​Insider trading is not new, although until Strong v. Repide pushed the Supreme Court to rule that company directors must either disclose ‘inside’ information or not trade on such information, but it lacked specifics on who would be considered an insider.  The Securities Exchange Act of 1934 went a bit further in assigning fraud to the illegal purchase or sale of securities, which added to prosecutorial leverage in insider cases, but again it was still fuzzy as to whom it applied., and while the Texas Gulf Sulphur case clarified the rules further, it wasn’t until the early 2000’s that the government became aggressive in pushing the rules to include a wide range of insider trading scenarios.  In most cases it was relatively easy to see that inside information was either traded on or disseminated to an individual or small group who were able to profit from the non-public data, and in 1997 the Supreme Court extended the insider trading rules to people that had confidential information even if they did not have any connection to the company involved.
Some cases were hard for the SEC to make, especially those less directly involved with corporate hierarchy, but the list of mid and low level employees and contractors who traded on information that they were either not allowed to see or had an obligation not to reveal or trade on is almost endless, and the idea that “…It was just a good guess…” in such a data driven world seems a bit ludicrous.   So why would Nathaniel Chastain, a product manager at OpenSea (pvt), the world’s largest marketplace for the purchase and sale of NFTs, think that nobody would notice that he was buying certain NFTs before they were featured on the OpenSea website and selling them soon after the digital items were featured, with many knowing he was part of the featured decision making process. 
Examples given in the indictment cited that o August 2, 2021, “…minutes before the NFT named “The Brawl 2” was featured on the OpenSea homepage, Chastain purchased 4 of the NFT, selling them hours after the features became public…” doubling his investment, and on August 9 he purchased 10 of the NFT collection “Flipping and Spinning” before the items were featured, then selling them for prices 250% to 300% higher.  While he made the purchases and sales using anonymous accounts and wallets, he did so on the OpenSea Etherium blockchain and tried to conceal the transfers by opening new accounts when transferring capital in an out.  Chastain purchased approximately 45 NFTs on 11 occasions, all based on inside information, that generated between two and five times his purchase price.
The charges in the indictment are for wire fraud and money laundering, each of which carries a maximum sentence of 20 years, and the defendant was arrested after the indictment was filed.   Bond was set at $100,000.   The FBI and the National Cryptocurrency Enforcement Team assisted in the investigation, which was the first involving digital assets being traded on inside information.  While the blockchain has many positives relating to security an anonymity, it seems to be far more traceable than many believe, although this case seems particularly obvious and ultimately provable (although currently ‘alleged’), so the lesson here might be both don’t trade on information that you are obviously privy to, and don’t think that just because the transaction information is broken up into many pieces across many computers that it cannot be put back together if absolutely necessary.
 

Jay Chou is a 43 year old singer, songwriter, rapper, director, producer, actor, television personality, and strangely magician who has been releasing album since 2000, has performed for more than 10m during tours, and starred in the Green Hornet in 2011.  As many Taiwanese recording and film stars seem to do, Chou collects artwork which he purchases using NFT’s (Non-fungible tokens), which protect the one of a kind artwork from being copied and sold as original.
Unfortunately it doesn’t protect art collectors from being ‘phished’ by sophisticated hackers who offer giveaway promotions on Instagram or other social media sites.  Mr.Chou made the mistake of clicking on one such offer only to find that his personal NFT worth $550,000 and three other valuable NFT artworks had been removed from his account, with the likely culprit being software loaded into his system by clicking on the free offer.  Mr. Chou first thought that the missing art was an April Fool’s joke but when the source of one piece of his art posted that they also had been hacked he realized it was no joke and the tokens were truly gone.
There are two questions here, first, why would one expect a free offer of anything? And second why would one collect what was stolen? (see below), but our is not to reason why, just to note how many hacks, scams, swindles, and flimflams (Thank you President Biden) take place every day relating to cryptocurrencies and NFTs, and the ones that make it into the press or even the technical press are likely just a subset of what actually occurs, as many would rather not see their names associated with such issues.  For what has been touted as a secure way to buy and sell ‘things’, the definition of secure seems a bit flimsy.

​The highly publicized rise of “Crypto Kings”, those now billionaires who came up with the idea that the world needed a new form of currency, that operates through the blockchain, making it ‘immune’ from governmental regulations and interference, have been the poster children for the new world of virtual entrepreneurship that has begun to attract attention from global governments that are trying to both understand and find a way to regulate these unregulated markets.  Names like Binance (pvt), Coinbase (COIN), FTX (), and Kraken (pvt) register billions of dollar volume each day in cryto-trading and have made billionaires of their owners, but while budding tycoons moon over posters of these new crypto-kings, things are not always as they seem.
Aside from China’s vocal denigration of crypro-currency and outright bans on mining, and the mostly embarrassing questions asked by politicians during Congressional hearing and testimony, regulators in many countries are trying to get a handle on the legalities of crypto as it opens a whole new world of fraud to those who invest.  Higher level discussions about whether crypto exchanges should limit transactions with evil-doers have been ongoing, but have been pushed into the headlines as financial sanctions against Russia have supposedly pushed oligarchs to convert the falling Ruble into crypto, with many exchanges citing the ‘libertarianistic’ basis for crypto as a reason not to exclude such customers.  But setting those aside, crypto is such a fertile ground for fraud that it begs for regulation by its very nature.
Here’s what we mean…
On March 3 the US District Court of the Eastern District of New York handed down an indictment against Dwayne Golden (Florida), Gregory Aggesen (New York), Marquis Egerton (North Carolina), William White (Pennsylvania) and a redacted defendant, along with EmpowerCoin and ECoinPlus, two entities that were operating between April 2017 and July 2017, and Jet-Coin, which operated between May 2017 and August 2017.  The Grand Jury indictment states that during those periods thousands of investors were induced to invest in these companies under the false promises that the investors assets would be invested in Bitcoin, that Bitcoin would be traded by these companies on behalf of the investors, and that investors would earn large returns as a result of that trading activity.  In truth the assets were used to repay other investors or simply stolen by the defendants, with the companies collapsing shortly after receiving the investor’s assets, without any trading activity.
The websites for these companies were nearly identical and guaranteed large returns that would be credited to customer accounts on a daily basis, with the defendants writing the advertising copy, contracting internet services, and writing the software to upload the content and maintain the sites.  Investors were encouraged to invest cash or Bitcoin, in some cases by a promoter, by sending it to a different Bitcoin address.  Some investors initially received small payments said to be ‘interest’, other investors soon realized they were not receiving returns and made complaints to the companies.  The defendants changed the name of the company to ECoinPlus in June, 2017 and relaunched, with the updated promise that they were no longer able to promise daily returns but would instead promise a 1% daily return and that their investments would no longer double in two months but would take six months instead.
When investors were still unable to see returns and complained to the company, they were told there were technical difficulties and that the sites had been hacked, but the defendants again tried to relaunch the sites, even after using the investor capital for their own use.  What is most astounding, is the fact that during the period between May 2017 and July 2017 the companies collected ~$21.7m from investors, that’s a rate of ~$236k/day (the final total was actually close to $40m) from investors that obviously did little or no due diligence, but to make matters worse, as the companies began to collapse the defendants began discussions as to what to do if the FBI caught wind of the ‘issues’.  Those discussions continued until February 2018 when the FTC filed a civil complaint and a subpoena from one of the defendants concerning Jet-Coin at which point the defendants erased information from a laptop which it them provided to the FTC in New York and provided statements to an attorney containing falsehoods that were designed to obstruct any investigation.  The lies were effective enough to convince the FTC not to depose the defendants and the case was settled and closed in November 2019. 
Sad ending for the investors? Not yet, as in June of last year the FBI served the lead defendant with a subpoena for all records relating to the three companies and in July one of the defendants made ‘materially false and misleading statements that were passed to the US Attorney’s Office in New York’s Eastern District, resulting in the Grand Jury indictment consisting of 11 counts including Conspiracy to Commit Wire Fraud, Wire Fraud, Money Laundering, Tampering with Evidence, and obstruction of Justice, all of which would lead to up to 20 years in prison if the defendants are convicted, along with forfeiture of any assets (good luck with that).  Of course, the defendants will have their day(s) in court to prove their innocence.
While not to the investors involved, this was a small case, with others, such as the September 2021 “BitConnect” fraud case (SEC) where $2b was raised (unregistered securities) by promoters promising returns as high as 40%/month along with ‘commissions’ to investors who brought in new investors (the result being the seizure of $56m in crypto) and a host of others, not only in the US.  The point here is that the promotion of cryptocurrencies by companies, celebrities, and paid promoters, leads potential investors to believe that the risks involved are minimal, being blinded by the ‘potential’ for massive gains.  As in every investment there is a risk/reward profile that can hopefully be determined by a careful examination of the assets involved and the history of transactions around the asset, but when it comes to cryptocurrecy, due to the nature of the blockchain, there is little transparency and in many cases no history.  While investors are supposed to understand the risks involved in making investments, individual investors rarely have the time or inclination to do such due diligence and rely on promoters to be truthful.  While we are not big fans of regulators in general, cryptocurrency scams will make Ponzi schemer Madoff look like an amateur unless regulations particular to the asset are devised.  There are so many ways to use cryptocurrencies for illegal purposes that it is almost mandatory that evildoers gravitate toward anything crypto.  

​Last week we noted that NVIDIA (NVDA) had been hacked by a South American group known as LAPSUS$.  The hackers stole over 1TB of data including details about NIDIA’s LHR (Light Hash Rate) system that limits the performance of NVIIDIA’s graphic card processors when its graphic cards are being used for crypto-mining rather than gaming.  Graphics cards are in short supply and prices have risen as cryptocurrency miners soak up whatever stock is available leaving gamers, NVIDIA’s long-term customers, with very high prices for the cards they need and little stock.  The LHR system makes it less profitable for miners to use the cards, in theory leaving more for NVIDIAs traditional customers.  By revealing how the LHR works, the hackers are threatening to thwart NVIDIA’s system, unless they pay.
The same hacker group seems to now have hacked Samsung Electronics (005930.KS) over the weekend and mow claim to have the source code for Samsung’s Knox security system and biometric codes for Samsung’s Knox security system that resides on almost every Samsung smartphone. Tablet, or PC.  Indications are that the hackers were able to access confidential source code and other classified data, with the hackers teasing an image of a portion of the data which included the algorithms to unlock biometric data and the code behind Samsung services, which, if true, would open up millions of Samsung smartphones to the hackers or those that decide to use the hacked information.  As of yesterday Samsung was still trying to evaluate what was taken and the risk to users and has not offered a workaround or fix, but with ~20% of all smartphones sold being a Samsung Galaxy device, the problem is potentially a large one.

On 2/23 NVIDIA (NVDA) discovered a flaw that could potentially allow entry into the company’s proprietary servers and began examining the issue, but three days later it was discovered that the system had been hacked by a South American group known as LAPSUS$.  NVIDIA originally thought they had neutralized the hackers and the data that had been stolen however the hackers began posting some of the information collected to prove that they still had the information.  While over 1TB was stolen that included employee information, the most important data included in the hack was details relating to NIDIA’s LHR (Light Hash Rate) system that limits the performance of NVIIDIA’s graphic card processors. 
“Why would a company known for their high processing power graphics cards want to limit their performance?, you ask, however the answer is quite simple, they don’t want their graphics cards to be used to mine cryptocurrencies, specifically Etherium mining.  The LHR system can identify when it is being used for crypto-mining and lowers the maximum hash rate of the card while the power consumption remains the same.  This makes mining less profitable and discourages miners from purchasing said graphics card for their activities.  “Why would a company not want to sell graphics cards?” you ask, but its not that they don’t want to sell cards, it is who they want to sell them to, and the answer to that question is gamers.
As we have previously noted graphics cards are in short supply and prices have risen as cryptocurrency miners soak up whatever stock is available with little regard for price as their cost is spread across a long production period.  That said, operational costs are a very sensitive subject for miners as mining is a very power intensive process, making even small changes in ongoing operating costs the difference between mining profitably or losing money.  By limiting card performance for miners but not for gamers NVIDIA expects more cards to fall into the hands of its traditional buyers, the gaming community, who have been starved for product or priced out of the market.  When LHR was first introduced it took only a few days for the code to be broken by miners but subsequent versions have been more closely tied to hardware and have continued to work against mining operations, but part of what was stolen from NVIDIA by LAPSUS$ was confidential data concerning LHS technology and the hackers are asking for $1m (in cryptocurrency) from the company or will release the confidential information concerning LHR to the highest bidder.
Fears that the hack was part of Russia’s plans for the attack on Ukraine due to its timing were erased when the hacking organization stated that they have absolutely no political affiliation (what else would a politically aligned hacker say?) and NVIDIA says the hack would have no effect on its business but given the amount of data stolen, including source code, we take both what the hacker’s said and what the company said with an ample grain of salt.  As the company has not responded to the hacker’s request for payment and the US government has made it clear that US companies should not negotiate with ransomware requests, we expect more data to be leaked and to eventually see more basic ways to defeat NVIDIAs LHR system posted.  We note that competitor AMD (AMD) does not limit GPU performance for cryptocurrency mining but under new Etherium mining rules likely to be implemented in June, Etherium mining will have less of an environmental impact but will also generate between 20% and 35% less revenue for miners, so the whole NVIDIA hack and LHR controversy could become a moot point.  Again, anyone for the gold standard?  It was so much easier to understand.

Perception of cryptocurrencies ratchets back and forth between good and bad on an almost daily basis.  On the positive side tales of vast fortunes being made and hints that ‘the world will be all crypto’ in years to come are balanced with negative press about money laundering, wallet stealing, and virtual real estate scams, leaving the average person thinking, “This sounds cool, but I don’t have a clue about what it is.”  Cryptocurrency is such a broad topic that we approach it by looking for metrics that can help us understand more about whether much that we hear about cryptocurrencies is promotion or fact and how the governments of the world view the application of same.

One metric we look at is where the cryptocurrency is being used and who is using it as its use in places with meager assets and unreliable fiscal reliability can indicate a different mindset than its use by a highly capitalized nation or organization.  The kind folks at Chainalysis.com have shared with use some of the data that they have derived concerning an attempt to measure where cryptocurrencies are getting the most traction, a more sophisticated task than just measuring the transaction volume.  Transaction volume would be skewed toward professional or institutional players and would leave out much individual participation.  The data ranks countries by a number of metrics, the first being crypto value weighted by purchasing power/capita, taking into consideration the ‘wealth’ of the average person in each country.   The second metric does the same with retail values, and the 3rd by peer-to-peer exchange trade volume, which is where much cryptocurrency activity occurs, especially in emerging markets, with the index score the total of the three
While our conclusions might differ a bit from others looking at the data, it seems to us that cryptocurrencies still have a long way to go to prove themselves as a legitimate  substitute for hard currency, with a number of countries with known ‘bad actors’ in the security world ranking high on the list.  Given that in some of these countries there is little else than peer-to-peer cryptocurrency trading, as centralized exchanges are not accessible, we temper that caution, also understanding that some emerging markets face currency devaluation, which pushes residents to use cryptocurrency to ‘preserve value’, which is done on P2P networks, and a number of emerging markets limit the amount of national currency that individuals can transfer to other countries, further encouraging the use of P2P networks, which allow residents to bypass such restrictions.  That said, we view the data skeptically, even the fact that during the period between 3Q 2019 and 2Q 2021 (after a few quarters of flat growth) the index totals showed that cryptocurrency adoption grew 2300% and 881% over the last year.  As cryptocurrency prices have risen, the attractiveness of such increases, both to institutional investors and individuals, but we expect the extreme volatility seen, particularly over the last few days, (up 14.6% as of this writing as Russia’s Swift sanctions push the government to use cryptocurrencies for payments) will bring cryptocurrency prices down to a more reasonable level of trading when the Ukrainian crisis is over, and temper some of the political enthusiasm that has been seen for cryptocurrencies.
While we show only the top 20 in the table below, in the P2P category, Kenya comes up in the #1 position, meaning the most P2P use/capita, while South Korea comes up last.  China is first in the retail category, and the Cayman Islands is last.

​The government of India will impose a 30% tax on income derived from cryptocurrencies and other digital assets as noted by the Minister of Finance earlier this month, which was taken by crypto investors as a tacit approval of crypto and NFTs, despite the fact that it put such income in India’s highest tax bracket and excluded crypto losses from offsetting other income.  Given that the Indian government was considering barring cryptocurrencies altogether last November, it seemed the least draconian of the possible outcomes.  With an estimated 15m to 20m crypto investors in India holding crypto ‘assets’ of ~$5.37b (unofficial), the idea that the government was developing a taxation system for crypto seemed to some that the government was at least recognizing the legitimacy of cryptocurrencies, or at least that is what the CEO of ZebPay (pvt), a cryptocurrency exchange, said, “Thirty percent tax on income from virtual digital assets, while high, is a positive step as it legitimizes crypto and hints at an optimistic sentiment towards further acceptance of crypto and NFTs”, albeit a bit biased.  Tax accountants were a bit less optimistic, estimating that such a tax would really amount to ~42% including surcharges and fees.
That said India’s Central Bank has voiced concerns over the instability of cryptocurrencies and a number of banks cut ties with crypto companies, but the Indian government also indicated that the Central Bank will introduce a cryptocurrency during the next financial year (2023?) using blockchain and other technology.  But late last week the head of the Reserve Bank of India stated that “Private cryptocurrency is a huge threat to macro-economic stability and financial stability...investors should keep this in mind that they are investing at their own risk, and these cryptocurrencies have no underlying (value) - not even a tulip”, referring to the Dutch tulip mania that gripped investors in in the early 1630’s until its collapse in 1637.  This seems to be the mantra of many governments, including the US, where stern warnings about the risks of cryptocurrencies are given but fear that the government will lose revenue or be seen as ‘technically outmoded’ push them toward issuing some sort of government sponsored cryptocurrency as we noted on 01/21/22. It’s a very complicated issue that is hampered by both a lack of understanding and greed.  Back to the gold standard?

​Facebook (FB), now Meta, is a logical supporter of the Metaverse as an opportune way to create new data channels and stickier users, but as part of the Facebook/Meta Metaverse dream, the company had been ‘developing’ an in-house cryptocurrency since 2018 through a subsidiary named Calibra, under the crypto name of Libra, which along with the name of the subsidiary (changed to Novi), was changed to Diem in 2020.  The concept was to offer Diem through Messenger and WhatsApp to the “half of the adults in the world that don’t have an active bank account” and to the “70% of small businesses in developing countries that lack access to credit.”
Under the Facebook plan, Diem was to be a safe and private currency that can be used for any transaction, and was to guarantee that no data (except in limited circumstances) would be shared with Facebook or any 3rd party, although “if a Calibra product feature can be personalized or improved with data from Facebook”, customer permission will be requested, adding “We may also use customer data to conduct research projects related to financial inclusion and economic opportunity with, for example, academic institutions and NGOs, though any published results will only contain aggregated statistics.”
Facebook created the Libra Association  (changed to the Diem Association) to oversee the Diem network and was intending for the Diem to be a stablecoin, but not pegged to a single currency but rather a basket of currencies, which means that the value in local currency would vary, albeit likely less than Bitcoin or other unpegged currency.   The assets backing the currency were to be held by a ‘geographically distributed network of custodians with investment grade credit ratings’ in order to increase security, and Diem was to beinflation neutral as the number of Diem coins will be adjusted to the value of the exchanged currency, either by adding or destroying Diem coins, with Facebook and 3rd parties collecting interest on Diem reserves.
Unfortunately, Libra/Diem faced considerable opposition, particularly in Europe where Facebook and Google (GOOG) were facing substantial fines for anti-trust violations, with the French foreign Minister stating “It is out of the question” that Libra “become a sovereign currency, It can’t and it must not happen,” and the German European Parliament representative posting on his Facebook account that the company could become a “shadow bank” and that regulators should be on high alert.  With the scrutiny that Facebook’s original Libra announcement caused, and the added warnings from European regulators, Facebook postponed the launch of the currency and renamed it Diem, which seems to be a go-to concept that Facebook uses to deflect bad press or increased scrutiny. 
However on January 31, the CEO of Diem stated that the Diem Group’s assets and IP were being sold to Silvergate Capital Corp (SI) for $182m (+ $30 in associated costs), essentially selling the rights to the Diem stablecoin and the blockchain network associated with the currency, giving Silvergate its own stablecoin, although the press release seemed to indicate that the current Diem Association would be wound down, and the operations melded into Silvergate’s Federal Reserve Bank organization and the Silvergate Exchange Network, a 24/7 digital network that allows SEN network customers to move dollars to and from any other Silvergate customer account using a stablecoin. 
With the assets behind Diem, and the negativity of its association with Facebook, Silvergate has bought a way to provide a stablecoin intermediate for its customers, which is especially attractive given the release of the Fed’s “Money and Payments: The US Dollar in the Age of Digital Transformation” report which we highlighted in our 01/21/22 note.  The report favored stablecoins over other cryptocurrencies, although we expect the Fed is still a bit away from adopting a CBDC  (Central Bank Digital Currency) and has put much of the onus on Congress to pass legislation that would put such currencies into a federal regulatory framework that would give the public an understanding that such a currency would not require deposit insurance, but would be a direct liability of the Federal Reserve, with no credit or liquidity risk, something Facebook was not able to provide.

​The Fed on Crypto
The Fed has issued a paper entitled “Money and Payments: The US Dollar in the Age of Digital Transformation” which begins a discussion between the Federal Reserve and stakeholders concerning central bank digital currencies (CBDC), defining same as ‘a digital liability of a central bank that is widely available to the general public’, however the Fed is careful to state that the paper does not signal that the Fed will make any imminent decisions about the appropriateness of issuing a US CBDC. Citing the advent of private sector financial products such as digital wallets, mobile payment apps, and assets such as cryptocurrencies and stablecoins, the Fed has been studying the potential benefits and risks of issuing a CBDC.
The basic criteria that the Fed considers when evaluating such an issuance are:

• provide benefits to households, businesses, and the overall economy that exceed any costs and risks;
• yield such benefits more effectively than alternative methods;
• complement, rather than replace, current forms of money and methods for providing financial services;
• protect consumer privacy;
• protect against criminal activity; 
• have broad support from key stakeholders

While the Fed extols the virtues of the US payment system, it does cite the fact that while the number has been decreasing over the last ten years, 5.4% of the US households do not have a bank account and ~20% of bank account holders still rely on costly financial services such as money orders, check-cashing services, and payday loans.  Cross border payments also face high fees, slow settlement, and limited access in a number of countries, which the Fed estimates represents 5.41% of the notional value of the transactions, with the concept that digital currencies might be able to reduce those costs.
The Fed seemed to favor stablecoins in the paper, as an alternative to other cryptocurrencies, as they are linked to financial assets, while other cryptocurrencies are mined, creating an unlimited supply with significant energy consumption.  Currently most cryptocurrency exchanges do not charge a fee for stablecoin conversions, while they do for most other cryptocurrencies, making them attractive to novice traders, however regulations and accounting rules for stablecoins are still in early stages and the Fed was cautious about a number of risks including destabilization runs and concentration of power in regard to stablecoins, urging Congress to enact legislation that would ensure that stablecoin payment arrangements were made under a federal regulatory framework.
That said, the Fed sees a CBDC as a way to open digital payments, such as those made through Fed systems to banks, available to the public, although they note that as a direct liability of the Federal Reserve a CBDC would not need deposit insurance to garner the trust of the general public, making it “the safest digital asset available to the general public, with no associated credit or liquidity risk.”  Further, “While no decisions have been made on whether to pursue a CBDC, analysis to date suggests that a potential US CBDC, if one were to be created, would best serve the needs of the United States by being privacy protected, intermediated, widely transferrable and identity verified”, which sounds quite a bit like a tacit endorsement.
As to how the Fed sees the use of CBDC on a daily basis, they aver that all CBDC transactions would need to be final and completed in real time, allowing users to make payments to one another using a risk-free asset. “Individuals, businesses, and governments could potentially use a CBDC to make basic purchases of goods and services or pay bills, and governments could use a CBDC to collect taxes or make benefit payments directly to citizens. Additionally, a CBDC could potentially be programmed to, for example, deliver payments at certain times.”  However, they also see such a product as one that could level the playing field for private sector firms of all sizes, helping smaller firms that do not have the resources to issue their own safe and secure private assets.
As the paper delves further into what a CBDC might do to help the US financial systems it seems more obvious that the Fed is both looking for a way to enter the ‘cryptocurrency’ market without the risks and volatility that most such currencies contain, and is looking down the road to the eventuality of a cashless society, albeit one where Federally directed monetary policy would be influenced by CBDC reserve demand, making it an even more complex structure to manage from a fiscal perspective.  There are mentions of privacy, since the use of intermediaries would be needed as the Fed would not be offering CBDC accounts to the general public, and safeguards to prevent financial crimes, but the Fed seems to be edging toward coming up with a plan that would allow it to gain a level of control over the cryptocurrency ‘wild west’ that exists today, which certainly needs ‘corralling’, especially when one looks at the list of cryptocurrencies that trade at least $1 in daily volume.  There are 8,347 cryptocurrencies in that list and many more that trade less than $1 volume/day, so the field is ripe for some sort of regulation and/or central system that would make it stable, while helping to bring the Fed into the 21st century.  The Fed is open to comments until May… .