Jake Chervinsky
@jchervinsky
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Lawyer, but not yours. CLO @variantfund. Board @fund_defi + @blockchainassn. Posts are not legal or financial advice.
Washington, DC šŗšø
Joined June 2009
1/ Market structure bill, December update The Senate is working very hard to get this done, but the closer they get, the more complex it becomes. I'm not betting on a markup this month. Three issues are holding up the bill: stablecoin yield, conflicts of interest, and DeFi š§µ
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Thank you @SenBooker for committing to protect software developers! š The only way to achieve this goal for good is to clarify that "money transmission" requires custody and control of user assets under Section 1960. This should be a dealbreaker for the market structure bill.
An especially memorable line from @SenBooker, speaking with @Sen_Alsobrooks this afternoon: "We can't criminalize people who write code, for crying out loud." Necessary sentiment as negotiations re: developer protections continue and as market structure moves closer to a mark
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Sleigh the season with the most personal gift around. Get them a Cameo video!
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Thrilled to announce our lead investment in @pyefinance, a new yield and stake trading protocol on Solana. Solana has become one of the most active ecosystems in crypto, yet its staking layer still resembles the earliest days of the network. Tens of billions in SOL sit in native
pye.fi
Building Solana's yield curve. Pye is a marketplace for buying and selling time-locked stake accounts.
Weāve raised a $5M seed round led by @variantfund and @cbventures to build Solanaās first market for term-based staking. Staking is evolving beyond set-and-forget delegation. Validators and stakers need clear terms, predictable rewards, and real price discovery.
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In case this somehow hasnāt crossed your timeline. A good read even if you donāt reach the same conclusion, as I do not. But surviving in crypto means keeping your eyes open and knowing why itās worth it, despite the froth. For me, Iāll leave this industry when Iām dead.
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Iāve worked the last eight years in crypto and I wouldnāt do a single day of it differently.
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Keep scrolling, NOTHING IMPORTANT HERE. Just Forbes lining up a so-called āmicrocapā NextNRG ($NXXT) next to Amazon ( $AMZN) and Kroger ( $KR), explaining how itās already in their trucking and fueling lanes. According to Forbes, NextNRG (NXXT) already provides fueling services
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The best countersignal in crypto history: @nytimes. I'll never forgive or forget the puff pieces they wrote about SBF weeks after his fraud was obvious beyond the shadow of a doubt. Today, a hit piece on stablecoins, the most obvious way crypto improves finance. Good sign! š
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Incumbents love to try regulatory capture, when they should just embrace new opportunities to grow
Read between the lines of Citadel's "everyone in crypto is an intermediary" letter to the SEC and you see an attempt to establish standing for a lawsuit once the SEC adopts its long-promised innovation exemption. TradFi's about to run the crypto policy playbook circa 2023. Glhf!
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Lindsay is among the best crypto policy advocates in the world. @BlockchainAssn and all its members are very lucky to have her on the team! š„
Iām pleased to share that Iāve joined @BlockchainAssn as Chief Policy Officer. This comes at a pivotal moment as policymakers consider foundational questions for the future of digital assets.
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Iām pleased to share that Iāve joined @BlockchainAssn as Chief Policy Officer. This comes at a pivotal moment as policymakers consider foundational questions for the future of digital assets.
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Mini ATG Gym Design + Knee & Lower Back Recipes That Have Been Wonderful For My Clients (Heads up: long article format) I measured off 200 square feet (10ā x 20ā), including ample walking space, and polished off my own mini ATG. In fact, only 100 square feet of it is really
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Read between the lines of Citadel's "everyone in crypto is an intermediary" letter to the SEC and you see an attempt to establish standing for a lawsuit once the SEC adopts its long-promised innovation exemption. TradFi's about to run the crypto policy playbook circa 2023. Glhf!
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This is consistent with what Iāve heard. Amongst the issues: big emphasis on Trump family conflicts and DeFi/national security (Iāve heard less on stablecoin interest but know itās lingering.) My responses: 1. Conflicts of interest are everywhere in government. Instead of
1/ Market structure bill, December update The Senate is working very hard to get this done, but the closer they get, the more complex it becomes. I'm not betting on a markup this month. Three issues are holding up the bill: stablecoin yield, conflicts of interest, and DeFi š§µ
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Big banks when stablecoins want to pass on yield to consumers vs keep it for themselves
5/ This brings us to the three big remaining disputes. First, stablecoin yield. In the GENIUS Act, the banks negotiated a "prohibition on interest" saying stablecoin issuers can't pay holders "any form of interest or yield." Okay, fine. No yield paid directly to holders.
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13/ Given the complexity of these issues and the short timeline before the holiday break, donāt be surprised if weāre still working on market structure in January. Thereās nothing more important than getting this right. We wonāt have a second chance. Stay tuned. [end]
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Okay, okay ā it was us. And we're just getting started. Want to see our next project? FOLLOW @citizens_sanity now and help us keep exposing the woke madness.
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12/ There is no market structure bill without developer protections, because there is no crypto without developer protections. Hopefully the whole industry will hold this line, even and especially centralized crypto companies dying to do a bill. On this, no room for compromise.
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11/ The DeFi issue is most important because the stakes are so high. Remember when OFAC made Tornado Cash illegal? When DOJ decided to put its developers in prison? When the SEC said DEX developers had to centralize their protocols to "come in and register?" Never again.
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10/ Sadly but not surprisingly, TradFi disagrees! Some TradFi incumbents have been pushing Congress to save their regulatory moat by treating pretty much everyone in crypto as an intermediary: developers, validators, you name it. For example, @Citadel: https://t.co/BEJ5UdQXoo
First Ken Griffin screwed over Constitution DAO Now he's coming for DeFi, asking the SEC to treat software developers of decentralized protocols like centralized intermediaries Bet Citadel has been lobbying behind closed doors on this for years Okay thats all pretty bad, but
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9/ Third, and in my view most important, DeFi. Letās be clear: market structure legislation is about centralized platforms that exercise custody and control over user funds and transactions. The only thing the bill should do with DeFi is protect it: https://t.co/Vipsfmmzst
Today, a coalition of 100+ signatories join DEF in sending a letter to Congress. Software developer protections are a non-negotiable in digital asset market structure legislation. This critical issue unites us ā crypto and tech builders, investors, and advocates.
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8/ Second, conflicts of interest. Some Democrats have said they wonāt vote for market structure unless the bill has language that restricts the Presidentās family from doing business in crypto. The politics are simple and obvious, but a solution to move the bill forward is not.
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7/ Set aside the silliness of the banks asking to amend a law they just supported, and to put stablecoin content in a bill about market structure. Nonetheless, the banks are influential and they might be able to get a few senators to agree. That could be enough to kill the bill.
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6/ But the text of the prohibition is narrow: it says nothing about non-yield rewards and nothing about yield paid by third parties. Banks hate this! They call this obvious plain reading of the text a "loophole" and want it expanded in market structure. https://t.co/AqXcRQ33LV
The banks demanded the exclusion for yield-bearing stablecoins in the GENIUS Act. Now they're upset that the language they asked for doesn't screw over stablecoin holders hard enough. Sorry you guys did a bad job negotiating your regulatory moat. Try lobbying better next time!
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5/ This brings us to the three big remaining disputes. First, stablecoin yield. In the GENIUS Act, the banks negotiated a "prohibition on interest" saying stablecoin issuers can't pay holders "any form of interest or yield." Okay, fine. No yield paid directly to holders.
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