Knowledge Circle podcasts

Crypto in Banking: Navigating the Emerging Regulatory Landscape

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In this episode, we’ll hear the highlights from our webinar on Crypto in Banking. The panel discuss what the right level of regulation is for the crypto space, where it’s possible to protect businesses and individuals, but also ensure fair access.

Our guests for this episode were:

1/ Rahul Advani, Policy Director for APAC at Ripple
2/ Richmond Teo, CEO of Asia and Co-founder of Paxos
3/ Daniel Lee, Head of Web3 at Banking Circle
4/ Nick Lord, Founder of Blue Pool Communications [moderator]


Transcript

Russell Goldsmith [00:00:05] Welcome to the Knowledge Circle podcast from Banking Circle, my name is Russell Goldsmith, and, in this episode, we’ll hear the highlights from our webinar on Crypto in Banking. Our guests were Rahul Advani, Policy Director for APAC at Ripple, based in Singapore, Richmond Teo, CEO of Asia and Co-founder of Paxos, and finally Daniel Lee, Head of Web3 at Banking Circle. Our host was Nick Lord, Founder of Blue Pool Communications, who we’ll hear from first.

Nick: [00:00:35] Over the past two weeks, the world of digital assets has arguably suffered more than at any time in the past ten years. So today we’re going to look at what’s happened, how this might have affected the institutionalization of digital assets, and perhaps most importantly, what should be done to take the industry forward. So, firstly, how did we get to where we are today? What are the root causes of this? Rich, perhaps I can bring you in to start us off.

Rich: [00:01:04] Well, let’s talk a bit about root causes first. You know, it’s interesting how we’re facing this and I’m recalling a discussion that we had here in Singapore where I live, where MAS, the local regulatory body, I was talking about the need for regulation and the need to curb speculation. And I was involved in that. And I talked about a couple of things that I thought were generally a problem with over speculation in the industry. I think the first one is just listing standards. Exchanges don’t really have very uniform listing standards. Smaller exchanges tend to be willing to list new tokens or less liquid tokens or really their own tokens, which I think is a real problem for the industry. So, I think if you look at listing standards, ensuring the exchanges on listing, just their own tokens or tokens that are extremely heavily invested in, I think that’s one key problem. The second is back then and this is all again, all this is just prior to FTX Alameda, but I think still very, very true. The second thing is market makers shouldn’t be co-mingled with exchanges. Think having that very separate is very important. The third is that exchanges should not list spot products, new spot products along with perpetual swaps. And I think that these firms being listed with new token listings that are very illiquid makes it very easy for price manipulation by market makers, by the project teams or by the exchanges themselves. And I think that is extremely, extremely dangerous. The third really is that exchanges really shouldn’t have a huge need to be taking out loans. They shouldn’t have a huge need to be loaning money out or be in that loan business with other companies in the space. I think that generally is a red flag. And the last thing I talked about is that exchanges really need either a custodian, a third party verified custodian that’s aware of the assets or we know who owns it or who has ownership of the assets, or there should be some sort of proof of reserves of assets or something that exchanges can provide. So, I do think that generally, a factor of these five things are very true to why we have excessive speculation, which cause a lot of the problems that we have this year. And that’s just taking just a general look at what I think causes that in the industry in general.

Nick: [00:03:32] That’s very prescient of you, especially to establish those thoughts before they’ve actually come to fruition in such a dramatic fashion. Daniel, what do you think the wider market impact of events of the last two weeks is going to be and specifically from an institutional viewpoint?

Daniel: [00:03:49] There’s a lot of this talk about stuff like that, but actually, I think a lot of this kind of things was also seen in other asset class when they were much in their infancy. Tick, tick, you know, emerging markets, equities, when they were in a less regulated space, they were actually operating very much like in cryptos. But crypto is happening. Even the schemes that you know, people are talking about this flywheel scheme that FTX allegedly use. Those were the kind of schemes that were being used like in the mid-nineties and during the second bought Malaysian emerging market equities. It’s not a new scheme at all. And if you think about how crypto is, I draw analogy to it, to let’s say 1985 Singapore. During that time there was this big crisis that was known as the pan-electric crisis, and it was the only time that the Singapore exchange was actually suspended for three whole days. And during that time, there was no such thing as a law or a statute that regulated equities. There was no Security Industry Act, there was no Security Futures Act. Basically, how equity ran was different members of the exchanges came together and set up your own rules. There was no power of enforcement by the exchange. They were just like bylaws. It’s just like a club that you join and then you just have to abide by these bylaws that you have. And that was actually what happened. That caused a big crisis in 1985. At that time, settlements of securities could take several days. So, a lot of people would just buy equities and not pay for them with the hope that they would just go up and then sell them later. And when the musical chairs stopped, there was a huge crisis. A lot of brokers went into almost bankruptcy. I was still a kid by the time. But I still remember a lot of people saying, I’ll never touch equities again, I will never buy a share again. But a year later, that whole industry changed. Regulations were actually put in, the Security Industrial Act was actually put in, and then the whole industry became a lot more better regulated. And you see, that’s how the equity markets actually grew in Singapore. And I draw analogy that to cryptos. Cryptos grew very fast. It was not very well regulated. But now you see a crisis is actually a time of opportunity, and an opportunity where you can make it better. We know where the pain points are and what to fix. So, I would think that, you know, the more positive, far-reaching consequences is that it’s going to be a better market in the future.

Nick: [00:06:54] Great. Do you think the institutions that we see who have been dipping their toe into the market, some dipping their whole foot in, do you think they’re going to continue with their crypto journeys, or do you think the last couple of weeks is going to put a stop to things or at least a pause? What are you seeing in your client base?

Daniel: [00:07:12] Well, in fact, I spoke to someone that is in traditional finance, a very senior banker in a traditional financial institution. They were looking to launch some crypto related products. So he wanted to talk to me about what would I think about the market and stuff like that. And what he ended up seeing is that actually now this gives me time to build a better product before I launch it. Because before that they were just rushing to have something that they can actually just launch, you know, something newsworthy that they could launch and stuff like that. But now I think that they can take a step backwards, look at things from a different angle, and then they can build a better product. So, there are still a lot of traditional financial institutions that are actually looking at different opportunities. Some of them might be a bit concerned about what to do with cryptos, but they are looking at other assets in this space as well, for example, Stablecoins. So, there are institutions that are now saying that I’m a bit more concerned about cryptos, but I’ll look at Stablecoins, I’ll look at tokenized assets. So, they are not completely saying that I’m out of this market, but they are seeing they still see the full potential of it. But I think they’re taking a step backwards and then trying to see what, how best to go back into this space.

Nick: [00:08:42] Rahul, I’d like to bring you in here with your policy hat on. What do you think as a result of this is going to be now the appropriate level of regulation for the crypto space? And how has this changed over the last month or so?

Rahul: [00:08:54] Like we’ve seen with all the innovations, digital asset activities have benefits as well as posed potential risks as we’ve now seen. The challenge for regulators is to be able to balance the benefits that the innovations in the sector brings with the risks. Now, when digital asset markets became increasingly active around five years ago, I think regulators around the world assessed money laundering and terrorist financing risks as the key areas of concern. However, with the rapid growth in scale and complexity of digital asset activities, we’ve seen other risks that have surfaced, and regulators need to focus efforts on addressing these new risks. These risks could include managing technology and cybersecurity related risk, ensuring retail investor safeguards, business conduct requirements, as Dan alluded to, such as segregation of accounts and conflicts of interest and market integrity measures to ensure that there are no unfair trading practices such as market manipulation, misleading conduct, or insider trading. Again, we’ve addressed all of these risks with traditional financial markets. We now need to look at this for the crypto markets. So therefore, we believe that regulators will begin to look at a risk-based approach to regulating the sector and that calibrates regulations to the specific risks posed by the activity. It’s very clear that a one size fits all approach is no longer going to work. And as Rich alluded to, I think it’s also important for industry participants to provide transparency and timely disclosures proactively. Such measures could also go a long way in towards building greater transparency within crypto and will be key to building trust in the industry. So, on our part, Ripple voluntarily issues an XRP markets report every quarter to update the industry on critical sales and purchases made by Ripple within the market. And we’re seeing more such proactive disclosures by other industry participants as well now.

Daniel: [00:10:44] I was thinking that one of the initial narratives on cryptocurrencies has stuck in the minds of a lot of regulators, is the narrative on money laundering and terrorist financing. And most of the approach by most regulators is to impose some sort of very stringent AML, KYC type regime, which includes customer due diligence on chain screening, implementation of travel rules. But the regulators have somehow not focused on so much on governance of the crypto firms. There are no specific prudential regulations gearing limits, limits on exposures, margin requirements, that kind of thing. And I think that instead of just focusing on more AML, more KYC type regime, we need to actually have regulations that prescribe governance, you know, things that prudential limits and stuff like that. And I think that’s the focus where it should be.

Nick: [00:11:40] Within that, and also referring back to what Rahul said about building trust, given the global nature of crypto markets, how can we achieve some form of cross-border consistency in regulatory frameworks and obviously in the regulatory response to this and specifically to avoid fragmentation? Rahul, perhaps you could start with that one?

Rahul: [00:12:01] I mean, given the cross-border nature of digital assets, what we don’t want to see is a race to the bottom and hence opportunities for regulatory arbitrage when it comes to regulations. So global consistency and clarity is important for the industry to develop sustainably. Now, in order to reduce regulatory uncertainty and to provide clarity to the legal character of digital assets, we feel it’s important for regulators to develop a taxonomy for digital assets. This will allow regulators to build frameworks that are forward looking and flexible, while also providing regulatory certainty and consumer safeguards and at the same time meet the goals of encouraging innovation and growth in the sector. I think Singapore is a great example of a jurisdiction that we believe provides such clarity. To start with, Singapore provides a clear taxonomy for digital assets. So digital assets are either regulated as digital payment tokens or DPTs under the Payment Services Act, or as digital tokens, which constitute a capital markets product and are regulated under the Securities and Futures Act. So, this allows for an activity-based licensing framework which encompasses a wide range of activities which better facilitates innovation in the sector while mitigating the risks that we alluded to. But we also feel that it’s key for authorities to cooperate and coordinate with each other. That could be both domestically, where you have multiple regulatory authorities and internationally to ensure that there is efficient and effective communication, information sharing and consultation in order to encourage this consistency of regulatory outcomes. We feel that global multilateral bodies such as BCBS, IOSCO, the FATF, IMF and FSB will play an essential role in fostering such cooperation. In fact, the Financial Stability Board is currently consulting on the International Regulation of Cryptoasset Activities. The Basel Committee on Banking Supervision just concluded its second consultation on the prudential treatment of crypto assets for banks. And we’re seeing more and more global bodies now focusing on digital assets. But we also feel that any approach to formulating regulation should be data driven. A good example of this is the recent survey that MAS conducted of DPT service providers to understand the interconnectedness of the market and aggregate exposures. Another good example is a recent Basel Study of Banks Crypto Holdings, which was published as part of the Basel three monitoring report in September of this year. And we feel like such data sharing amongst regulators will be key to ensuring this regulatory consistency globally.

Nick: [00:14:31] So I think we’re sort of drifting into the third part of our discussion of how we can actually make long term improvements to the industry, I think. Rich, you came up right at the beginning with some really very apposite ideas, especially around exchanges. I want to just address a wider issue to begin with first. As a result of all the impacts of what is coming, how can we ensure that fair access remains for digital asset markets whilst at the same time weeding out bad actors, making more prudential regulation? How can we make this? How can we ensure that the good things of crypto remain.

Rich: [00:15:14] I’ll start by saying that obviously Paxos is pro regulation. We have recently, just two weeks ago, we received our full license here in Singapore by the MAS. We’re headquartered in New York. We received our license from the New York Department of Financial Services as a trust bank in 2015, the first crypto company to ever get it. And we received our national charter from the OCC as a digital bank as well. That’s a conditional approval. As a firm, we’re very pro regulation. Now, having said that, I would say that in this industry over the last ten years, there are three general types of companies that I’ve seen kind of emerge, right? I think the first would be the companies that scale very quickly and get a lot of trust from their users, their users like them, they’ve great products and so they scale and they are successful and they exist. The second category, I would say, are people who come into the industry, very splashy, make a lot of expensive purchases or a lot of very, very, very strong marketing, very heavy spend kind of players. And I think when those players come in, they can also scale quickly because they seem to have a lot of money to spend. And I’ll see the third category are people who proactively got regulation and that’s the category that Paxos is in. So, I kind of think that the second category becomes more questionable given what everyone has experienced this year. And I think that we need to look at the first and the third category, people who just naturally build a good product and have a lot of users and people who are regulated and find a way for those guys to progressively get more licensing in more regions and basically have that put their resources towards getting better regulation in the world. I think a great example of that is how quickly Binance grew. You know, Binance now probably has the most number of users and they’re spending a lot of their resources country by country, talking to regulators and trying to get regulated and trying to understand the rules and trying to basically put in the best framework that is being used. And so I think some sort of merge between a great product that users really, really like and getting them to basically get the best licenses in the world, I think that’s where we should just generally as an industry move towards. And I think one example of how I kind of see that playing out is that Paxos and Binance, for example, has a joint venture called BUSD that’s a Stablecoin that’s branded with the Binance name on it. It’s on Binance is used actively on Binance, but it essentially uses Paxos’ trust status to very safely hold funds and have that in a very regulated manner. So, we’re the only ones of the major Stablecoins that are fully regulated. And I think we’re working with Binance to kind of help bridge that gap more quickly. And it’s a gap that Binance is bridging right now. But I think that helps accelerate a lot especially just for this one silo, for Stablecoins specifically. And I think that process should be going on and hopefully, that will bring out more, more clarity and more safety in the industry.

Daniel: [00:18:44] I think one thing that Rich talked about is about how you bring his Stablecoins that is in a very regulated manner to the market. I think that’s very important. In fact, we were thinking one of the things that we could do as a bank is actually take deposits of Stablecoins like BUSD, at least something that is very fiat based. And these are conversations that we are having with our regulators at the moment to see if that can happen, that, you know, as a bank, whether we can actually take Stablecoins as a deposit, as I would take Fiat as a deposit. So those are things that are being done, being discussed with regulators that could actually help ringfence, protect assets for institutions, give them comfort and stuff like that. But I think one of the other things that is also lacking in the industry that I hope to see more is that there are no specific regulations on things like creating false markets, false trading, market rigging, transaction, market manipulation, false or misleading statements. Those are all things that are considered illegal in the securities world. But there are no specific regulations that are preventing that in cryptos. And I will hope to see more of such regulations coming in. And I think those are one of the things where you can prevent bad actors. And the second thing is also to bring in things like the fit and proper regimes that is actually being used in traditional asset to be applied to its crypto firms. Whenever you want to get them to get a license, you need to apply the same standards of fit and proper as what you would do in capital markets, for example.

Rich: [00:20:36] I’m going to add real quick to what Daniel said. I think one of the things that we’ve seen happen over and over again is firms misrepresenting themselves as having some form of regulation or being regulated or things like that or displaying that they have regulation, they talk to regulators or things like that being misinterpreted as actually being regulated. And I think that’s one of the things that we’ve seen over and over again. And I hope that stops in the future.

Nick: [00:21:07] This begs the question, is there not a danger that we’re just going to essentially import all the traditional finance regulations into crypto and in so doing, not recognize some of the unique qualities of crypto? How can we ensure that this doesn’t just become another arm of the traditional finance industry? Rahul perhaps, we haven’t heard from you for a while. And just as a follow up question to that, is the answer maybe about having different regimes for different types of crypto activity and have a focus at the activity level, such as lending, writing options, trading? Is that maybe the solution?

Rahul: [00:21:45] I think we have to go back to the risk sensitive approach that I outlined earlier. It’s important to ensure that effective regulation is proportionate to the financial stability risk posed by the activity. And I think a broad principle we can use for that is same risk, same activity, same treatment. And that’s an order not to throw the innovation baby out with the bathwater. So, a digital asset that provides equivalent economic functions and poses the same risks compared with a traditional asset should be subject to the same regulatory requirements as the traditional asset. So as a starting point, the framework should apply the concept of technology neutrality, right, and not be designed in a way to explicitly advocate or discourage the use of specific technologies. It should be based on the activity and the risk that that activity poses. Now, should there be different regimes for crypto than for traditional finance? I think it depends on the jurisdiction and framework. It’s very difficult to give a general answer to that. I think some jurisdictions will be able to regulate digital assets within existing frameworks and I gave the example of Singapore earlier where digital assets are regulated either under the Payment Services Act or Securities and Futures Act. Other jurisdictions may need to look at creating new regulatory frameworks because the existing frameworks don’t support regulating digital assets. It depends on the nuances and the legal nuances of the jurisdiction. But I think what I’d like to highlight here is that what’s important is the function, not the form. Creating a new regulatory regime for the sake of it may not be the best approach and could lead to more confusion and unintended consequences. I think what’s important to ensure is that regulators meet the policy goal of supporting innovation while addressing the risks of the sector.

Daniel: [00:23:34] To me, I don’t think it’s really possible to even use existing regulations to regulate this, because even if you take things like the different asset within traditional finance, you take commodities versus securities, it’s actually governed under different statutes, different acts, different regulations altogether, and in many, many countries is actually run by different regulators as well. And in some countries, derivative regulators and securities regulators are different. And that’s for a very specific purpose because the asset behaves very differently and poses different risk. And therefore, I think we need to have very specific clear regulation that it’s more, rather than getting a regulation that is copied from something else, you take equity and then you think you can apply it directly. There are certain provisions, general things like market abuse and stuff like that that we could take on. But I think that to regulate it well, you need something more specific. And we cannot have a regime that is over encompassing. Like, for example, in Singapore, we have digital payment tokens that cover anything. You can be an exchange, can be a proprietary trading firm, you can be a market maker, you can be an OTC broker, it’s still the DPT regime, right? And I think that more and more regulators are acknowledging this. So, for example, let’s say the best regime in Europe has five different categories. And then when MiCA comes live, it actually refines into ten different categories of crypto activities. And I think that would be a much more appropriate way to regulate the crypto space.

Rich: [00:25:24] I generally agree, but I would say that if there was a lot more regulation early on in the space, whether it was very, very specific to a product or very principle based, it would generally have been a positive, a net positive from what we see today. A lot of things that are older and may not apply to the world of crypto, it’s not like they’re completely irrelevant. I think that just, generally speaking, just segregating customer assets, having someone to ensure that what you say and what you do were the exact same thing, these are very principle-based approaches that I think that we should get. We should get the regulators on and from that, depending on the company, the product that has to be made clear to a regulator and someone has to understand that what you’re doing does not break a key principle. I think the key pillars that we should be concerned about is money laundering, one thing that is very widely discussed, and the other is consumer protection. And I think a lot of these things, you can look at it from a principal standpoint or you can look at it from a product standpoint, but somebody other than internal leaders and a company could help make that a lot more transparent. And I think there are a lot of products that get conflated together. Not all tokens are the same or not all products are the same. So, I think at least getting a step through the door, a foot in the door, and basically running your operations from a more principals-based approach where you care a lot about these traditions, I think that’s important rather than a long, drawn out 20-year policy that we may or may not see.

Nick: [00:27:00] It’s interesting you say that. I mean, after the financials of GFC in 2007, 2008, a similar thing happened, a complete reregulation of the traditional finance industry around these ideas of principles. In the UK, the regulator became the Financial Conduct Authority with the focus very much on conduct. And one of the consequences of this was born a huge industry of internal controls, three lines of supervision, three lines of risk, focusing on the surveillance and monitoring, everything like that, and which again, leads to a situation where only the big guys can really afford to take part. Even after the regulations exist in normal financial markets, there are still lots of insider trading and each regulator has its own type of bias. So, then the question becomes what is the actual use of crypto once it’s regulated in the sense that part of the whole attraction was the decentralized aspect and non-governmental interference. At the same time, governments are always behind in how to stop the next problems and are slow to react. But I think within that, the germ of the question, the kernel there is how can we keep the unique attributes of crypto, everything that makes crypto so special? How do we keep that and then make it better regulated?

Rich: [00:28:21] I think what we’ve been talking about for the last half an hour is exclusively on CFi, right? The decentralized aspects of it and I think that’s a very valid question because where we see all the problems today are on CFi platforms. So, I think regulation to the CFi platforms is pretty important. Defi platforms are completely transparent. So, things we talked about like what’s the leverage, what’s the risk and all that, that’s transparent to the user. So that’s a huge positive. What’s a huge issue from a regulatory standpoint is the KYC money laundering aspects of those platforms. So, I do think that a CFi would still play a role being a good gatekeeper of moving assets between CFi and DeFi platforms and having regulators work with CFi platforms to ensure some sort of anti-money laundering standards. Being able to trace sources would be helpful in general.

Nick: [00:29:23] Rahul, do you have anything to add to that from a policy perspective?

Rahul: [00:29:26] I totally agree with Rich. I think what we’ve been discussing thus far is all CFi and a lot of the regulation has been focused on CFi, up until now. I think what we’re going to see is an emerging interest in how do you regulate DeFi. I think it’s a very philosophical question, right? How do you regulate something that’s decentralized when regulation is predicated on a centralized entity that the regulator can regulate? So, I think we’re going to see that conversation evolve over the next few years. But I think, as Rich said, I think, you know, I think the points that we’ve made today are purely on CFi and DeFi as a whole other area of focus for regulators.

Daniel: [00:30:08] I think one way you can regulate DeFi is that you regulate it where fiat goes in and fiat goes out, have gatekeepers there. That’s where banks and financial institutions should actually be there. So, if you put regulations where all the fiat in and fiat out is controlled by a financial institution that’s regulated, you could actually have some sort of gatekeeper for the DeFi space. So, I think that is one of the steps that could be taken to sort of put some form of regulations to DeFi.

Nick: [00:30:46] Great. Are there any other sort of collective actions that the industry might be able to undertake? We’ve seen one suggestion this week from Binance about creating a kind of crypto central bank. What do you think of things like this and not just in terms of institutions, but also in terms of, I think we’ve mentioned a few times today, new standards having an agreed taxonomy. How can the industry come together as one and move forward? And so, we get away from this sort of series of things that happened?

Rich: [00:31:19] I mean, some sort of general industry effort to basically help stabilize the industry. I think that makes a lot of sense. I think what he also actually said that makes a lot of sense is that he said that I believe one of his tweets mentioned that he thinks that that how did he phrase it, that he’s usually kept silent on what he sees as big risks in the industry, but he’s going to change that policy from now on. And I think that us as an industry as a whole should think about ways that we could do that collectively and come together and discuss what’s going on. I do think that in the right circles and the right conversations after everyone shared their stories, a lot of what has happened was not that shocking. So maybe one person didn’t get to see the whole picture, but then you get a group of enough guys, and they talk about what their experiences were. And then you start linking the dots to quite a few things. So, you know, I do think that as an industry coming together regularly to discuss what’s going on, what are the developments and what the risks we see, I think that’s really important. And being able to have a forum to do that, you know, is something that we need to think about.

Rahul: [00:32:38] I think it’s also important to talk about public private collaboration. I think it’s just as important for those that are subject to the regulations. Those of us in this room to be informed of government policy as it is for policymakers to understand the industry that they are regulating. So, we absolutely need strong public private collaboration. And there are already some countries that are leading the way. I think recently the UK FCA hosted two rounds of crypto sprints with private companies, industry groups, as well as other public actors. Ripple participated in this. Other key regulators around the world, we think could think about this model specifically, which allows them to hear directly from people on the ground on how policies are affecting them. And then another option is also innovation sandbox, like one that MAS is already running. If regulators don’t fully understand the use case, an innovation sandbox is a way to test innovation in a controlled environment before introducing it to the public.

Nick: [00:33:35] Daniel, perhaps you could give us your take on where Stablecoins go from here.

Daniel: [00:33:39] You have many types of Stablecoins right? Crypto asset backed, those backed by various types of securities, bonds, etc. And then you have the ones that are backed by fiat. Like what Rich does. And I think that the value would be in those that are really backed by fiat or near fiat. Those are the important type of Stablecoins because, you see up to today most of the use case of those Stablecoins has been to be a medium of purchase in an exchange. But you have not really used many real cases was that. But I think Stablecoins can be used for all kinds of stuff. For example, you can use it for overseas remittances. It can actually replace a cross-border bank. So, these are the kind of things that I would think that it’s there for the future of Stablecoins, and I believe that we’re going to see that use case of Stablecoins pretty soon.

Nick: [00:34:40] Just a question that pertains to your previous answer, Rich, about the industry coming together and actually calling out what they see as excessive risk. The question is, who would be the unbiased observer who can be the one to broadcast the risks to the wider world without it being tainted by the desire to, say, short a position and then buy below?

Rich: [00:35:00] I mean, I think that if a forum like that were to come together, I think there are a couple of names that are emerging this year as people who clearly have a lot of credibility. And I think those people can speak about it publicly. I think that the industry as a whole having a closed-door session about what they’re seeing on a regular basis, I think that will be really helpful. I think it should be closed doors because it shouldn’t be about calling people out. I don’t think people feel comfortable if it seemed as if it was just calling out other players. And so, I think that there are a handful of names. I think we can all think of a couple in this industry that have shown a high level of integrity so far. And I think that they could be great leaders in being able to speak out publicly. But I think that for other industry participants in general, I think maybe a closed-door kind of setting would be useful and maybe publishing comments that are not made or attributed to any specific person would make people be more willing to talk about their experiences.

Nick: [00:36:10] Fantastic. I want to thank you so much for taking time out of your busy, busy week to join us today and discuss these really important issues. I think what has been said has been hugely valuable. Great ideas about how to take the industry forward, how to keep the focus on institutionalization, how to get the right regulation, the appropriate regulations in place, and not overregulate or just replicate regulations and some differing opinions on what those regimes might look like. It’s not just about regulations, obviously. It’s about conduct. It’s about making sure that the use case is one of not just speculation, it actually has some utility. But I think most importantly, there is nothing new necessarily under the financial sun. We have seen these kinds of collapses before. We’ll see them again, different asset classes and every time they’ve come back. So, on that note, I think it’s one of positivity. The industry can only get stronger and get better and we can all rebound and learn from what is going on at the moment. And in a few years, we’ll be laughing about it. I hope.

Russell Goldsmith: [00:37:20] Well, that’s it for this episode of the Knowledge Circle podcast. Thanks once again to our guests, Rahul, Rich, and Daniel and of course, to Nick for hosting. If you enjoyed the conversation, please follow, like and share on your podcast platform of choice. You can find out more at bankingcircle.com. Hope you can join us on the next episode but until then, thanks for listening and goodbye.

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