How 2020 set the stage for the 2021 bitcoin bubble – Amy Castor

I try to read both sides of the crypto story – the believers and the critics. Amy Castor and David Gerard have just dropped a new post offering a detailed update of the argument that a lot of crypto (and DeFi) is mostly a Ponzi scheme.

The TL;DR is “there’s no money left, and no more coming in” according to Amy and David but their long answer can be found here and is (I believe) worth reading whatever side of the debate you sit on.

The post admittedly plays to my sceptical bias on crypto and DeFi but let me know what I am missing.

Tony – From The Outside

P.s. if you want to hear the other side then “The Breakdown”, a podcast by NLW, is one of the sources I rely on.

Two perspectives on crypto – Irony and Optimism

There has been a lot written about the crypto winter but I want to call out two perspectives I thought had something interesting to say.

The irony

One is the ever reliable, entertaining and informative Matt Levine in his Bloomberg Money Stuff column. The nominal focus is the immediate impact on Voyager Digital Ltd but his broader point is that, while crypto started as a response to the 2008 financial crisis and the associated problems with the conventional banking system, one of the more tangible achievements of the DeFi financial system system that has been built on crypto foundations has been to recreate the interconnectedness, leverage and opacity that crypto was meant to replace.

He starts with the theory …

“A Bitcoin is a Bitcoin, not the debt of some bank, so there is no buildup of leverage in the system as investors hunt for safe assets. Crypto avoids the opacity of traditional banks: Crypto transactions occur on an open transparent blockchain; there are no hidden obligations that can bring the system down. Crypto is decentralized and open; “code is law”; mistakes lead to failures, not bailouts. “The basic philosophical difference between the traditional financial system and the cryptocurrency system is that traditional finance is about the extension of credit, and crypto is not,” I wrote earlier this month. 

Matt Levine, “Money Stuff” Bloomberg 24 June 2022

… while in practice …

But the current crypto winter shows that this is amazingly untrue in practice. There is a ton of leverage and interconnection, and who owes what to whom is surprisingly opaque, and when it causes problems it is addressed by negotiated bailouts from large crypto players. Crypto has recreated the opaque, highly leveraged, bailout-prone traditional financial system of 2008.

Matt Levine, “Money Stuff” Bloomberg 24 June 2022

.. and concludes

I don’t know what to make of that. Mostly I just want to say: What an accomplishment! Rebuilding the pre-2008 financial system is a weird achievement, but certainly a difficult one, and they went and did it. One other possible conclusion is that that system was somehow … “good” might not be the word, but “natural”? Like, something in the nature of finance, or in the nature of humans, tends toward embedding opaque leverage in financial systems? Crypto was a reaction against that tendency, but as time went on, that tendency crept into crypto too.”

Matt Levine, “Money Stuff” Bloomberg 24 June 2022

… the optimistic perspective

I don’t want this to be a pile in on crypto so let me conclude on a more optimistic note courtesy of Gillian Tett at the Financial Times. Gillian, like Matt, notes that leverage and complexity are always problematic

“The companies imploding are those that feature one or all of the following traits: high leverage, opposition to regulation, excessively complex innovations and heavy spending on expansion”

Gillian Tett, “Crypto enthusiasts are betting the house on creative destruction” Financial Times 23 June 2022

Gillian however argues that this can be viewed as a healthy dose of creative destruction that is getting rid of the rubbish and allowing better versions to secure their place in the future. She concedes that this may just be “desperate spin” on the part of the DeFi and crypto industry but I do believe she makes a good point.

The individual players obviously do not like it, but every industry benefits from creative destruction and I think there is a pretty strong argument that part of the problem the conventional financial system faces is that it has been shielded from the full force of this process.

I have to confess that it is still not obvious to me what exactly crypto and DeFi will contribute to the future of finance but history shows that companies themselves often stumble on solutions that seem obvious in hindsight but were not what they set out to create. The often quoted story of rise of the personal computer is a case in point (who knew that we all needed one). All we can say at this point is that the current crypto winter is at least increasing the odds that the industry might yet deliver something useful and maybe even revolutionary.

Summing up, scepticism is a pretty sound foundation for viewing most innovations in finance but there is room for a little optimism as well.

Tony – From the Outside

“The basic philosophical difference between the traditional financial system and the cryptocurrency system …”

… according to Matt Levine (“Money Stuff”) “…is that traditional finance is about the extension of credit, and crypto is not”. He acknowledges that this is an exaggeration but argues that it does contain an essential truth about the two systems.

He uses the different ways that crypto approaches money and trading to illustrate his point.

In the traditional financial system money mostly represents an entry on the ledger of a bank. There are ways in which the risk is enhanced but people holding this form of money are essentially creditors of the bank. Crypto, Matt observes, is deeply unhappy with the idea of building money on a credit foundation and he cites Bitcoin as crypto’s attempt to build a form of money not based on credit.

In the case of trading, deferred settlement is a feature of the way that traditional finance operates whereas the crypto trading paradigm operating on a decentralised exchange is based on the principle that trade and settlement occur simultaneously.

Matt goes on to argue …

“Many advocates of crypto like this; they think that crypto’s philosophical uneasiness with credit is good. Money without debt – without fractional-reserve banking – is sounder, less inflationary and safer, they argue; trading with instant settlement is clearer and more logical and safer than trading with delayed settlement and credit risk”

I have to say that, as much as I like Matt’s overall body of contributions to deconstructing finance, I struggled with some elements of this argument. The better crypto analogue for money is I think a stablecoin (ideally one that is at least fully reserve backed and ideally has some capital as well) not a crypto asset like Bitcoin.

That said, the argument that the crypto trading model involves less credit risk than the traditional deferred settlement model does seem broadly right to me. Different context but the fact that bank supervisors have pursued Real Time Gross Settlement (RTGS) models I think illustrates the advantages of real time settlement of intraday credit risk.

There is of course a range of stablecoin business models currently being employed, but it still feels to me that anyone holding a stablecoin is probably still effectively lending fiat money to the stablecoin issuer but without the protections and enhancements that people holding money in the form of bank deposits enjoy.

The inspiration for Matt’s observations on this question was the proposal by Sam Bankman-Fried’s (SBF) proposal for changes that would allow a decentralised form of trading settlement. Matt notes that there are plans within traditional finance to move some trading exchanges to a T+1 model. That would reduce but not eliminate credit risk so the question remains as to whether the simultaneous settlement model proposed by SBF represents the future.

Matt argues that at least one consequence of moving to the crypto trading settlement model is that there will be less room (none?) for people to smooth over technical settlement failures and “market dislocations” or to reverse errors.

“There are debates about whether this is good or bad; simplistically, you’d expect the FTX model to lead to more defaults and liquidations, but for those defaults to be less bad. IN the traditional system, sometimes people will have a “technical issue”, and the exchange will “give the appropriate amount of time not to dislocate the market and create a bigger stress on that”, and it will work out fine – but occasionally it won’t work out fine, and by delaying the exchange will have caused a much bigger problem”

I don’t pretend to know the answers to the questions posed above (I am somewhat biased towards systems that favour resilience over efficiency) but I do think it is an issue that is worth putting on the radar as it plays out.

Let me know what I am missing …

Tony – From the Outside

Crypto sceptics unite

Stephen Diehl has done a post linking to a letter that a group of people working in the industry have submitted to US policy makers regarding how to engage with the crypto and DeFi movement. One of the key arguments Stephen makes is that the term “blockchain” has become so ubiquitous as to be largely meaningless.

My bias is that scepticism is virtually always the right starting place but Stephen notes that crypto scepticism is of course a broad church …

Crypto skepticism is not a homogeneous school of thought, and there is no central doctrine or leaders to this movement other than a broad north star of working to minimize fraud and protect the public from undue financial harm. There are crypto skeptics who think there might be some redeeming qualities in some crypto assets, and there are those who want it all to “die in a fire” and everywhere in between. The guiding principle of this letter is to find a middle way that at least most people can agree on and phrase it in a manner such that it can be best understood by our policymakers, who are deeply confused by even minimal jargon and technical obscurantism.

Countering the crypto lobbyists, Stephen Diehl

For what it is worth, I count myself in the camp who remain open to there being something of substance amongst the hype. Like any debate, the potential for crypto and DeFi to contribute something useful to future of finance can only benefit from agreeing on exactly what is meant by terms we use to debate the merits of the new, new thing. Stephen cites “blockchain”, to that I would add “digital money”.

Tony – From the Outside

Adam Tooze wants everyone to read “The Currency of Politics” by Stefan Eich

I have only just started reading the book myself but the outline that Adam Tooze offers suggests to me that it has a lot to say on an important topic.

At this stage I will have to quote the author for a sense of what this book is about ..

The Currency of Politics is about the layers of past monetary crises that continue to shape our idea of what money is and what it can do politically. Grappling with past crises helped previous theorists to escape the blindspots of their own time. We must do the same today.

This seems like a pretty worthwhile endeavour to me so I thought it was worth sharing for anyone else engaged in trying to make sense of the role that money (and banking) does and should play in our society.

Tony – From the Outside

The elasticity of credit

One of the arguments for buying Bitcoin is that, in contrast to fiat currencies that are at mercy of the Central Bank money printer, its value is underpinned by the fixed and immutable supply of coins built into the code. Some cryptocurrencies take this a step further by engineering a systematic burning of their coin.

I worry about inflation as much as the next person, perhaps more so since I am old enough to have actually lived in an inflationary time. I think a fixed or shrinking supply is great for an asset class but it is less obvious that it is a desirable feature of a money system.

Crypto true believers have probably stopped reading at this point but to understand why a fixed supply might be problematic I can recommend a short speech by Claudio Borio. The speech dates back to 2018 but I think it continues to offer a useful perspective on the value of an elastic money supply alongside broader comments about the nature of money and its role in the economy.

Borio was at the time the Head of the BIS Monetary and Economic Department but the views expressed were his personal perspective covering points that he believed to be well known and generally accepted, alongside others more speculative and controversial.

I did a post back in March 2019 that offers an overview of the speech but recently encountered a post by J.W. Mason which reminded me how useful and insightful it was.

The specific insight I want to focus on here is the extent to which a well functioning monetary system relies on the capacity of credit extended in the system to expand and contract in response to both short term settlement demands and the longer term demands driven by economic growth.

One of the major challenges with the insight Borio offers is that most of us find the idea that money is really just a highly developed form of debt to be deeply unsatisfying if not outright scary. Borio explicitly highlights “the risk of overestimating the distinction between credit (debt) and money” arguing that “…we can think of money as an especially trustworthy type of debt”

Put differently, we can think of money as an especially trustworthy type of debt. In the case of bank deposits, trust is supported by central bank liquidity, including as lender of last resort, by the regulatory and supervisory framework and varieties of deposit insurance; in that of central bank reserves and cash, by the sovereign’s power to tax; and in both cases, by legal arrangements, way beyond legal tender laws, and enshrined in market practice.

Borio: Page 9

I did a post here that explains in more detail an Australian perspective on the process by which unsecured loans to highly leveraged companies (aka “bank deposits”) are transformed into (mostly) risk free assets that represent the bulk of what we use as money.

Borio outlines how the central banks’ elastic supply of the means of payment is essential to ensure that (i) transactions are settled in the interbank market and (ii) the interest rate is controlled …

“To smooth out interbank settlement, the provision of central bank credit is key. The need for an elastic supply to settle transactions is most visible in the huge amounts of intraday credit central banks supply to support real-time gross settlement systems – a key way of managing risks in those systems (Borio (1995)).”

Borio: Page 5

… but also recognises the problem with too much elasticity

While the elasticity of money creation oils the wheels of the payment system on a day to day basis, it can be problematic over long run scenarios where too much elasticity can lead to financial instability. Some degree of elasticity is important to keep the wheels of the economy turning but too much can be a problem because the marginal credit growth starts to be used for less productive or outright speculative investment.

This is a big topic which means there is a risk that I am missing something. That said, the value of an elastic supply of credit looks to me like a key insight to understanding how a well functioning monetary system should be designed.

The speech covers a lot more ground than this and is well worth reading together with the post by J.W. Mason I referenced above which steps through the insights. Don’t just take my word for it, Mason introduces his assessment with the statement that he was “…not sure when I last saw such a high density of insight-per-word in a discussion of money and finance, let alone in a speech by a central banker”.

Tony – From the Outside

Why Canada is cultivating an M-pesa moment for bitcoin – Izabella Kaminska

Izabella Kaminska is one of the commentators that I find reliably generates interesting and useful insights. Personally I remain sceptical on crypto but this link takes you to a post where she makes an argument that I find persuasive.

For those short of time here is an extract capturing the key points I took from her post…

My position on crypto has evolved over time to appreciate this factor. Crypto may not be an optimal system. It’s clunky. It’s energy intensive. It’s confusing. But as a back-up system for when the shit really hits the fan, it’s an incredibly worthwhile system to have in place and I increasingly think we should be grateful that some deep-pocketed individuals with concerns for freedom and privacy took the risks they did to make it become a thing.

I have in the past compared crypto to a monetary equivalent of the right to bear arms, whose main purpose, many argue, is to act as a deterrent to rising authoritarianism. Its optimal deployment is as a right that it is never actually exercised.

Crypto should be treated the same way. On a day to day basis, it’s much better for us all to trust in a centralised and properly supervised system. But having crypto there as a challenger or backup system is no bad thing. It should in theory enhance the core system by helping to keep it honest and working in our interests.

“Why Canada is cultivating an M-pesa moment for bitcoin”, The Blind Spot 18 February 2022

Tony – From the Outside

SWIFT gpi data indicate drivers of fast cross-border payments

One of the use cases for cryptocurrency and\or stablecoins is that it offers cheaper and faster alternatives to the conventional payment rails. Whether they will succeed remains to be seen but I have long believed cross country payments is one of the areas where the banking system really does need to lift its game.

Against that context, this research study released by the Bank for International Settlements (BIS) suggests that TradFi banking is making some improvements.

The study lists three key takeaways …

“- The speed of cross-border payments on SWIFT global payment innovation (gpi) is generally high with a median processing time of less than two hours. However, payment speeds vary markedly across end-to-end payment routes from a median of less than five minutes on the fastest routes to more than two days on several of the slowest routes.
– Prolonged processing times are largely driven by time spent at the beneficiary bank from when it receives the payment instruction until it credits the end customer’s account. Longer processing times tend to occur in low and lower-middle income countries, which can be partly attributed to capital controls and related compliance processes, weak competition as measured by the number of banks as well as limited operating hours of and the use of batch processing by beneficiary banks.
– Cross-border payments on SWIFT involve, on average, just over one intermediary between the originator and beneficiary banks. Each additional intermediary prolongs payment time to a limited extent, while the size of time zone differences between banks has no discernible effect on speed.”

If I am reading it correctly, the study does not capture any delays the initiating bank may introduce before it processes a payment instruction. With that caveat, it is worth noting that TradFi is not standing still – competition can be a beautiful thing.

Also worth noting the extent to which domestic payment systems are improving though not necessarily in the USA.

Tony – From the Outside

The future of stablecoin issuance appears to lie in becoming more like a bank

Well to be precise, the future of “payment stablecoins” seems to lie in some form of bank like regulation. That is one of the main conclusions to be drawn from reading the “Report on Stablecoins” published by the President’s Working Group on Financial Markets (PWG).

One of the keys to reading this report is to recognise that its recommendation are focussed solely on “payment stablecoins” which it defines as “… those stablecoins that are designed to maintain a stable value relative to a fiat currency and, therefore, have the potential to be used as a widespread means of payment.”

Some of the critiques I have seen from the crypto community argue that the report’s recommendations fail to appreciate the way in which stablecoin arrangements are designed to be self policing and cite the fact that the arrangements have to date withstood significant episodes of volatility without holders losing faith. Market discipline, they argue, makes regulation redundant and an impediment to experimentation and innovation.

The regulation kills innovation argument is a good one but what I think it misses is that the evidence in support of a market discipline solution is drawn from the existing uses and users of stablecoins which are for the most part confined to engaged and relatively knowledgeable participants. This group of financial pioneers have made a conscious decision to step outside the boundaries of the regulated financial system (with the protections that it offers) and can take the outcomes (positive and negative) without having systemic prudential impacts.

The PWG Report looks past the existing applications to a world in which stablecoins represent a material alternative to the existing bank based payment system. In this future state of the world, world stablecoins are being used by ordinary people and the question then becomes why this type of money is any different to private bank created money once it becomes widely accepted and the financial system starts to depend on it to facilitate economic activity.

The guiding principle is (not surprisingly) that similar types of economic activity should be subject to equivalent forms of regulation. Regulatory arbitrage rarely (if ever) ends up well. This is a sound basis for approaching the stablecoin question but it is not obvious to me that bank regulation is the right answer. To understand why, I recommend you read this briefing note published by Davis Polk (a US law firm), in particular the section titled “A puzzling omission” which explores the question why the Report appears to prohibit stablecoin issuers from structuring themselves as 100% reserve banks (aka “narrow banks”).

4. A puzzling omission.

By recommending that Congress require all stablecoin issuers to be IDIs, the Report would effectively require all stablecoin issuers to engage in fractional reserve banking and effectively prohibit them from being structured as 100% reserve banks (i.e., narrow banks9) that limit their activities to the issuance of stablecoins fully backed by a 100% reserve of cash or cash equivalents.10

The reason is that IDIs are subject to minimum leverage capital ratios that were calibrated for banks that engage in fractional reserve banking and invest the vast portion of the funds they raise through deposit-taking in commercial loans or other illiquid assets that are riskier but generate higher returns than cash or cash equivalents. Minimum leverage ratios treat cash and cash equivalents as if they had the same risk and return profile as commercial loans, commercial paper and long-term corporate debt, even though they do not. Unless Congress recalibrated the minimum leverage capital ratios to reflect the lower risk and return profile of IDIs that limit their assets to cash and cash equivalents, the minimum leverage capital ratios would make the 100% reserve model for stablecoin issuance uneconomic and therefore effectively prohibited.11 It is puzzling why the PWG, FDIC and OCC would recommend a regulatory framework that would effectively require stablecoin issuers to invest in riskier assets and rely on FDIC insurance rather than permitting stablecoins backed by a 100% cash and cash equivalent reserve.

This omission is puzzling for another reason. There has long been a debate whether deposit insurance schemes or a regime that required demand deposits to be 100% backed by cash or cash equivalents would be more effective in preventing runs or contagion. Indeed, the Roosevelt Administration, Senator Carter Glass, a number of economists and most well-capitalized banks were initially opposed to the proposal to create a federal deposit insurance scheme in 1933.12 Among the arguments against deposit insurance are that the benefits of deposit insurance in the form of reduced run and contagion risk are outweighed by the adverse effects in the form of reduced market discipline resulting from the reduced incentive of depositors to monitor the financial health of their banks. This reduced monitoring gives weaker banks more room to engage in risky activities the costs of which are borne by the stronger and more responsible banks in the form of excessive deposit insurance premiums or by taxpayers in the form of government bailouts.

In a competing proposal that has come to be known as the Chicago Plan, a group of economists led by economists at the University of Chicago argued in favor of a legal regime that required all demand deposits to be 100% backed by a reserve of cash or cash equivalents.13 Proponents of the Chicago Plan argued that it would be more effective in stemming runs and contagion than the proposed federal deposit insurance scheme, without undermining market discipline or creating moral hazard. The Chicago Plan would have been analogous to the original National Bank Act that required all paper currency issued by national banks to be fully backed 100% by U.S. Treasury securities. The Chicago Plan was ultimately rejected in favor of the federal deposit insurance scheme that was enacted in 1933 not because it would have been less effective than deposit insurance in stemming runs and contagion, but because it was viewed as too radical. Policymakers feared that by prohibiting banks from using deposits to fund commercial loans and invest in other debt instruments, the Chicago Plan would have resulted in a further contraction in the already severely contracted supply of credit that was fueling the great contraction in economic output that later became known as the Great Depression.

It is understandable why the Report does not recommend prohibiting IDIs from issuing, transferring or buying and selling stablecoins that represent insured deposit liabilities. What is puzzling in light of this history, however, is why the Report would effectively prohibit stablecoin issuers from structuring themselves as 100% reserve (i.e., narrow) banks that limit their activities to the issuance, transfer and buying and selling stablecoins fully backed by a 100% reserve of cash or cash equivalents.

“U.S. regulators speak on stableman and crypto regulation” Davis Polk Client Update, 12 November 2021

I am open to the possibility that the conventional bank regulation solution was unintended and that a narrow bank option might still be on the table. In that regard, I note that Circle has been pursuing the 100% reserve bank option for some time already so it would have been reasonable to expect that the PWG Report to discuss why this was not an option if they were ruling it out. The value of the Davis Polk note is that it neatly explains why being required to operate under bank regulation (the Leverage Ratio in particular) will be problematic for the stablecoin business model. This will be especially useful for those in the stablecoin community who may believe that fractional reserve banking is a free option to increase the riskiness of the assets that back the stablecoin liabilities.

But, as always, I may be missing something…

Tony – From the Outside

Self regulation in DeFi

This article in Wired offers a useful summary of how some motivated individuals are attempting to use the transparency of the system to control bad actors.

It is short and worth reading in conjunction with this paper titled “Statement on DeFi Risks, Regulations, and Opportunities Commissioner Caroline A. Crenshaw that sets out a US regulator’s perspective on the question of how DeFi should be regulated. This extract from the paper covers the main thrust of her argument in favours of formal regulation

While DeFi has produced impressive alternative methods of composing, recording, and processing transactions, it has not rewritten all of economics or human nature. Certain truths apply with as much force in DeFi as they do in traditional finance:

– Unless required, there will be projects that do not invest in compliance or adequate internal controls;

– when the potential financial rewards are great enough, some individuals will victimize others, and the likelihood of this occurring tends to increase as the likelihood of getting caught and severity of potential sanctions decrease; and

– absent mandatory disclosure requirements,[10] information asymmetries will likely advantage rich investors and insiders at the expense of the smallest investors and those with the least access to information.

Accordingly, DeFi participants’ current “buyer beware” approach is not an adequate foundation on which to build reimagined financial markets. Without a common set of conduct expectations, and a functional system to enforce those principles, markets tend toward corruption, marked by fraud, self-dealing, cartel-like activity, and information asymmetries. Over time that reduces investor confidence and investor participation.

Conversely, well-regulated markets tend to flourish

“Statement of DeFi Risks, Regulations and Opportunities” by Commissioner Caroline A Crenshaw, The International Journal of Blockchain Law, Vol. 1, Nov. 2021.

Tony – From the Outside