestly, since the day that the task force launched, I've been obsessed about, you know, this question because what you don't want is an environment in which what tens of millions of dollars of staff time is just flushed down the toilet because of a change in the winds, right? And there's various ways you can protect against that. And one of the ones that I'm really proud of the task force being really mindful of is this This was not just a 10th floor initiative.
Starting point is 00:44:24 This is not a CTF initiative. This is a framework that's being built by this building. And so again, when we leave, when leadership changes, if staff has been involved across every policy division, across other relevant divisions and offices in this building, and they understand the work they're doing and they're applying the same rigor and questions and processes that they would for any other asset class,
Starting point is 00:44:49 I think it's important not to get hung up in the fact that this is crypto. This is just another area, you know, certain parts of it that the SEC oversees. And as our job as public servants is to create a framework that industries can rely on, that investors can then invest in with the confidence of knowing that there's regulatory protections. So it is important to note that this is not really, it shouldn't be and isn't political at all because this is something that is being driven by the mission of this building and then the staff of this building who are here, you know, hopefully five, 10, 15, 20 years down the road.
Starting point is 00:45:26 Yeah, and for people who don't have SEC insider knowledge, the 10th floor is where the commissioners sit. So we often just refer to it with that shorthand. But I think, you know, something Samira said really does deserve underscoring, which is that we have a task force, which is wonderful and has great people on it, but it's relatively small. And, And the bulk of the work that's being done is being done by staff throughout the SEC, and they have really jumped in with the intellectual curiosity and, you know, knowledge and expertise that has been sitting there all the time untapped. And so it's really fun to see them and to work with them on these things.
Starting point is 00:46:15 And we have lively debates in the building, too, which is great, as we should, because we really want to get to the right place. I love that. I love a good intellectual debate. Spicy and then you walk away as friends. So I think I would like to shift to your personal legacies, both of you. I do just want to call out Commissioner Perce. If you ever decide to run for office, I will leave my job and run your campaign. I'm just putting it out there because we know. No politics. I know there's zero chance of that, but I just want to put it out there because we need more people like you, and I was really inspired by comments you made at an Illinois blockchain association function about the need to engage in debate and part as friends. I think that's so
Starting point is 00:47:02 important. I think occasionally in certain areas, we've lost the thread there. I hope to see more of it. I hope to see that with whatever you do next. But I will turn over to V to ask some specific questions about your legacy. Yeah. Yeah. So I know we're wrapping up here. But I think it was like a year and a half ago I was interviewing you, Commissioner Perce, and I asked you what you thought your legacy would be or what you wanted it to be, and you demurred. So I'm going to ask it in a slightly different way this time. And for you too, Samira, what do you think you're going to walk away the proudest of during your time at the SEC? I mean, honestly, it is the people that I've that I've hired to help me do stuff,
Starting point is 00:47:48 of whom Sumera is one of them. So I mean, I would say I just, you know, these are people who have poured themselves into, whether it's crypto or other things that I've worked on here. And I've just been blown away by how talented they are. So that is the thing I'm certainly proudest of. Well, Sumera, that raises another question.
Starting point is 00:48:11 And by the way, Jesse's quiet because she's a weak internet. So we're missing the Jesse Brooks. I can't hear you. The Jesse Brooks rant of the day, we're going to miss that for this podcast episode. But, you know, Samira, for your own work at the commission, what does the task force look like after Commissioner Perce leaves? Like, how are you feeling about this transition? Before we get into that, I need to take a moment to say, Commissioner Perth will never speak about her legacy because she's one of the most humble and modest people you will ever meet. She'll be mad at me for now going into this.
Starting point is 00:48:45 but it has been the honor of my life to serve for her. Her legacy is she has, I don't want to cry, but you have set the standard for what a public servant should be. I have never met a person with more integrity, with more intellect and more humility in the work that they do. The task force could not exist without her leadership and the confidence people had in her. That is why they responded to her request for information.
Starting point is 00:49:12 That is why they engaged with this building because she has been a beacon of light for so many of us. She has modeled courage and integrity. And I will benefit from that for any step I take moving forward. I'm so grateful for that and for your friendship. Well, that's very kind of you to say. But as you said, there's no rebuttal for this. You must accept humbly.
Starting point is 00:49:38 No opportunity to comment. Commissioner first. We're out of time. We're all just crying over here. So I am. Carrie eyed, and the moment has not even come, but the task force has a strong, strong foundation in the work of the staff in this building
Starting point is 00:49:54 that will continue on no matter what it looks like and whoever fills that unfillable seat over there. So I'm confident that the work is going to go on and we will complete many of them for projects that we speak in here. I love to hear it. And we are going to wrap in a minute with our crypto good news of the week, which we always like to feature. But before we do that, I wanted to give both Sumera and Commissioner Person opportunity, anything else you'd like to convey to our listeners to kind of crypto market participants at this point in time.
Starting point is 00:50:31 I mean, one, I'm a big fan of the show. So I enjoy listening to you guys. But second, I think it's the point that Sumera has been making, which is that we really want to hear. from people at each stage of the process. And so please do continue to engage with us. That's the only way that we can get to a good place. There are some controversial issues coming, right? We can see that in the written input that we're getting.
Starting point is 00:50:57 You've got strong views on all different sides. And so we may not make everyone happy, but we are trying to get to the right place. And it's iterative. So if you don't like what we've done, if you think we need to take a step further, come talk to us, explain to us the legal basis for what you're doing and the practical and commercial realities of why what we've done is too limited. Please, you know, help us to continue to shape the next step. And my message is just something that, you know, I had to say to myself
Starting point is 00:51:32 a lot over the last seven years, but for everyone who's building in this country, like, never give up. There will be doors and then there will be walls, and that will always be the case. You have to keep going. You have to believe in what you're making. That's what makes America the best place in the world. We have people who are not afraid to build and create and innovate and dream of a world that is even better than the one we live in. And that happens because of builders. So keep going. Samira, I think you need to run for office. I know. We're not allowed to talk about politics. I would never. That was very inspiring, but we're not allowed to talk about politics. It's an ugly bit. You know, I'm just going to be out there. No way. Yeah.
Starting point is 00:52:16 Well, I can't tell you how much we appreciate both of your time, your expertise. You're both incredibly inspirational to not just women, frankly, people, but particularly women. It's such an honor to continue to highlight, you know, prominent, responsible women with integrity who have an impact on this space. So I'll just take one minute to highlight our crypto good news of the week and then we'll say goodbye to our guests. But speaking of women, we just wanted to call out the Eve Wealth Summit, which is happening in a couple weeks. All three of your co-hosts will be speaking there. And the reason why this summit is awesome, and I think we provided a picture to put on the screen. But when you look at the speakers of the EVE Wealth Summit, the most important takeaway of this summit is it looks like your average crypto conference.
Starting point is 00:53:10 but the gender is reversed. Like there are a few men well qualified, I guess, like, you know, Chris John Carlo and a few others speaking at the summit. But this summit, it's the second annual. It's, you know, designed to support a powerful community of women and allies driving diversity in digital assets. So we just wanted to call out, you know, kudos to Eve wealth and this summit for really highlighting the high caliber of women who can and, you know, are happy to speak.
Starting point is 00:53:40 with authority and insight on digital assets. So with that, I will say goodbye to Samara, Commissioner Perce. Thank you so much for joining us. Thank you to our listeners. And we will see you next week on Dex in the City. Thanks for having us. Thank you.

There aren't comments yet for this episode. Click on any sentence in the transcript to leave a comment.