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Raye Hadi
@rhadiARK
Onchain things @ARKInvest | Disclosure:
283 Following    2.5K Followers
Crypto just had a milestone week in terms of regulation. While Clarity didn't pass, the SEC and CFTC are acting within their power to ensure this industry has a clear framework to accelerate in the US. Full coverage below:
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Top 10 takeaways from SEC innovation exemption: 1. The main thing the IE does is define the requirements for a venue to host tokenized equity trading onchain. Refers to these venues as TSVs (tokenized securities venues) and exempts them from the "exchange" definition so they avoid being classified as a 'trading center, ATS, or market center'. 2. The second biggest thing the IE does is define which types of tokenized equities are allowed. The IE only covers native issuer tokenized equities or third party custodied ones that carry full ownership through (dividends + full voting rights). Not synthetics. 3. Neither Coinbase nor Robinhood's tokenized equities meet the standard today, but Coinbase is much closer. Robinhood is going to need to restructure the entire ownership wrapper model, Coinbase mainly needs to pass through voting. 4. Does not apply to the full defi stack. It prohibits financing and hypothecation, so lending/leverage/looping aren't allowed in the current framework. 5. Requires TSV smart contracts to live on "public, permissionless blockchains". Base and Robinhood Chain are likely eligible (the single sequencer raises some questions, but I believe its dependent on open read/write access). Discretion seems to be left to SEC staff, arguably bullish Ethereum and Solana. 6. Exempts TSVs from RegNMS, huge. RegNMS would've required defi venues to adhere to requirements they mechanically cannot support (best bid, trade through,..). This exemption is what allows tokenized equity trading to exist onchain. 7. Exempts LPs from dealer registration. LPs are protected as "covered firms" and therefore can market make and seed pools without needing to register. 8. TSVs must be US users, permission participants, coordinate halts with the SEC and consent to exams, and can only host secondary trading. 9. Per name tiered volume caps. The onchain volume of stocks in tier 1 can trade at or below 0.25% of prior month offchain average daily volume (ADV), stocks in tier 2 at 2.5% offchain ADV. 10. This exemption sunsets after 5yrs; not meant to be permanent. Designed to be supplanted by more durable SEC rulemaking/legislation.
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Been starting to see a trend form since the Coldcard news broke last Thursday
literally thinking about taking all of my bitcoins on exchange for now what a grim timeline this is
I think Lighter has a clearer path into the US than Hyperliquid. To reach US retail an onchain perps venue has to either: A) register to become a CFTC-licensed entity B) Qualify for some DeFi exemption Lighter is obv pursuing A, as it has a US C-corp that issues the token and operates the protocol, an ongoing CFTC license application, and a founder on the CFTC Innovation Advisory Committee. This gives it an accountable legal entity on top of a relationship with the CFTC. The chain runs on a single sequencer so B is not really an option. Hyperliquid is kind of stuck here. It doesn't have an accountable US legal entity to license to so hard to do A and it likely isn't decentralized enough today for B (closed source, historically concentrated stake). Hyperliquid can neither cleanly register nor is it likely exempt. While the HPC's ability to make progress on B is a factor here i don't want to discount, I feel like the registration route materializes first, especially with the probable chance we don't get Clarity. Additionally, despite the personal connection between the two Vlads, I'd guess a real part of Robinhood's selection criteria was Lighter's ability to compliantly offer to US retail down the line. Especially since Robinhood is a regulated US public company whose whole business is US retail.
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@ARKInvest is proud to join the Transparency Alliance, backing the Token Transparency Framework (TTF). For too long, investors have had to piece together diligence on tokens from disparate, often incomplete sources. Even as AI has improved this process, critical details are still missed or are not publicly available. The TTF solves this by giving investors a standardized framework for disclosure, straight from the teams themselves. We believe tokens can't mature without this level of transparency, and we're glad to help make it the industry benchmark. Thank you to @Blockworks for leading the charge.
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Enjoyed hopping on the pod with @robbieklages. We talked ETH, ZCASH, Perps, and Clarity First one in the books. Onward and upward
Stablecoins, Perps & Tokenization: @ARKInvest's Framework For The Next Bull Run with @rhadiARK 00:00 Intro 01:45 Bull Market 2021 Changed Everything 04:04 JP Morgan BlackRock Goldman On Tokenization 07:00 Stablecoins Most Interesting Megatrend 09:30 Perps Are Underrated Secular Trend 12:17 Ethereum Foundation Subtraction Problem 15:00 Token Value Accrual Framework 18:16 Zcash Private Bitcoin Or Meme 20:59 Near Intense $23 Billion Volume 24:00 Stablecoin Yield Debate Settled 27:11 Pre IPO Perps Real Price Discovery 30:00 Chinese Memory Maker On Hyper Liquid 34:15 Lighter Incentives And Growth Explained 37:44 Senator Lummis Will It Over The Line
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Monad TVL up ~60% since the start of June. Mainly driven by the Aave V3 deployment, Pendle, and K3 Capital vaults. Still relatively small at ~$630m tho I continue to be skeptical of general purpose L1s outside Ethereum and Solana but like what Keone and team have built at Monad. Will continue to follow and update priors as needed
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Not every stablecoin is built the same. DAI cannot be frozen or upgraded. USDS can. They share the same backing. That is by design. While they share the same backing and overlap on many qualities, their design priorities diverge. DAI leans on sovereignty and transparency. USDS optimizes for accessibility and yield. @rhadiARK unpacks the tradeoffs across five criteria: transparency, durability, sovereignty, accessibility, and incentives in part 3 of ARK’s Guide To Stablecoins. Read the full research blog.
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Every year we get our consortium style initiative around a stablecoin, we have seen this with Diem, Global dollar and now Open USD. While the set of players here is obviously potent, I remain highly skeptical any of these initiatives can hit scale. A few thoughts on OpenUSD: 1. Liquidity and the cold-start problem. USDC and USDT have massive network effects across exchanges, payment processors, and brokers. This is always repeated but it's true, there are no BTC/sofiUSD pairs to trade on any of these exchanges or markets. These are not stableocin market makers and participants are willing to hold in size, as you can’t really use them anywhere. The fair counter is that crypto markets will be far smaller than remittances or equities/bonds. Probably true, I suspect in the medium term, but those markets are still converging on the same stablecoins. Hyperliquid just struck a massive deal with USDC/Coinbase. Every tokenization initiative so far is built around the incumbents too. 2. A consortium of 500 rivals has no precedent for working. The pace of decision-making across 500 competitors is going to be glacial. Not everyone gets a board seat at Open Standard I imagine, so what happens when decisions cut against some of the players? Circle and Tether ship whatever they want, whenever they want, with zero commitment to anyone. 3. Regulatory and antitrust risk at scale. Circle and Tether are willing to absorb enormous pressure, they have being doing so for years. They hold hundreds of licenses they can use to arbitrage markets, Yes GENIUS act gave a lot of breathing room and clarity, but oversees, this is not the same story. The moment this gets hard under regulatory pressure, I think a lot of these partners just walk away. And a bloc of the largest banks and card networks jointly issuing money is an obvious antitrust target. 4. The "socialist" economics starve the issuer. Passing reserve revenue back to partners sounds great in practice, but what does Open Standard actually operate on? Little to no retained capital. People forget Circle doesn't just have marketplace/exchange partnerships; it funds a whole web of rebates across on/off ramps, stablecoin settlement, OTC desks, and more, with each deal being somewhat bespoke depending not he partner. Who funds that at Open Standard? Who decides which deals, on what terms, especially when the counterparty is a rival of an existing member? Circle GAAP Opex for 2025 were 900M USD, if you strip out one time cost and IPO related cost, its adjusted OPEX is closer to 500M annually. Let’s say open Standard gets 25 bips, which is what other consortium did, At 10B of supply, open standard is making 25M a year… You don’t fund much with that…. You need to become huge very quickly. 5. The announcement is basically a giant LOI. Read the quotes: BlackRock calls it "a constructive step," BNY "looks forward to exploring ways to support," others say it's "interesting." Meanwhile the partners are backing rivals: Stripe owns Bridge and has its own stack, Coinbase is wedded to USDC, banks are building their own deposit tokens, and the card networks support every token out there. They'll hedge across all of them. Distribution only matters if it's exclusive — and it clearly won't be. 6. The "mint/redeem fees are a problem" claim is wrong. In practice every large institution minting and redeeming through Circle and Tether already gets big rebates. The real cost of moving money is FX, not mint/redeem and there's no moat there, because anyone can just match free mint/redeem. All in all: one to monitor, but I'm deeply skeptical that an organization that looks like a DAO of 500 companies can move fast enough to matter long term. Who decides go-to-market? Capital allocation? Anything? Ultimately this reminds me of the DAO experiment. The pitch was identical: no single owner, "neutral" governance, aligned incentives, decisions made collectively for the good of the network. In practice DAOs almost universally failed at the thing that actually matters: shipping. Governance turned into endless forum debates and token-weighted voting where nothing decisive got done, capital sat idle because no one could agree how to deploy it, and the projects that won were the ones with a clear owner willing to move fast and take risk. "Owned by everyone" almost always means accountable to no one. Open Standard is a DAO of competitors that are not really committed to anything, and I'd bet on the two operators who can ship unilaterally over a committee that has to ask 500 rivals for permission.
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Forward to community
No one in crypto wants to see this technology abused to facilitate harmful activity. We understand that KYC/AML is a proven preventative measure to accomplish that. Our concern is that it must be applied at the layer that makes sense. Sec 604 in CLARITY aims to lay the groundwork for this. What Sec 604 says is that a non-custodial software developer cannot be treated as a money transmitter, meaning they are not required to apply Anti Money Laundering (AML) mandates such as Know Your Customer (KYC) in the services (Frontends, UIs) they provide. For anyone touching law enforcement or the catholic orgs that oppose this section, I'd like to provide a list of reasons why I believe Sec 604 makes sense: 1. Non-Custodial Services Don't Gather Customer Data- These services work as routers that simply provide a nice interface for users to interact with decentralized financial apps. Treating the developers as money transmitters would require them to report data their services are not built to collect. 2. Increased liability- Forcing these services to collect data creates centralized targets developers now must manage. This brings on more liability for a service that was supposed to act as an interface for accessing defi, not an intermediary. 3. Asymmetric Compliance- Immutable smart contracts are accessible and exist publicly available on the blockchain regardless. And with the rise of AI and open source models even non-technical bad actors can interact with them without using a gated interface (Frontends/UIs). Requiring KYC/AML will not force bad actors into a supervised gateway, it only forces regular users into more supervision. 4. Offshore Migration- US facing providers will either have to geo-block (pushing users to unaccountable foreign services and VPNs) or absorb regulatory liability and overhead. Both push users and developers outside of the US and do the exact opposite of bringing this technology onshore in a safe and reasonable manner. 5. Everything on the Blockchain is Public- For most public blockchains, every transaction and wallet balance is completely transparent and trackable giving law enforcement durable, permanent visibility. There are already top onchain forensics teams like Chainalysis and Elliptic that operate here. Even as blockchains seek to build native privacy eventually, at crypto's current state implementing KYC at this layer will have little to marginal benefits in what can be deciphered from blockchains. The letter states that law enforcement's concerns aren't with developers who publish code but with exemptions broad enough to also shield mixers and custodial money movers. That's fair, but it's an argument about line drawing, not about the viability of 604 and others. If there is language change, as long as non-custodial, non-controlling developers and their services are exempt and control is defined so that any custodial service that actually moves or obfuscates crypto is subject to AML/KYC this makes sense. In my opinion, a more effective strategy is to regulate the chokepoints, not the interfaces. AML/KYC makes sense at custodial on/off ramps because they already collect user information and manage significant regulatory overhead/liability. A change of language that pushes developers towards classification as a money transmitter is directly at odds with safely bringing this technology onshore as it reflects a mismatch between how these services work and what the money transmitter framework requires. Additionally, it encourages offshore migration while only providing marginal benefits to law enforcement's existing capabilities. I encourage all involved parties to consider these points. We are on the same page when it comes to safety, but it is important to ensure that safety is implemented thoughtfully and without creating a regulatory environment that is unworkable with the growth of this technology.
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