Ep 140: A 101 briefing on Crypto Regulation in the US with Amanda Tuminelli, Chief Legal Officer at DeFi Education Fund

[00:01] Welcome to the Feelings Check-In, a feelings first look at the news of the week. Takes no one asked for on topics everyone's talking about. I'm Natasha Hoskins. I'm Dina Burke. And this is Boys Club. Wait, is it just Boys Club? It's just Boys Club. The Boys Club podcast? No. [00:18] No. [00:19] Just boy stuff. [00:20] Bonsoir. Bonjour. How's it going over there? Oh, it's going good. I'm in Perry for... [00:29] the listener who doesn't listen to our other podcast too online. How's that time zone treating you? Oh man. I go to bed really late. I go to bed at like, [00:37] 1:30 or 2:00 and then I wake up at like 10. [00:40] 30. [00:41] Good thing you don't have an aurora ring. [00:44] Well, I'm getting a lot of sleep. [00:46] That's like eight hours. [00:47] Okay. [00:48] Because I'm waking up at like 10. [00:49] ish 10 30 okay because i work until i'm working like mostly east coast hours so you know i'm up late and then once i'm done i want to unwind and just give myself insane anxiety by looking at the internet for an hour and a half before that twitter post that's like before i go to bed i like to look at 300 to 400 posts [01:09] That's to unwind. But I found an incredible, incredible mega reformer Pilates class. [01:18] So that was a huge unlock for me. Ella, I'm sorry. [01:21] at Snake and Twist in the 9th R. Undiesmont. [01:25] is [01:26] A exceptional instructor and an incredibly beautiful woman. So beautiful that I didn't want to let her down. You know when you're working out and you're like, I can't let this one down. I have to keep up. So I've really been enjoying that. Yeah, that's the update. But more to come. More to come. It's been pretty wholesome. Man, the crossover of Pilates and crypto policy stuff.

[01:49] is maybe small, but if there is a crossover, it is going to be people who are listening to this podcast. Wait, what's the policy of it all? Well, that's the podcast episode that we have today. [02:04] I'm saying the folks that are interested in a reformer class and also interested in policy conversation, I think maybe are the ones... It's 12 people. 12 people and they all listen to this [02:19] I hope you feel a sense of belonging here. [02:24] Yeah. So on today's show, we have Amanda Tuminelli, who works at something called the DeFi Education Fund. She basically, her and her team go to Washington and they do the very hard work of educating policymakers on crypto. And honestly, God's work. Seriously, seriously, God's work. And they've done a lot of really incredible work. [02:49] regulation in the US that I have [02:51] had a really hard time keeping up with. She does a really great job of doing like a state of the union. And a lot of it's really positive. And I think it's, it's, it's, [02:59] credit where credit is due like [03:01] They have done a lot of groundwork to get us here. Amazing. Of course, there's a lot of work to do still yet to come. The work never ends. The work never ends. So anyway, if you've been wondering, if you've been seeing the headlines and seeing all these like... [03:16] amicus brief someone suing someone else terraform labs who knows what's going on there's all this regulatory stuff that's always coming into my uh media diet across your desk across my desk and she does a great job of sort of giving a 101 like state of the union on it so

[03:35] that's what you have coming up on today's pod. Enjoy. [03:39] Hey, Natasha. So a question we get asked a lot is, what do you look for in a crypto platform? So let's talk about it. Well, Dina, I look for a secure, no fuss platform that I can dive into right away. That's why I love today's sponsor, Kraken. If you're waiting for the right time to get into crypto, Kraken makes it super easy and intuitive to get started. Plus, if you get stuck, they have an award-winning client support team that's available 24-7, along with a bunch of educational guides, articles, and videos to help you along the way. If you're ready to check out [04:09] to kraken.com backslash boys club and see what crypto can be not investment advice. Crypto trading involves risk of loss. Cryptocurrency services are provided to us and us territory customers by payward ventures, incorporated PVI DBA kraken view PVI's disclosure at kraken.com backslash legal backslash disclosures. [04:29] On today's podcast, we have a very special guest, Amanda Tuminelli, the Chief Legal Officer at DeFi Education Fund, which does policy and advocacy work to help DeFi flourish. Amanda, welcome to the show. [04:44] Thank you for having me. Really excited to have a conversation to help navigate these murky waters of policy and regulatory stuff that's happening in the US. Before we get into it, can you tell us a little bit about what the DeFi Education Fund is? [05:00] is? Sure, absolutely. So the DeFi Education Fund is a nonpartisan policy organization. We advocate for DeFi users, developers, projects who are trying to figure out how to make sense of everything that's going on. And we are a C4, so we don't have members, but we represent the industry as a whole. And we more recently have started to get involved in impact litigation, meaning appealing to the

[05:30] for Congress to catch up and give us some clarity in the law. [05:34] Okay, well I'm hoping to get some of that clarity myself here today because there's been a lot that's happened over the past couple months. [05:41] on the policy side and we're going to be focusing this conversation on the US for folks and even for myself as someone who tries her best to try and keep up and cover this industry and I do podcasts and newsletters like I'm, I'm totally overwhelmed and at this point lost in the sauce in terms of what's going on and what the latest is. So really excited to have this conversation with you. Before we get into that though, is your work? Are you like in the DC scene go into the [06:07] happy hours and meeting with legislators? Like what's that? Or do you do mostly remotely? Just out of curiosity. I'm a little bit. I'm, I'm, I'm, I'm hesitant to say that I'm in the scene because like my CEO would laugh to hear me say that because he is in the scene. Okay. Okay. Um, but I am dabbling in the scene. I will sometimes go meet with members of Congress or committee members to talk about proposed legislation and what that has to do with DeFi. And if they're [06:37] in the background. Okay. Okay, cool. [06:41] All right, let's jump in. So State of the Union want to start with kind of a feelings check in on the overall vibe for crypto regulation in the US right now. Where are we at? [06:51] I think vibes are good. I think vibes are maybe the best they've been in a really long time. I went on my first long vacation from May 13th to the 25th. And I always expect to go away and hear some terrible new thing has happened in crypto, but the exact opposite happened. And like two really positive things happened while I was gone. So I came back to a much better policy landscape than I left the US for. So it was just like a fun change in how it normally goes in

[07:21] were those big moments that happened in the past two weeks and really just the past couple months that have, yeah, resulted in this feeling of, [07:28] things maybe being positive, things picking up speed. [07:30] Yeah, so I think one major thing we should mention at the top is FIT21, the Financial Innovation and Technology for the 21st Century Act. It's a mouthful. FIT21 is easier. FIT21 passed the House with overwhelming bipartisan support. That is huge. You know, crypto has really been waiting for Democrats to get in the action. And I think this was a strong showing. [08:00] FIT 21. And I think that the will get we can get into some of the details. But I think the takeaway here is two thirds of the house voting for a market structure bill means two thirds of the house is not [08:14] happy with the status quo. It is very much a rebuttal of the refrain that you hear Chair Gensler saying, which is that the law is clear and these 100-year-old statutes apply to crypto. I would say two-thirds of the House disagrees with that and says, no, we need new law. And what is in the bill is really important for crypto. It's a market structure bill. So it answers questions about regulatory gaps that we have all been shining a light on for a long time. So if it [08:44] it can and will change as it continues through congress but in its current form it tells you how to classify a digital asset whether it's a security or a commodity and how you should do that analysis it defines

[08:58] payment stable coins. It has explicit differentiation between DeFi and CeFi, which, of course, we're very interested in seeing and happy to see. There's a test for decentralization. And it also, importantly, exempts certain decentralized finance activities like running a node, writing software, creating a liquidity pool. Those are exempted from regulation. So that's really positive. And there's also a registration process for intermediaries. There's [09:28] provision on custody. So there is a, it is expansive. It is comprehensive. There are still some gaps. That's not a perfect bill by any means, but it does go much farther than what we have right now toward telling people. [09:41] how to operate in crypto. Okay, that sounds very promising. That sounds great for the crypto industry. There was a moment a couple weeks ago where folks seemed to be elated at a similar bipartisan support of, I think it was SAB 121. I believe Congress passed this [10:02] I'm now going to butcher exactly what happened. But there was some sort of elation on the timeline where people were like, oh, this thing that seems fairly positive for crypto is getting some bipartisan support. And then once it reached Biden's office, he. [10:15] A rejected... [10:16] his support of it. So, and that seemed to sort of [10:20] be a wet blanket on things. Do you expect something similar to happen to Fit21? Do you feel more positive about it?

[10:29] staying intact, how is that going to sort of shake out in your view? [10:32] Yeah, so SAAP 121 was a roller coaster for exactly the reason that you just said. We had bipartisan Congress support for repealing SAAP 121. So what SAAP 121 did, just to take a quick step back, was the SEC put out guidance to the banking industry, TradFi institutions about how to custody crypto. But in reality, it would have served as a ban on banks custody and crypto. It was unworkable. OK, so the SEC puts out SAAP 121. [11:01] Congress realizes this is bad for everyone. It's not just bad for crypto. It's also bad for TradFi. They vote to repeal it, so to get rid of it. And Biden vetoes it. And I will say the major difference between SAAP-121 and FIT-21 is that before SAAP-121 went to Congress, Biden said he would veto it. So he kind of backed himself into this statement of if Congress votes to repeal it, [11:31] and support the SEC's original formulation of this guidance. He did not make that statement on FIT 21. So he did not say, "I'm going to veto FIT 21 if it passes." And FIT 21 does have a ways to go. It now has to go -- it passed the House, so it still has to go to the Senate. [11:47] I am guessing, but I don't expect Biden to veto it if it passes the Senate as well, although I do think that's like a next year thing. So the election will... [11:57] maybe change what goes on there. Okay. And it also from hearing you talk about what is in

[12:02] Fit 21, it also feels [12:05] more broad and far reaching. So [12:09] Perhaps there was a setback on SAB-121, but that FIT-21 feels much more impactful. I do think that the takeaway here is like we are seeing bipartisan support throughout all of Congress, right? Like the fact that SAB-121 was actually repealed by Congress means we now have a pathway. There are Democrats who are willing to vote in favor of pro-crypto policies. We see that now on both of those two bills. And I think Biden's going to do what Biden's going to do. [12:39] president will have to make policy decisions. But I think seeing that in Congress, that makes me hopeful. That makes me think that [12:47] there will be progress in the next year or so in seeing like more pro crypto focused legislation go somewhere. OK, so we have FIT21. Thank you. Now I feel briefed on that. [13:01] Then there were the ETH [13:02] ETF approvals. [13:05] Exciting. [13:06] Exciting. Yeah, I think we... [13:08] It is definitely positive. I think we don't yet know what this means. Like, I think we're waiting to see, does this signal a C-shift by the SEC or is this a one-off? I mean, so there, now we're not talking about Congress, we're just talking about the SEC. They approved the initial applications for spot ether ETPs from BlackRock, Fidelity, and a bunch of others. And necessarily in that,

[13:38] that ether is a commodity and not a security. So the question has been answered by the SEC in allowing this process to go forward. That's positive, right? That's undeniably positive. But I think it will be years before we understand the full implications of this. Like, does this mean that they're going to stop their regulation by enforcement pattern? Are they going to stop suing people in the industry? Is ether [14:01] now not going to be the subject of any litigation or enforcement actions by the sec we'll see i would love to think that it means that big of a signal shift right that they're going to stop enforcing in the way that they have been but i'm not i'm less hopeful about the sec than i am about this congressional action okay can i ask probably what's a very down question if and when there's an administration change [14:25] Does Gary Gensler's position change as well? [14:28] Is he tied to the current president? [14:30] Yes, he's tied to the current president. I mean, it's not like automatic, like the next president will have to change the chair. But I think that's likely to happen if there is an administration shift. But even if Biden continues to be wins the wins reelection, he can still make the decision to switch out the chair. And Gensler also could resign. So it is possible that we will not be [15:00] hearing from you, big takeaway is that there's [15:03] then [15:04] a shift in how... [15:08] politicians bipartisan support for crypto is happening now. What

[15:14] do you think has caused that? [15:16] I mean, the industry has been doing a very good job of educating. You guys have been working really hard. Like not to just completely take credit. Take credit for it. Take credit for it. I think the whole industry deserves credit for really trying to engage productively with members of Congress. I'm not going to say everybody is engaging productively. I mean, crypto Twitter still exists. [15:46] with Congress and what they're saying and making it clear that there are millions of Americans who own and want to own cryptocurrency. [15:55] There are developers, there are people here who are building and innovating, and these are voters. These are people who you should care about, right? It took a long time, but eventually, I think people are realizing that their campaigns are going to need to make statements about what they think about crypto because voters are in their districts. So... [16:12] I think it is the industry doing all that it can to be taken seriously and also fight [16:19] years of being painted with a broad brush with, you know, fraud, massive frauds. I think it was we had to kind of like get past a few hurdles of being looped in like the whole industry is a monolith and everybody is involved in fraud. And if Senator Warren headed her way, it would still be that. Right. But I think we have hopefully been scoring some points to show like there are very good faith actors who are building, innovating and using crypto here.

[16:46] Yeah. One thing that I've experienced in trying to research for this episode, but also just kind of trying to stay abreast of everything is that [16:54] there's so much legalese in all of this conversation around regulation and policy. And I'm there and I'm reading the articles and I'm kind of tracking and then all of a sudden I'm like, I have no idea what an amicus brief is. I will never know. Like I'm never gonna like know that in my bones. And so I feel really stuck around keeping up with policy stuff. And [17:18] I want to ask you, [17:19] Sort of setting aside the legalese, what are some of the fundamental stuff that I should be paying attention here, that listeners should be paying attention here? What are the core values, the pillars? [17:30] that we should be listening out for and advocating for. [17:32] Well, if you do want to talk about amicus briefs, I'm your girl. Oh, amicus. See? I didn't even know what to say. We do a lot of them, and we are looking for amicus support for our own cases so we could get into that. But I'll answer your second question first. So I think whenever you are looking at either a proposed law... [17:51] or a judge's opinion, you should be looking out for whether the [17:56] law that is being interpreted and analyzed regulates [18:00] people, alleged bad actors, or whether it regulates software or protocols, right? Who is the subject of this proposed law? Because that's really important. And to give you an example, in the Tornado Cash criminal case, there's also some civil cases related to Tornado Cash, but you know, the smart contracts were the subject of sanctions, and now the developers are

[18:24] faced with criminal charges. If the DOJ's indictment was taken to its ends, like if somehow it became like the what's in the indictment became law, then [18:34] that would mean that software developers are going to be held responsible for an immutable protocol [18:41] being used by third parties [18:43] years after it was created to commit crimes. That's insane. You should always think about who is the law regulating, and whose conduct is it making illegal or criminal? [18:56] the person who created the allegedly bad thing. And then you should also be thinking about tech neutrality. And that's not a new concept. That's an old concept dating back to the 90s, right? The technology itself should be neutral. Privacy protecting technology should be neutral and should not be thought of as illicit in and of itself. The law is supposed to regulate bad actors, not software, not technology itself. And also, like, I think specifically [19:23] in defy and in crypto we want to think about self-custody our ability to custody our own funds and operate peer-to-peer without intermediaries that's another value that i'm always looking for when i'm looking at a case or or law so those are kind of like [19:41] the things that I think about first when I'm analyzing... [19:45] Does this judge's opinion make any sense? Is it good or bad for crypto? Is it good or bad for innovation? But yeah, I think there has been [19:53] a lot of opportunity to get involved legally i think crypto is really unique and that everybody in crypto knows what the howie test is right like in what other industry are there

[20:03] users of just [20:05] the product that know what the Supreme Court test is for determining how that product is classified. So I think crypto is unique in that we have all been super focused on the legal implications, the legal tests and analysis. But that's because we're in the fight. I think 10 years from now, it won't feel as much like that because hopefully we'll have already had... [20:26] hopefully helpful law in place, hopefully helpful regulation in place, and people will just be using and innovating as opposed to having to think about existing and surviving. Well, hard to imagine that future, but I love you painting that picture. I think there are a lot of people in the crypto industry who think any regulation [20:45] is bad. [20:46] or bad maybe is too moral of a word, but has negative consequences. [20:52] from how I'm hearing you speak, [20:55] you see a path for healthy people. [20:57] balanced regulation or [20:59] or from what I can tell. Is that true? Do you think that those two things can exist together? [21:03] I do think they can exist. I'm also coming from the perspective of having been a criminal defense lawyer for 10 years and securities litigator for 10 years. So in my mind, [21:13] Having no law and no regulation means we get more bad criminal cases like the tornado cash indictment and even like the Samurai Wallet case where [21:24] people are going to face [21:25] the worst, in my opinion, the worst of all consequences, which is their liberty being taken from them, because of a lack of understanding or a lack of clarity by the government. So I would like to think that with more law and regulation that is clear and tailored to the tech,

[21:41] We have less people being punished because of a lack of understanding and a lack of meaningful engagement. I understand. I totally understand the argument. And like maybe even like my irreverent ethos can get behind the like all regulation is bad. But I don't think that's the most productive way to move forward. I think that crypto will exist. Crypto will continue to exist in this country and other countries. I think we've reached escape velocity. [22:11] there needs to be clear law and regulation on how to use it, create it, and innovate. [22:17] Yeah, I'm totally with you. There are moments though, like the little sort of irreverent libertarian, tiny little libertarian me can peek out when I see usually, you know, those hearings where Congress people, legislators are talking about tech, and you get the sound bites of them being really wrong about stuff. I think there was one that happened a couple weeks ago that was about Snapchat. And it was some congressman who was talking about tech. [22:42] He was talking about how Snapchat worked and it was just like totally wrong. And I was like, if they can't even get that... [22:48] Right, which is a consumer app and how it works like, or maybe it was a TikTok, maybe it was a TikTok hearing. And I'm like, man, it has me really lose [22:58] faith, hope in... [23:01] our government being able to have a balanced [23:06] informed take on how to regulate these things. I understand that's the work that you guys are doing to help inform them. But that's kind of where my skepticism, I think, comes from when I'm like, man, I see those things. I'm like, I just don't know that they're gonna get the nuances of it.

[23:19] Fully with you on that. Like, I live in fear of them trying to write a law about DeFi because we are so far from a regulator or a lawmaker understanding DeFi on a technical level. And I do think we need more time to educate people behind the scenes and to think about, I mean, there's tech that hasn't even been invented yet that will actually assuage lawmakers' concerns, right? [23:49] solution as opposed to a law created solution that doesn't actually work with the tech. And I think we need time for that. So I definitely am not here being like, please regulate, please create laws about all this tech. [24:02] at a baseline level, a jurisdictional law about whether the SEC or the CFTC is the regulator we should be dealing with. I think that needs to happen on the sooner end of the spectrum, and I really hope that we're not talking about laws regulating the actual tech itself anytime soon. [24:20] Thank you. [24:21] It's time for a more open, inclusive, and transparent financial system. A system that serves nearly everyone, everywhere, all the time. That's why we love today's sponsor, Kraken. Kraken is a crypto platform that provides a super simple on-ramp to the world of crypto with a 24-7 support team. Crypto transcends physical and imaginary borders. No matter where you are, you can send funds easily and quickly to almost any part of the world. Plus, forget about waiting times and waiting lines. You can send, receive, and trade crypto anywhere near instantly.

[24:50] be at kraken.com backslash boys club non-investment advice crypto trading involves risk of loss transfers to a third party are not available on kraken cryptocurrency services are provided to us and us territory customers by payward ventures inc pvi dba kraken view pvi's disclosures at kraken.com backslash legal backslash disclosures [25:11] We're going to keep this part of the conversation totally neutral for all of our sanity. But this week, it would be remiss for me to not mention crypto has entered the political realm in a very meaningful way. I just read an article about Trump's. [25:25] San Francisco fundraiser that he did a couple days ago and there was a bunch of crypto people there and he's calling himself the [25:31] quote unquote crypto president. Also Joe Biden's team a little [25:35] slower on the pickup here, but have also said that they're paying attention to crypto now. It's happening. It's only going to happen [25:43] more as we lead up to the election. [25:47] What do you think the next couple of months are going to look like? So I think you hit on the major points. I think that Trump has come out pro-crypto, which has forced the Democrats, including Biden, to start talking about crypto in a way that they had not been talking about it before. I think... [26:02] The FIT21 issue, as we talked about, has forced there to be a more national conversation about who's pro-crypto and who's not. [26:10] and also we're nearing an election, so it is now an issue for [26:14] campaign platforms. I think that you're exactly right that Trump has come out [26:18] being pro crypto. I will just note my concern is that he has flip flopped on crypto in the past. He has made some statements in the past that were not so pro crypto. So I don't know that we can depend on anyone, not just him, on anyone to be consistent and how they're going to view crypto over the next.

[26:36] year. But yes, I mean, he has come out and made pro-crypto statements. Biden said after FIT 21, he said that he is open to working with Congress [26:45] to create a market structure, pro crypto kind of legislation. I would not say it was like a glowing endorsement of crypto, but it was at least an openness and a shift from [26:57] his policy statement, whether I forget it was a year or two ago where he was kind of like it was all just about fraud and crime and crypto. So this definitely is a positive shift. So who are... [27:07] maybe going down a level [27:09] president aside, who are some of the other folks that [27:12] either side of the aisle that are [27:14] doing good work for the crypto industry. [27:16] So the members of Congress that you see trying to draft legislation, I think, are doing great work in attempting to make progress here. So like Lummis and Gillibrand have a bill in the Senate that's a bipartisan bill. Lummis is a Republican. Gillibrand is a Democrat. So you have a bipartisan effort there. Wiley Nichols, a Democrat who co-sponsored FIT. Mick Henry, who is the chairman of the Financial Services House Committee, is amazing, totally understands the tech, totally gets what we're trying to do. [27:46] And then my personal favorite is Richie Torres, who is a representative in New York from the Bronx. He's a Democrat who totally understands the progressive values that do exist in crypto. And I think just like the broad swath of who you see on the House Financial Services Committee and the Agricultural Committee,

[28:07] These are there are people on both sides of the aisle trying to get crypto legislation done and at least making an effort to understand the tech and and make [28:15] good law on the tech. So I think there's a lot of good work being done and [28:20] We are hoping that we'll see more people engaging with the industry as we head into the election cycle. [28:28] You wrote an op-ed recently on something called the Consolidated Audit Trail. You called it the SEC's mass surveillance tool. You also have spoken about privacy in this conversation. [28:40] What is that? What's going on here? Yeah, the cat is very concerning and not enough people are talking about it in crypto. I've seen more chatter in TradFi because [28:51] members of TradFi are going to have to register to put information into the CAT. So what it is, is the largest database of securities transaction that has ever been built. It is over 10 years in the making. It is going to cost over $500 million in its first five years. And it will require every equity and option trade to be logged, including customer information in one massive [29:21] personally identifiable information of customers. Brokers, retail brokers will have to report customer information into the database where it will be stored. I mean, it's a mass honeypot. If you were going to hack something, like, of course, you would hack this gigantic database that has user information for everybody in the U.S. It is a real-time,

[29:40] surveillance tool with no suspicion of wrongdoing. Whereas normally the government would have to go get a warrant to get your bank records because there's a suspicion you committed a crime. Now it's just going to be reported and it will be accessible to thousands of SEC staff and all of their self regulatory organizations and their staff. It's thousands of people with access. It's just like a massive OPSEC risk and [30:05] The SEC had [30:06] at some point considered better security tools. [30:11] on the database and they just never passed them. Like it's just it's [30:14] It's truly breathtaking to think about how far this has, I mean it's live, like it had [30:20] that we're here and it's happening because it feels like the most un-American thing that I can think of. It already exists. Oh, yeah, it exists. OK. [30:28] Yeah, I mean, I think the SEC Twitter account getting hacked, what was it, six months ago? Yeah. I think shows us how OPSEC [30:37] issues can arise even in an agency like that. [30:40] Right. Like they don't understand two factor authorization. Like they, they don't understand two factor. They're building like the most massive database of information ever. And so Hester Peirce, who we love commissioner Peirce had. [30:53] a great dissent in the budgeting for CAT and talked about the cost in dollars and time and individual financial privacy and makes the really excellent point that [31:04] Our financial transactions evidence our beliefs, our morality, so much personal information just by how we transact.

[31:12] And [31:12] you may be okay with the current political regime, but what if you are not comfortable with the next political regime? Are you comfortable with the government being able to monitor every transaction you make in real time? [31:23] It's just, it's a little, it's scary to me. That's why we wrote the op-ed. We're going to put an amicus brief into this. There's an ongoing litigation challenging the CAT by the National Civil Liberties Alliance. And we will write an amicus brief, which just means a brief that helps educate the court. [31:41] with the Blockchain Association explaining why this is particularly problematic with cryptocurrency transactions. [31:48] Okay. Wow. [31:49] Thank you. I had no idea. I didn't even know. No one in crypto is talking about it, but they should be. They should be worried. Yeah. OK. Anything else you any other wisdom or advice you want to impart on our listeners as we enter the next few crazy months here? [32:05] So I would say that we've talked a lot about Congress, but not so much the judiciary. I think we're going to see a lot of action and ongoing litigation. DEF, we sued the SEC related to airdrops. So in our suit, we partnered with a company called Beba, which makes bags and apparel, all luxury leather handmade goods. [32:24] and they're based out of Texas, and we sued the SEC for a court declaration saying, [32:29] that free airdrops are not securities transactions and also challenging the SEC's [32:36] authority to regulate by enforcement, to keep suing people in the industry because under the Administrative Procedures Act,

[32:42] They are supposed to do rulemaking through notice and comment, not by just suing people over and over again. So that's our suit. There's been other pre-enforcement challenges like ours. There's the Legilex case in Texas, which is asking for a court declaration that this centralized digital asset trading platform is not a securities exchange under the SEC's rules. There's just a lot of industry movement. Everybody's probably familiar with the Coinbase case. There's actually two Coinbase cases, right? [33:12] and then Coinbase's case [33:14] their petition for rulemaking, asking the SEC to issue rules in the Third Circuit. It's like that meme where the two... [33:22] Spider-men are pointing back at each other. Yes, exactly. And [33:28] That's the first case that deals with crypto to get to a circuit court on that issue. [33:36] going to be closely paying attention to what happens there. It would be really meaningful if the Third Circuit said the SEC had to do rulemaking. That would be a big moment. And then, of course, we're waiting to see if the SEC actually files an action against Uniswap. You know, they sent the Wells Notice to Uniswap Labs. [33:52] Labs responded in May and now it's just [33:55] a wait and see, like, have they actually shifted? Does the ETF approval mean they won't sue Uniswap? Or does it mean that does it not mean anything in terms of their litigation strategy? So over the next few months, like those are the cases that I'm focused on. There are definitely others. But

[34:13] There's a lot going on, as you said at the top. It's just so much drinking from the fire hose here. Wow. [34:21] Well, you are going to be busy. Amanda, thank you so much for all the good work that you're doing. Clearly, we can see the impact. Just really grateful for just your work more broadly and also for taking the time to have a conversation with me here. [34:35] Thank you so much. And I really do love your pod. So thank you so much for having me on. Thank you. We'll have you back.