GENIUS Act vs. MiCA: Comparing US and EU Approaches to Crypto Regulation | EBC11

So welcome everyone to our next panel. So don't just look for the needle in the haystack by the whole haystack. Today we are going to find maybe the needle in the hay stacks or some of them because what we are very passionate about in this panel is to find the like the details because the devil is in the details. So genius act and micica regulation is our topic today. differences.

We're going to talk about this focus of the different regulations, the scopes of it, the implementation and everything that is around like the differences but also the commonality maybe. But before we get started, I would just like to introduce my beautiful panel and they will introduce themselves by just telling who they are and what they are doing like in the space and the role. So hit it up.

Um hello everyone. Really happy to be there. Thank you very much for the invitation. So I'm head of public affairs for Mofu which is the second biggest uh defy lending protocol in the world and I am the co-founder of the uh professional body of web players in France and Europe Adan. Hope you know hope you know them and uh really happy to discuss this very important topic about regulations because I I am actually passionate about the regulatory developments around web three.

Um hello uh super glad to be uh to be here in this uh in this panel. I'm in charge of legal affairs for the core team behind car protocol and car swap. Um uh we are actually a DEX aggregator for those who know uh we have a very nice moo sound when you swap. Um we are a leader in uh in our domain. Our references are actually uh Vitalik himself, the Ethereum Foundation but also World Liberty Finance that are using uh Kwap to uh to settle their trades.

Um yeah, thank you.

Hello, I am Ana Olivera. I am chief compliance officer at Ben. We are a young startup here in Barcelona. We are Spanish company and we aim to go global soon. My role I had the task to help the team to get the Mika license.

So it was a nice interesting journey and we are waiting for the final decisions. We are almost there.

Hello everyone. Nice being here. So my name is Karula. I'm managing partner at WIPO. BIPO is a law firm standing for you which is all you here and PUG is for partner of game changers.

So you know which industry we are advising. So we are advising game changers and my personal field of expertise is regulatory law. I love to help business models to act compliantly in the European market because we are based in Europe mainly in Germany and in the UK.

Super. So now everyone in the audience know how is the sound back there because it's very difficult to please raise a hand if you find that the sound is good enough because otherwise we will uh bring the microphone closer. Okay, perfect. So uh just to set the scene, I'm sure that a lot of the people in the audience know already about the regulation and the Micah and Genius Act, but still for the ones who don't know all the details, I'll just sum up that we are talking about Genius Act, which is one of three regulation or federal laws that turned into force in the United States this year. And we're talking about Micah, which is the regulation for the EU, which also turned in full force like last year.

Um, and the way to the regulation was quite different because it actually took like two months for the US to pass the the Genius Act, which is one of three. We've got the Genius Act, which is the stable coin regulation that we are going to talk about today. then the Clarity Act which is the next US regulation coming up and then the antitrust act later on but Micah regulation was and maybe it's somehow saying about the way that the EU is working was actually like discussed in 2020 and uh still it took some more time than the United States too but let's dig into the scope to begin with would you just just talk about like the uh yeah the scope of the regulations the differences and what you see. So yes, as you said, Mika is a very largest regulation if you compare with the Genius Act. If you take Mika, Mikas, the goal was to implement a regulation for markets in crypto assets in Europe.

And when you are speaking about crypto market and market um if you take Mika, you are covering both the issuance of those crypto assets and the secondary markets and the issuance is about crypto assets which are not stable coins and stable coins. Um if you take genius we are not at all uh on the level of the secondary market. Genius is really about the issuance of stable coins. So even on the level of the markets which are covered it's very different. Also on the crypto assets which are covered it's very different.

If even if we are dealing with stable coins in both Mika and Genius, the scope of the stable coins covered by uh Genius is really smaller because it's uh really focusing on the payment stable coins which are fiat collateralized. If you are looking at Mika, you have and I won't go into technical too much technical details but you have two categories of stable coins. Um well you you can have rules different if you are in face of a payment stable coins of an investment stable coin and at some point we told European institutions it it can be a bit difficult to distinguish or to to to make a clear categorization and uh you in Mika you also have the crypto collateralized stable coins and coll um um stable coins collateralized with other things and fiat currencies which are covered in genius the question is raised because even if genius news does not cover those uh nonfiat collateralized stable coins. It's already written that there had to be a deeper analysis to see if there will be another frameworks or new rules for those stable coins. So in a nutshell, if you take genius, you are really uh on a very specific uh um layer of the market, let's say to the issuance of uh payment stable coins.

Um and you are you have some um first ideas around what could be uh the services on those stable coins and the rules that can uh arrive for the um um crypto markets providers uh doing custody doing exchanges doing other services. But it will be the point of uh other regulations to deepen those requirements and it will come afterwards maybe quite uh quite rapidly because we saw uh how long it was to to make genius appear and actually it was not that long. So we have to stay tuned because it will be uh actually in the coming months and years that we will have more clarity about that. So in terms of the way to get there, it's often like the objective of the law that is actually pushing people to get together and then either it's like we need to solve this now or we're going to like take more time. So in terms of the different objectives from the different laws, so even though Micah is covering a lot more uh than the Genius Act, can you say something about the objectives of the law?

What was like the intention? what did they want to fulfill when they do it? Um yes uh of course if we uh if we think about uh about uh the differences we can see the traditional uh differences between the EU and uh and the US where the um the European Union will look more conservative and looking into um not only regulating the assets themselves but protecting the sovereignty of uh of the EU. um in regard to um to crypto assets. Uh and this is why as Fing was saying, Mika is quite wide on on stable coin and uh and on everything that can be seen as a as a stable coin and and here I would almost say that this uh this uh has been somehow planned uh or at least is in the spirit to be able to push proper uh CBDC uh in the in the EU.

So control the the market of private money just to make sure that public money uh remains remains here. So the objective here is very conservative is for Europe to try to um to protect the the euro system uh against external actors uh but also against private European uh actors. If we if we look at at the Genius Act, it's slightly different in the sense that the Genius Act uh will focus on payment stable coin with quite strict um obligations for for issuer. There's no doubt here. However, uh the fact that they are um excluding the non-payment stable coin uh as for now at least uh shows that the US wants to uh to leave a little bit of um uh room for for innovation and the strategy behind the the Genius Act is quite uh quite clear with the new US administration.

The idea is just to uh make sure to reinforce the position of the US dollar as a global currency and there is absolutely no doubt here and they are heavily relying on private actors uh that are issuing their their stable coin but also leaving once again room for innovation in case some other form of stable coin can at the end of the day be um be used and and and yeah I think Uh I think this is classic uh dichotomy between uh the US and uh and the EU.

Gola, you were nodding a bit. Do you have any like uh supplement things to add to this that is telling us?

No, I think he said it out already perfectly. But I think the big difference is that the idea of mika has different angles and one of the angles is of course uh financial stability and I think the basic line for the genius act I'm not talking about clarity act because I think if you limit it to genius act it's just stable coins let's wait and see how the regulation will look like under clarity act because for everyone maybe just two sentences clarity act then tries to put things in different boxes. So these commodities like bitcoins, east etc. will be regarded as commodity and um regulated under the CFTC. So it's then just a commodity with very limited regulation because it's more a self-regulation system as commodities are regulated in the US generally.

But it is a regulation and then it comes to tokenized securities which will of course be regulated as securities. So I think therefore let's wait and see. But when it comes to the genius act, it's quite clear that they wanted to push innovation through the door. And um I think when it comes to the US kind of mixture between personal interests of some members, [laughter] I think it might have a reason why it was pushed so quickly. But let's not discuss about politics.

But I think the angle is different. It's more about innovation and pushing through this US dollar dominance FU has said and less this kind of financial stability mindset as was one of the main goals within the EU. It seems in terms of the uh like future outlook from the United States that they were actually not just forced but actually had to like change their mindset and and you told me earlier today before we went on stage that you were actually like at US company right when they had like the former administration and uh so can you tell us a little bit about how it was to be like in the middle of everything and the change

that will be a bit of a back the scenes know before joining I was working for a law firm in the US that was trying to bring US companies to Europe and for the American culture, the way they do business there, Mika was way too complex. It was like too expensive, too many demands and for them it was basically um not interesting enough, you know, all all the the bureaucracy, but they were actually going away from the way that the supervisors were acting there, you know. So in the end of the day um Nika represented for them something that is very natural for for Europeans you know this legal clarity foreseeability proportionality things that we discussed theoretically and then for them it's like when they see when they saw the let me allow me to say the chaos that was the Gary Gensler SEC and the legal demands that they were facing then this foreseability, clarity, it starts to look interesting and then they were shifting to to Europe and then that created also for them that was a big um complaint from companies there that during this specific moment they were losing a lot of brains. They were losing developers, they were losing investment because big funds and also brains were just afraid of doing business there. So it they were they were shifting to Europe in terms of uh we were talking about details.

So let's dive into the details of the the differences that are in there. Um so I have noticed some of them and uh you can uh just chip in with other ones. So there's the reserve requirement who can actually issue um a stable coin. So if we just take some of them yeah [laughter]

I can take the the reserve because for um it was a bit of a discussion internally in Venga about the asset reference tokens. So we we we needed to delve a bit deeper there and Genius Act is like super clear you if you want to issue a payment stable uh coin you need to have parity oneonone so it needs to be 100% backed by US dollars or treasury bonds or a public debt from the USA to use an expression that we are here in Mika we have what we know the e-money uh EMT e-money tokens and asset reference tokens. I think at this point in time we we are very acquainted to what it means e- money you need to have an EMI license to operate to that it needs to be liquid you need to have your deposit a funds deposit also in a banking institution and for art we would think about a proportion of your funds in euros or any fiat currency plus bonds treasury and you can also still have like an algorithm that keeps the the balance in this reference token. But what I if you allow me, what I would really want to bring like to spice up uh a bit this discussion is that why is this uh happening like this in the US you know because they are bringing the the fact that they are demanding 100% liquid parity this um you cannot um charge any fees for withdrawing and it needs to be instant but Why only US dollars and why only Treasury bonds? Because in the end of the day, if you want to issue uh payment stable coin in the US, you need to buy treasury bonds.

So that means that if you have a huge depth in your country or you have a problem with liquidity or if your currency if the US dollar is losing dominance in the global market because any other political issue what that means is that it will force companies to buy your public debt buy uh US bonds and bring dollars back to US banks. So this is very interesting from this point of view. In my opinion, very humble opinion, Genius Act is nothing to do with crypto. Genius Act is about keeping the US dollar dominance in the world and making US dollar universal in the crypto space. But it's not about them thinking about innovation, regulation of crypto, etc.

Okay. So, it's about like uh the uh the overall society and not and not about maybe the consumer. So what about the protection of the consumer because we if we are thinking about shifting over to a new like era

I wanted to go back on the point of the entities which are allowed to issue stable coins because it's a very very big point and the crucial difference between genius and mika if you take Mika the approach was only incumbents because they would be authorized as credit institutions or uh eony money institutions would be allowed not to issue stable coins. So at the time when Mika was discussed um there was no really um um understanding a not good understanding of the reality of the markets willing to issue such stable coins because if you go back in between 2018 2020 in Europe um those willing to issue stable coins were more than newcomers um which has projects. Uh at that time I was working at consensus uh and there was a big retailer big group willing to issue his own stable coin. Um when we were talking with banks well it was not really a topic. So it has been decided in Mika to have this narrow scope of incubance be being allowed to to to issue those stable coins and it makes makes it very difficult for newcomers um to to to to comply with those rules.

Uh that actually that was the intention. If you take genius, it's very different. So you have very different level of financial institutions and banking institutions uh which are uh supervised at different level of the of of the US being allowed uh to to to to apply to issue stable coins. But you also have non-banks and that's really um clearly written non-banks being able to get authorized to issue stable coins if they comply of course with the requirements of of Genius. So it really shows that there is a a very different understanding in uh what is the reality of market and also who we want to make this market grow and in the US there is really no reluctance in the fact that they could be uh newers and actually if you are looking at the main players I'm thinking about circle I'm thinking about t they they are not the current financial institutions that we know so it's a very crucial difference because it makes also very clear about the intention that we already discussed uh in between Mika engineers.

The goal of Mika being to really prevent from the development of the ecosystem of stable coins and not to encourage it with the reality of markets of market participants willing to do so. Um and regarding the entity there was maybe and I will be quick another point that is interesting to raise. Uh the by default rule in Genius is that if you are a foreign issuer you are not allowed to issue stable coin dollar. And I think it's important to show that in the context of GUC US were much more uh interested and they they did take care of protecting their markets. Why in Mika it's very different.

Uh there is no that much protection of our our uh actors our markets and it makes it really easier for foreign players to be able to issue stable coins in Europe. Um so I think it will be interesting to see in the coming developments what will be the regulatory regimes that the US will consider as equivalent to uh to to favor the fact that proins issuer can issue stable coin uh dollar in the US but at this time the by default rules is that if you are a non US uh based entity you cannot and I think it's uh it's also a very uh pragmatic approach of the US um in their uh uh a willingness to develop a a very powerful US ecosystem of stable coin dollars.

Do you have any like comments on the fact that uh if the Genius Act is not taking into consideration the protection of the consumers but they are really pushing and everyone could do it. So any comments on the what do you think is a better way to go?

I know the sound is not that good here up here.

Thank you. Um so no actually actually the the genius act uh does uh protect uh quite uh quite well. Um in case uh in case an issuer fails for whatever reason the genius act will uh make sure that uh the users are made um prioritary uh to get back their uh their assets. So that's also a difference with uh with um with Mika where um it's a more broad consumer protection regime that applies to um to users. Uh however um there is not that financial priority uh given to uh to them uh to protect them against any market uh event.

Um I think this is quite uh quite interesting also because this will provide uh a lot of confidence in [snorts] the US stable coin uh market and um and user will be more attracted because they can feel more protected uh against uh any event like we may have seen in the in the past.

So you uh have been advising companies. So if I was a new company and I wanted to go into the US or to Europe, what would you say like what is going to be like the main concerns for this company? So currently I would say there is still a bit of advantage in Europe because we have certainty and even if people say yes it's complicated and what you said might be a bit difficult. So having achieved advising companies like Coinbase, Bullish and others to enter the European market, I think it's the way of how you approach them and I think currently it is still an advantage that you have full full certainty. Clarity is so connected to the clarity act now you have full certainty what is happening in Europe.

You have a set of documents now which goes beyond Mika. So it's also all the level two um regulatory technical standards in place now. So you really know in detail what's coming up. Of course there are still some open questions because there are coming up points nobody has thought of when drafting Mika but nevertheless it's quite sure what you have to go for when you would like to set up a company here. And then you have this um advantage that whenever you have an HQ in one of the European 27 countries, of course you can easily passport and passport means you just notify your home regulator that you would like to passport your services and we talk about services and assets.

So I think that's also one advantage because if you set up for example a crypto exchange or if you set up a let's say it carefully in Europe you certainly know what's coming up and then you can passport your services so your MTF trading platform services custody services everything connected to that into the European market wherever you want to and I think doing that currently is an advantage and I think that was the reason why previously the companies prior to Mika, I think only Germany had a regulation for crypto assets and they deliberately came to Germany because of that certainty and these are one of the first movers now with Mika licenses because of having the German license it was easy to transpose them into a Mika license because as you said uh and also for said the requirements are very similar and for Europeans very similar in particular to financial instruments which is interesting to know because therefore if you want to do pers and other things which would be governed by miit 2 later on it's not so hard to jump from one regime to the other because it's very regulated in a very similar way and so this is a very big opportunity of the mika regulation to have this passport and that's why it's a it's a very big problem when you have local regulators like the French uh the uh Italian and I think the Austrian or I think the Austrian ones altogether decided to say we are not sure that we will grant the passport even if you have Mika compliance uh entities coming from other countries because it's it makes the uncertainty for actors on this very big advantage which was the passport so it's really annoying we are we we we had the uh with this passport the um the opportunity to to grant an advantage that they did not have with regulation and actually I think that if you ask obliged entities what are the advantages of being uh compliant with regulation there are not a lot of experted passports so there is currently uh so that that's why I call your attention a very big problem in the u um in the approach of some local regulators which would like uh not to grant this passport uh and to make the life of the companies which are currently struggling with such compliance even more difficult and with even more incentive at the and to be compliant.

Yes. Because that's right where we have are right now. So we have the regulation and it's supposed to be like the same regulation and the same way of interpretation in each member state. But yet we see that there are different times where it turns into false like it could be up to 18 months of difference from one country to another. We have like some of them are like the regulation translated into is like 30 pages other ones are like 80 pages or even more.

So something is like not like completely one to one and if we do have a passport which is in theory like a very nice thing to have but everyone needs to accept that the passport actually like uh

one small word and I

comment on that [laughter] we have countries advising on fasttrack ma license cannot close our eyes to that the biggest advantage of mika is passporting you do the license one you pay for it once and you access the market

but you cannot advertise on fast track but we do see that people like were they applied in France for example and then suddenly they withdraw their application for MA and then they went to Malta

yeah I would say that that's not because they wanted to go to Malta it's because they wanted to go to France and that they did not get the answers that they wish to get and I I mean if you are looking at the list of the today CASSP which are registered under the MA regulation. The point is not that Malta is giving lots of authorization because it's not the case. If you take the French authorities and the Matan authorities, it's they barely authorize the same numbers of Casper in between five and seven I think something like this. The biggest providers of authorization today is Germany for example. So the the problem that is raised is not one I mean Malta is not giving free passports to lots of companies.

uh well they there are some uh some uh process of scrutiny by ESMA on some precise topics but the problem of uh those actors that they they wanted to come to France is that they fought and they were right that they wouldn't have not enough resources and that the delays would be too long to get authorized and so to be able either to launch or to continue their activity and at the end that's what actors want to know is they want to know when they can launch their activity they want to know until when they will be able to to to keep on doing this activity um and their choice will be to the most efficient regulators. So it could be mata but actually it can be Germany if you are having a list a look at the list. So it's really it's really annoying because the message that is provided and I understand why regulators want to to to to share this message that that the photo actors they decide to go to Malta. French actors they are currently struggling with French authorities they they are not going to Malta. They do want to to to be compliant under the um uh with the with the French authorities.

They they did not go to Malta. they would they want to stay in France but it makes their life really really uh more difficult

maybe one point to add I think that's important to see but what we have to also know is that in the first stage you have always these differences so I have the advantage of being a bit older so I know the pre mika one world which was 25 years ago and when Mika 1 and Mika 2 was implemented it was a bit the same you had these differences is all over and I think that's exactly what we experience now again with Mika but in a certain point in time we will have at least a certain standard we have these ESMA papers these ESMA Q&As so we get more and more certainty and there will be more and more clear guidances for all the European regulators because I'm totally agree with you we do see these differences but I just wanted to point out it's normal early stage to see these differences and I think we will overcome them. And because you ask about the US, it's not that the US is easier because we have a federal level just for stable coins. We don't talk about the other services. If you want to issue stable coins, it depends on thresholds whether it's done just on a state level. When it's above [snorts] 10 million, it's on a um federal level.

You can opt in also for a federal level. Of course, if you are below this threshold, but there are all different kind of regulations. Yes. Anyways, so it's not that it's easier in the US that you just send in once. And when you talk about different states, so if you talk about the US states, Wyoming, it's very different from New York because New York is like

a French license for example. Why? Wyoming, it's maybe closer to Cypress and Malta. But you do see these differences as well. And I think that we in Europe have a lot of experience in kind of bringing things closer together again due to these ESMA guidances.

So ESMA is the European authority. So European security market authority and I think that we have ways to kind of overcome these broad differences and some will remain and then investors will decide. If you look into the more institutional world they don't opt for Maltese entities. they tend to opt for French, Italian, Spanish, German ones, Dutch ones.

So different scope, a different objective, different way of implementing. No one not not one is easier than the other one maybe but for all of you like here on the panel for the next five years which of the Europe might be a bit uh in front at the moment but for the next five years where do you see like the whole industry evolving in terms of both innovation but also protection of both the industry but also the consumer. So Gola, do you want to start and then we can

So I think the industry overall in Europe won't change too much. It's betting to go regulation better. Uh in five years time, maybe not, but in 10 years time I would say we converge more and more the classical financial services world and this kind of crypto assets world. Um I I think that also overall on a global level uh Europe and the US will kind of align and I think one big portion of that is how the clarity act will look like in the end and what is regulated. Um so I think in Europe we will have of course um new coming up laws like uh Mika 2.

0 because there are defy world is not regulated. We didn't have the point or the time to touch that point because it's about decentralized world which is not really regulated in Mika. We will have clarity on that. But overall I think um the US and Europe probably will somehow align because I think it's difficult otherwise uh to do trades on a global level.

What I would say is that also Mika is being used as a template for a lot of jurisdictions in the world. So maybe in a couple of years from now we will have a more harmonized system internationally. So we might see Latin America, Mexico, um Africa, we we might see a lot of countries uniting like we saw in AML regulation over the 20 years, you know, like we saw in banking regulations, IBN Swift systems, you know. So I think that that will make our lives as compliance officers easier as well, you know. And one thing that uh we didn't mention until this point and I think it that would be also um turning point is how the national competent authorities and EU EU supervisors are acting.

So a a lot of the discussion to create the genius act and the clarity act is this chaotic interpretation that they have from the supervisory agencies there and fines and you have no uh clarity on what's to come if you're a big exchange and in that sense I feel very proud of asma you know it's difficult to read and understand all the regulatory technical standards but I think they are setting a very very good base in the sense that it's not only the law but is also how this law is being applied in in all those countries and I think as we evolve we will see also regulators gaining experience and um applying this regulation even clearly and I think it then we will have innovation in Europe you know because we will know okay this is not securities you don't need a broker license still you can have this token listed in your in your company you know that will come and [laughter] I would be happy to see it. Your thoughts?

Um, so for the next next uh next five years um if I look if I look at uh at Mika uh I'm pretty sure I'm not worried about incubants and institutions because this regulation has been uh really tailored for uh for them. Um I would be bit more worried about uh defy project uh because um there is this uh uncertainty about defy what is uh what is decentralization what is inter intermediation and and Europe is not really giving good signal to um to to defy uh products while actually let's be uh completely clear and honest um defi are the one innovating in this field. I mean it's our field um while uh so let's see the if and when uh Mika 2.0 zero uh how how this will uh this will go while in the um in the US there is still that uh wait and see uh policy of uh of the US legislature even though these future acts are are coming but it seems that uh that up to now defy is a bit more um accepted as an innovation uh vector for the whole um whole market and and ecosystem and that the US will really want to uh to rely on on DeFi for the future of their uh their economy. So let's see uh let's see what happens.

uh just uh hope that uh European regulator will uh leave more room for uh for innovation in term of stable coins but also in term of uh of other product because we really have a lot of things to bring to uh to this market. We have a lot of things to bring to institutions, products that they have like no idea about and and this is uh this is really important. I think uh I think talking for for D5 product we really need to uh to fight hard to uh to get there. Yes, I I will also jump in D5 because uh uh it's already scheduled at least in Mika that there is a work to be done by the European Commission for both a definition of what is fully decentralized and that's actually making the life a bit uncomfortable right now for D5 protocol because we can imagine tomorrow if there's a strict understanding of what is fully decentralized that at the end there are defy protocols falling into Mika in a a second second stage. So uh we know there is there is this work coming from the European Commission also the analyzes on whether it is feasible and necessary to regulate DeFi and it's a really from scratch work because that's how they understand DeFi and that's why they decided that Mika could not cover DeFi.

It's because the rules of intermediaries which are the targets of Mika cannot apply in the word of D5 protocols. Fortunately, right now the position of the European Commission is that we are not in a rush to regulate DeFi. So it's it's uh it does not mean that uh we need to wait for that. Uh to the contrary and that's why actually I've joined more uh it means that we have the time to prepare this regulation in cooperation with public policy makers at the level of member states because they are involved in developing uh European regulations and at the level of European institutions. So th this will be really key questions uh in the strategy and the speeches that we can have in the US around D5 at the moment it's it's quite positive they are really positive but I don't know if you had a look uh last week there was a leaked proposal uh of defy regulations from the democrats and NATOs which was quite awful because actually the goal was to reintermediate defy protocol and to qualify them as digital asset intermediaries.

is and that that's actually the main risk tomorrow if we do not work with policy makers in order to make them understand that we are not in the word of intermediaries and that we cannot be covered by the current regulations and that we do need a proper one and I think that what will come to the mind really quickly just to find to for the final word is that it will be really more easy for regulators to understand how to regulate the interactions between TRFI and DeFi because the word of TRFI and the word of intermediaries is much more familiar to them and what we see is a development of more and more uh integrations of defy protocols by uh third parties. So that was the the the recent news at Moro with social with so with Coinbase etc and reg for for regulators it will be much more tangible and easy to see how they can add requirements to those people in their interactions with DeFi. Super we have this time to that would be the final words because we'll have to leave the stage for something else. But a lot of things are on our minds. We have a lot of opinions and we hope that you enjoyed our conversation around the Genius Act and the uh Micah as much as we did.

Thank you to my wonderful panel.

Thank you. One