watershed moment for the the crypto industry - grateful to all the teams who dedicated immense amounts of capital and energy to lobbying, advocacy, and litigation over the last decade
onward (not sure on the upward for now)
North Capital Launches Tokenization Subsidiary, North Capital Token Services LLC, for tokenization of debt, equities, and private fund interests, and on-chain credential certification. https://t.co/QA5YM6PgH1 via @ein_news
Real estate projects, private funds, registered funds, private secondaries, liquid alternatives, crypto digital assets (soon). If you are a sponsor, broker, manager, advisor, consultant, or investor, watch this space. IYKYK
🚨 Users are reporting problems with Google Workspace Admin Console. Is Google Workspace Admin Console down for you? RT if you are having issues. https://t.co/9lrQe6pAQ3 #google-workspacedown
Department of Government Efficiency has solicited specific changes to government regulations that would be significantly impactful for innovation, economic growth, and government efficiency. Here are my three best ideas:
(1) 15 U.S. Code § 80a–3 - Definition of investment company - delete the 99 investor limit in 3(c)1; delete 3(c) 7 in its entirety. The limit of 99 investor "slots" in 3(c)1 exempt investment companies is stupid. It encourages managers to jack up minimum investment requirements when it would be better for issuers and investors to allow for greater diversification. It causes funds managers to forego launches because with a 99 investor limit, what is the point? In the words of Warren Buffett, something not worth doing at all is not worth doing well. What is the magic about 99 investors? Precisely nothing.
(2) 17 CFR § 230.506 - Exemption for limited offers and sales without regard to dollar amount of offering. The Reg D exemption should be extended to investor resales of issuer securities to facilitate the development of secondary markets. Investors and advisors alike are wary of private securities due to their lack of liquidity. But the lack of liquidity is a direct result of government restrictions on secondary trading. It is stupid that a resale of securities is subject to more stringent requirements than a primary exempt offering. Normalize the rules and secondary markets will expand and provide better outcomes for investors. Limited liquidity is good for nobody. Greater liquidity is good for everyone.
(3) 26 CFR § 1.7704-1 - Publicly traded partnerships. Create an exemption for PTPs under $1bn. PTP rules preclude the development of robust secondary markets for private funds. The QMS exemption is very limited and not practical for small funds. Create a limited exemption for small private funds (<$1bn) and capital formation and secondary market liquidity will explode.
These three changes --- eliminating the 99 investor cap in 3(c)1 of the Advisors Act, broaden the Reg D exemption to include resales of exempt securities, and establishing a limited exemption to the PTP rules to provide for secondary trading of small private funds ---would dramatically improve capital formation, liquidity, and transparency of private markets.
#privatemarkets #secondarymarkets #doge #departmentofgovernmentefficiency #PTP #liquidity #Transparency @DOGE@VivekGRamaswamy@elonmusk
(1) 15 U.S. Code § 80a–3 - Definition of investment company - delete the 99 investor limit in 3(c)1; delete 3(c) 7 in its entirety.
(2) 17 CFR § 230.506 - Exemption for limited offers and sales without regard to dollar amount of offering. Extend the Reg D exemption to investor resales of issuer securities, to facilitate the development of secondary markets.
(3) 26 CFR § 1.7704-1 - Publicly traded partnerships. Create an exemption for PTPs under $1bn.
These three changes would unleash uprecedented capital flows and capital formation. Why?
(1). The limit of 99 investor "slots" in 3(c)1 exempt investment companies is stupid. It encourages managers to jack up minimum investment requirements when it would be better for issuers and investors to allow for greater diversification.
(2). Everyone criticizes exempt offerings due to their lack of liquidity. But the lack of liquidity is specifically due to government restrictions on secondary trading. It is stupid that a resale of securities is subject to more stringent requirements than a primary exempt offering. Normalize the rules and secondary markets, on the same terms as the primary exempt offerings, will expand and provide better outcomes for investors.
(3). PTP rules preclude the development of robust secondary markets for private funds. The QMS exemption is not practical for small funds. Create an exemption for small private funds (<$1bn) and capital formation and secondary market liquidity will explode.
@DanCrenshawTX 100%. If you would like to have a more in depth discussion about how this works in practice with small broker-dealers, have your people call our people. We can regale you with stories that will blow your mind.
I think the crypto regulatory enforcement agenda is going to rapidly pivot from legit companies to fraud schemes.
Bullish for a crypto criminal defense lawyer, like me.
Bullish for crypto start ups everywhere.