‘This Is Not the End of Crypto in the United States’ - Ep. 504

Transcript

foreign welcome to Unchained your no hype resource for all things crypto I'm your host Laura Shin author of The cryptophans I started covering crypto eight years ago and as a senior editor at Forbes was the first mainstream media reporter to cover cryptocurrency full-time this is the June 9th 2023 episode of Unchained secure your crypto accounts with a secure email service protonmail is end-to-end encrypted meaning that no one not even proton can access your emails go to proton dot me slash Laura copilot is a best-in-class personal finance app for mac and iOS designed to give you a complete view of your

financial life use code Unchained for a free two-month trial and get started today to see your money in a whole new way with the crypto.com app you can buy trade and spend crypto in one place download and get 25 with the code Laura Link in the description today's guest is Emily Myers general counsel at Electric Capital welcome Emily hi thanks for having me this week the SEC sued both finance and coinbase what are your main takeaways about both of these actions well I think that there are a couple of things one is this is not the end of crypto in the United States these cases

are going to take a very long time to play out in the courts and so there's a lot of water under those bridges to cover before we get to the result the second thing is this highlights the importance to engage on the legislative side there are proposals in Congress and a lot of congressional activity that we are not talking about because we're talking about these two cases and it's important to remember that courts are part of the question of clarifying regulation of crypto in the United

States but they're not the only piece so now let's dive into the details of these two lawsuits what is the SEC saying that these two exchanges have done wrong one thing before we dive into the details that I think is interesting is that the SEC has brought these cases one right after the other I think so that we could speak about them together and try to treat them together but while there are some similarities to these cases there are also some key differences and so to talk through those a bit neither of these are a surprise right the SEC has been investigating both binance and

coinbase for many months if not longer the cftc and the New York attorney general already brought cases against binance and so the fact that the SEC would join in is not a surprise likewise with coinbase we know that the SEC had served coinbase a Wells notice so again the fact that they're suing them is not a surprise so what do these cases say we can start with what's similar between them both cases allege that binance and coinbase were operating unregistered Securities exchanges and they list a number of tokens that they

were allegedly Trading illegally they also both allege that both binance and coinbase were offering unregistered Securities in their very staking offerings what is different is that in the coinbase case that's pretty much where the allegations end there are some additional allegations against finance that relate to fraud to commingling of customer assets and self-dealing and manipulative Trade Practices that are not at all present in the coinbase action okay so one other

thing that I wanted to ask about this is it looks like these lawsuits rest on this assumption that the tokens named are securities do you think that that assumption will just be taken for granted or could that in itself become a contested issue before even the merits of the lawsuits themselves are adjudicated that's a great question I think that it is a fundamental question to both of these suits because in order to be operating and unlawful unregistered Securities Exchange you have to be trading in unregistered Securities and so how the court will analyze any of these I think is really fundamental to

the merits of these alleged violations and what's also interesting is of the 17 tokens that are alleged to be Securities between these two cases added on to 70 plus others that the SEC over its enforcement history has alleged are unregistered Securities there's only been one issuer that the SEC has gone after directly all of the others almost 100 tokens at this point that the SEC has claimed as Securities have all been in the context of enforcement actions against other people and if the SEC was

very confident in its assertion that these are in fact unregistered Securities then the SEC could have gone after the issuers directly and it chose not to oh so it sounds like you're implying that basically it's not confident that it would win on the merits of going after each of these token issuers individually is that what you're saying I think that that would be very challenging for the SEC to accomplish both from a resourcing perspective and potentially on the merits as well whereas while they group all of these together in other enforcement actions like here in order for the SEC to be

able to prove that either binance or coinbase was operating an unregistered exchange they only have to prove that one in the bucket of the tokens that they name was an unregistered security okay and so you're saying that it seems like as these cases go through the courts as long as the court agrees that at least one of the ones listed would fall under the definition of a security then the case can go forward correct then it's not necessarily a threshold issue although certainly both binance and coinbase are going to file motions to dismiss and I'm certain or I would

expect that they would argue that point but it is fundamentally tied to these broader questions of the merits of each case so something else I want to ask about was um just in the binance complaint one of the issues that SEC mentioned was that us customers were told to use offshore entities to continue trading on binance.com after binance us launched and I was just wondering is that illegal because if you have kind of like a multinational organization that does have different entities and jurisdictions I I just thought that that was a thing that companies do um so it wasn't clear to me if that is actually something illegal

so what is not illegal is U.S users choosing to use platforms that are offered under the regulatory Frameworks of other jurisdictions of their own choice that's perfectly fine where binance is alleged to have violated the law is their misrepresentations about how they were geofencing U.S customers from binance and that they were to your point alleged to have tried to help customers avoid those geofences to binance or instead of using the U.S regulated entity to use the global entity that was

not under U.S regulation so it's not necessarily the use it's more what they were saying about it and the finance complaint includes some evidence with internal Communications at binance that speak to their desire to avoid U.S regulation okay and one other piece of this was the lawsuit contends that binance co-mingled funds which gives off FTX vibes I was just wondering if you saw something in the complaint that made you think that what has happened at binance is something on the level of FTX I think that it's tough to compare FTX

and binance in terms of the scope of what transpired I think that binance has a large and legitimate trading business and there's certainly evidence in the in the complaint that there was improper commingling of funds and potentially improper use of client or customer funds but it's tough at this point to know what's just alleged in the complaint as opposed to what the actual facts may be about how those assets were used and where there

was outright fraud and because of the phase of the proceedings against FTX and the bankruptcy process we have a lot more insight into exactly where the assets were and were not compared to where we are now with the binance case and later there was an additional document that I believe was added to the court docket uh and it was by an SEC accountant and it alleged that CZ the CEO of finance and Guang Ying halina Chen received 12 billion dollars of customer funds through their holding company and it said quote the SEC has been unable to determine why a Zhao

controlled entity that was purportedly trading on the binance U.S platform using xiao's personal funds would have acted as a pass-through account for billions of dollars of Finance platform customers funds so I was wondering what did that look like to you does it again look like something on the level of FTX again it's tough to say until we know for sure and until finance and CZ have an opportunity to defend themselves in court and present their side of the story certainly on their face they're not particularly helpful facts for binance but knowing exactly who controlled those accounts why the transfers were made and

how those funds ultimately were used I think is important and one other really interesting facts that came to light late Wednesday was that in 2019 Kinsler apparently offered to become an informal advisor to binance and so the exchange is now asking for Gensler to accuse himself or at least asking also if the SEC has already had him recuse himself and I wondered what you thought of that development and whether or not you thought against or should recuse himself I think it's really significant Gensler has stated in Congressional testimony and numerous public forum that he doesn't think that the crypto markets

are necessary and that he thinks that almost every crypto asset is a security so by virtue of the fact that he has in his public statements and even testifying before Congress claimed that predetermination that could in itself be grounds for him to recuse himself from any sort of enforcement action in the crypto markets now particularly with respect to his interaction with binance in 2019 that certainly raises some ethical questions about the extent to which he should be involved or to which he should

recuse himself from this enforcement proceeding and that's something that finances lawyers appropriately are pressing the SEC on to get some clarity with respect to that and I think that it speaks to gensler's broader strategic agenda here that his whole stance against crypto doesn't really align well with the sec's mission of protecting investors and maintaining Fair orderly and efficient markets and facilitating Capital formation this is not advancing those goals in

that way and so I think that we need to tell our representatives to hold the SEC account for that and making sure that the American investors are at the core of everything that Gensler is doing and a lot of his recent actions seem to undermine that I mean even just the coinbase suit I think is a great example of that the SEC approved coinbase is S1 allowed them to go public their stock trades on NASDAQ and when Gensler sued them after refusing to provide some affirmative regulatory

guidance or work with coinbase as coinbase was repeatedly going to the SEC to try to understand what they needed to do and be able to implement it and then there's a material drop in coinbase's stock price and it's hard to look at those actions taken together and see how that is effectively protecting American investors and advancing any of the three aspects of the sec's mission yeah so in a moment we're going to talk more about the sec's lawsuit against coinbase but first a quick word from the sponsors who make this show possible your emails reveal a lot of sensitive information hence why you need a

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performance and net worth finds your subscriptions and bills and categorizes your spending copilot's iOS and Mac apps even have custom Integrations for all of your favorite apps like venmo coinbase and Amazon you can enter a code Unchained in onboarding for a free two-month trial and get started today to see your money in a whole new way back to my conversation with Emily so I did want to ask I mean you you know you kind of went into this about how they were allowed to go public but one thing that I did wonder was I've heard multiple explanations of why it was that the SEC allowed them to go public and then is now suing them one of them was that when uh companies go public the SEC just checks that the disclosures are all

okay and um at least somebody on a recent episode of Unchained gave an example of how marijuana companies which are not legal on a federal level have gone public however I later realized this scenario is just different because an SEC is the actual regulator of coinbase whereas like a marijuana company would be regulated by a totally different agency so I wondered like is that normal for the SEC to allow companies go public and then later sue them or is this like one of the first times it's happened or the first time like does it show inconsistency I think there are a couple of things at play here one is coinbase went public on April 14th 2021 that is the exact same day that Gary Gensler was confirmed by

the U.S Senate to the SEC so we're talking about two different regimes in terms of who at the SEC was evaluating their S1 and approving it and then Gensler now bringing the enforcement action and so there is some aspect of that discretion in the leadership of the SEC changing I think the second piece is the S1 while not a total evaluation of every aspect of uh registrants business fundamentally it is a sign to the American investor

that this company is accurately stating what it does what its business is and on that basis is appropriate for investment and it's fundamentally challenging to reconcile the sec's imprimatur on coinbases S1 with now going after them as operating an illegal unregistered Securities Exchange when that has been its fundamental business when it when it applied for its IPO and today and so I think again this goes to the lack of

clarity as to how folks should be operating in this space and that's true both for Founders and for users another um I don't know if wrinkle is quite the word but another factor to consider here is that the SEC sued coinbase only after coinbase had sued the SEC back in April and you wrote up an interesting tweet Thread about how legal offense might play out between these two lawsuits so please describe that so just to set the stage a bit last July so July of 22 coinbase after having engaged with the SEC for a long time to try and get some regulatory

Clarity ultimately filed in the third Circuit Court of Appeals in federal court to get the SEC to say whether or not it will actually make those rules because it hadn't said anything right so in July of 2022 the SEC formally asked the commission to please make rules they waited nine months heard nothing and so in April of 2023 coinbase sued the SEC in the third circuit U.S federal court of appeals to try and get them to say simply are you or are you not going to

provide a rulemaking on this and we think you should and trying to get the the court to compel the SEC to do that and that has not yet been determined so the court didn't have an opportunity to rule on that before the SEC sued coinbase and then the S and then the third Circuit of its own volition saw in the news that the SEC had student coinbase and so asked the SEC what it should do next whether this was denying coinbases petition to get them to write

rules whether they needed more time to make that decision and why the third circuit shouldn't retain jurisdiction to get the SEC to answer those questions and so I think because the the third circuit is appropriately holding the sec's feet to the fire here the SEC has a week to answer those questions about what they're going to do and so it'll be interesting to see how the third circuit continues to move forward and whether or not they will ultimately press the SEC to issue those rules that coinbase and others in the

industry have been clamoring for for so long I just find that so hilarious that they were like so are you denying because it seems pretty obvious I think that's what's happening um but I just love the notion of like a judge having to formally ask so at the same time that all that's going on meanwhile we have um House Representative Patrick McHenry has introduced this crypto Market structure bill that could be a path forward for legislation and I wondered if you knew kind of which process might play out faster and um how you saw all these different battlefronts regarding crypto regulation in the US playing out that's a great

question I think there are a lot of headwinds for both paths and so it's tough to know which will come first I think it's possible that if the third circuit really wants to hold the sec's feet to the fire and really compel them to issue this rulemaking that is within their power and they certainly could impose a specific time limit for the SEC to do that that's certainly not typical outcome but it is certainly possible and given everything else that's going on with the other litigation where SEC is

the plaintiff that there could be an opportunity for the third circuit to make that order I think in Congress there certainly are headwinds to being able to pass any legislation right now because the Republicans have such a narrow majority in the house the Democrats still hold the Senate and I think that ultimately a lot of the Democrats priority is elsewhere and the Republicans need to make a real concerted effort to engage their Democratic counterparts to advance this legislative proposal but I think that

the sec's court cases this week just highlight how necessary some sort of regulatory Clarity is for the space and that is going to come faster through a legislative attempt rather than through anything that could go through the courts because both binance and coinbase like lots of other crypto defendants ahead of them have very well resourced and are very interested in fighting the SEC on all of these issues which could be existential in terms of how they proceed

so we're definitely in for a long drawn out Court battles that could go all the way up to the Supreme Court and all of those take a very long time okay yeah and I just from some headlines I've seen I think even the House Republicans are not um all uh kind of of one mind within themselves so yeah that's could be a long drawn out battle um so one other interesting thing that has happened kind of in this arena is that there are two platforms that were recently approved to trade digital asset Securities one of them promethium would even likely classify eth as a security um as the CEO Aaron Kaplan implied on a recent episode of Unchained

um the other platform both Sonic seems to be limiting itself to like more clearly established Securities but I was wondering do you think the fact that they were able to get finra approved means that the industry has been disingenuous when it claims that it's tried to come in and register but has not been able to no I don't think that that's the case at all I think that if there were an effective path that made sense that coinbase would have pursued it it has been trying for years to do so and I think there are a couple of problems with assuming that an SEC registration or a finra registration as an alternative trading system or ATS would

solve all of this because as we were talking about at the beginning of the interview underpinning all of these requirements are you can only trade registered Securities and so all of the existing tokens would need to come under the regulatory umbrella in some way even if those exchanges could actually register and I think it also raises some fundamental questions about when we go back to the first principles of the purposes of Securities regulation of markets in terms of maintaining fair and transparent markets and resolving

information asymmetries those two objectives look very different for digital assets than they do for traditional assets and it's important that investors have the appropriate information and protections that relate to those assets in addition to the way that they relate to traditional assets so there are a number of of fundamental problems that I think need to be addressed before we can have the kind of regulatory regime that actually makes sense for crypto and crypto Trading and I think that that is possible Within

U.S Securities Law we just need some appropriate amendments to address the risks and the opportunities that crypto provides for investors we just mentioned ether which to my mind is kind of the elephant in the room here chair Gensler has repeatedly said that all cryptos but Bitcoin are securities which obviously would mean that ether then it's a security however the sec's former director of Corporation finance bill Hinman said in a speech in 2018 that leaving aside the manner in which ether was sold in its current state it is not a security so since the chair has been clear so many times that he views ether

as a security even if he refuses to say so directly why do the complaints avoid naming ether I mean they go after several other large market cap coins such as Solana automatic Etc what are your thoughts on that I think there are two things here one is strategically the SEC doesn't have to list all of the potential assets that it thinks are securities in either of these complaints all they have to do is prove that one is a security in order to prove that either binance or coinbase was operating an unregistered Securities Exchange and so

strategically for the SEC they want to go after ones that they think are less controversial that they could win so strategically there's no advantage to them going after what is arguably the most controversial there I think the second potential question is does the SEC have some other plan for how they're going to address ethereum and is that why Gensler has refused to testify in Congress even when asked directly do you think that eth is a security and in the meantime there's

more confusion in the marketplace because the cftc chair Benham is testifying that if is a commodity and asserting that eth is a commodity in its action against binance earlier this spring and the New York attorney general is claiming that eth is a security in her action against kucoin and so all of this confusion just further underscores how important it is for everyone in the U.S market to be able to understand how these assets are treated and also the complexity of these assets and their categorization so again I think the

draft proposal on Market structure that Representatives McHenry and Thompson published recently really speaks to an attempt to resolve these types of questions that would allow the industry to move forward I I have so many thoughts there um but just when you were naming all the different things that people have said I sort of Imagine This like clown car all these people running around um but one thing that I did uh just want to ask you so when you said that the SEC might have another plan for addressing ether what would that be since uh director Hinman had already stated that ether was um not a security so just like there is a different

Administration when Bill Hinman made those statements while he was the director of the office of Corp Finn again it's like there's a new sheriff in town now and that SEC clearly has some alternative belief and so I don't know if the SEC is planning anything or would want to plan anything I think that it would be important for the market to clarify how all digital assets should be treated under U.S Securities and commodities law and obviously understanding how ethereum should be

treated is fundamental to that okay but one last bit on that is is the SEC required to have consistency across time because it feels like it should but maybe it doesn't or effective markets need predictable and consistent rules that can be applied by all of the market participants and that's the reason why this scatter shot approach and regulation by enforcement on the sec's behalf is so challenging because it's all backward looking and it's not predictable or consistent and so all of the market participants are left wondering how do we treat this and

trying to examine the tea leaves and parse across all of those different tokens again we're almost up to 100 tokens that the SEC has alleged enforcement actions are securities and try to identify well this one was issued in this way and in this one the founder stated these things about the protocol and in this one they didn't State anything about the protocol and these folks were zinged for non-disclosure and these folks said too much and it is very very challenging to be able to actually operate amidst all of that confusion all right well thank you for unpacking

all of these issues with me it's been quite the discussion um yeah thanks again for coming on Unchained thanks so much for having me Laura it's been a pleasure don't forget next up is the Weekly News recap stick around for this week in crypto after this short break join over 80 million people using crypto.com one of the easiest places to buy trade and spend over 250 cryptocurrencies spend your crypto anywhere using the crypto.com Visa card get up to five percent cash back instantly plus 100 rebates for your Netflix and Spotify subscriptions and zero annual fees download the crypto.com app now and get 25 with the code Laura Link in the description

U.S House Republicans propose new crypto bill as discussed briefly on the show despite negative regulatory news around binance and coinbase there was a potentially significant development with U.S House Republicans proposing a bill to pave the way for crypto assets to be classified as digital Commodities Republican chairs Patrick McHenry and Glenn Thompson spearheaded the initiative with the legislation seeking to settle a long-standing debate around the classification of digital assets as either Commodities or Securities the proposal put forward a set of criteria for a digital asset to be considered a commodity with one key element focused on the decentralization of the blockchain network under this framework an asset could be classified as a commodity as long as the network is

sufficiently decentralized and no individual or entity owns over 20 percent of the Network's tokens the bill also requires that in the previous 12 months a single person should not have had the power to quote control or materially alter the network coinbase Chief legal officer Paul Grewal lauded the effort for laying quote a strong foundation for regulatory jurisdiction and definitions in the crypto space despite the Bill's potential to clarify regulatory boundaries for the digital asset industry the legislation still needs broad bipartisan support for it to become law this follows a growing Rift between Democrats and Republicans on crypto regulation with different bills from each party currently in the house Financial Services committee and a

polarisim that far extends this industry Atomic wallet breach results in 35 million loss decentralized wallet provider Atomic wallet was rocked by a security breach that left some users in Dire Straits leading to 35 million dollars worth of crypto assets being siphoned off with one user reportedly losing nearly 8 million dollars in usdt tokens alone crypto analytics firm elliptic connected the exploit to the notorious North Korean hacker Collective Lazarus due to the ill-gotten gains being funneled through a mixer often utilized by the group the exact method of the exploit remains undetermined however previous warnings from cyber security firms about vulnerabilities within Atomic wallets system raise questions about the team's

effort to address them criticism has been leveled at Atomic wallet for alleged negligence with Maya crypto CEO Taylor Monahan accusing the company of ignoring a security report flagging critical vulnerabilities she said quote your security posture sucks you refuse to listen to people you aggressively silence people and your products and services facilitate theft on a daily basis and have for years the breach only adds to the increasing number of crypto industry hacks this year underscoring the urgency for robust security measures within the sector if you want to hear more about crypto wallets and security don't miss this week's Unchained podcast which came out Tuesday with Oriole Ohan and itai turban the Met plans to return ftx's donations

the Metropolitan Museum of Art intends to return 550 000 to the now bankrupt cryptocurrency exchange FTX the funds were donated to the museum last year Under The Entity West realm shires service a subsidiary operating FTX U.S the museum received two donations from FTX one in March and another in May both of which it aims to return FTX founder and former CEO Sam Pigman freed known for his philanthropic activities and effective altruism philosophy has reportedly spent 93 million dollars on his political donations the court is still to approve the Met's return of donations to FDX with a hearing scheduled for June 28th FTX under new CEO John Ray III is working to recover

assets to repay creditors affected by the exchanges collapse the return of donations is seen as a necessary step in this recovery process Genesis gains reprieve and bankruptcy proceedings in the unfolding Saga of Genesis Global bankruptcy case U.S bankruptcy court judge Sean Lane recently granted an extension for Genesis to file its recovery plan the company now has until August 2nd as opposed to the initial request for an August 27th deadline this deadline however hinges on Genesis maintaining collaboration with its official Committee of unsecured creditors meanwhile FTX a notable creditor of the company was denied participation in mediation talks with judge Lane emphasizing the need for a

degree of confidentiality in these discussions FTX had alleged Genesis owed them nearly 4 billion dollars a stark contrast to genesis's zero dollar estimate a dispute to be resolved in future hearings in addition to this defunct crypto hedge fund 3 Euros capital is frequently advocating for a seat at the mediation table the failed fund has asserted claims of over 1 billion dollars against Genesis these developments occur amidst increasing frustration from genesis's creditors such as Gemini and customers affected by genesis's Financial downfall who are calling for a swift resolution the judge however insists that extending mediation won't necessarily prolong the case but potentially prompt faster

resolution dokwon is released on controversial bail Terra co-founder dokwan was granted bail at 400 000 Euros or 427 thousand dollars by montenegro's high court after it was initially denied his approval came amidst allegations of him funding montenegro's political party Europe now claims which outgoing prime minister dritan abazovic is pushing the special State prosecution to investigate former CFO Han Chang are embroiled in a case of allegedly attempting to travel with fake documents this incident comes after the Terra ecosystem crumbled in May 2022 causing a collapse worth 40 billion dollars The Fallout led to South Korea and U.S authorities requesting

Quan's extradition to face charges after the Montenegro trial adding to the mystery there are reports of Quan's connection with the leader of the Europe now political movement milochkos magic whilst magic denies these claims the merging Scandal could pose a significant challenge if spajik leads the parliament after the upcoming elections in the meantime Quan is under house arrest awaiting his court appearance on June 16th in a statement to the Press abazovic warned quote we cannot become a breeding ground for Global fraudsters even if they use blockchain or anything else arbitrim suffers unanticipated halt arbitrim a layer 2 scaling Solution on ethereum experienced a temporary halt on Wednesday pausing transactions for roughly an hour with over 2.24 billion

dollars in deposits the stoppage was initially attributed to the sequencer a key transaction processing software component running out of ether used for transaction fees however contrary to this explanation Arboretum developers cited a sequencer batch poster bug as the cause of the interruption noting that the sequencer's wallet is programmatically refilled regardless of the exact cause the incident underlines the tension between decentralization and the practicalities of operational Control blockchain Association stands against tornado cash sanctions in a recent development the blockchain association filed an amicus brief supporting coin Center's lawsuit against the U.S treasury over its sanctions on tornado cash the cryptocurrency mixer

which the US government alleges was used to launder more than seven billion worth of digital assets Kristen Smith CEO of the blockchain association argued that tornado cash is a tool and sanctions should Target those who misuse it rather than the tool itself quote punishing the tool itself simply because it can be used by anyone including Bad actors runs contrary to the values this country was founded upon Smith said the suit also emphasized the need for financial privacy in the digital asset industry underlining that users seek tools like tornado cash to maintain privacy without compromising blockchain technology benefits tapping on the Privacy debate on blockchains Luke Chang CEO of Nocturne told Unchained quote it's just very hard

to imagine a future where everything is public by default time for fun bits so we just talked about dokwan's bail but let's now hear it from stand-up comedian Jenny Hogan so disgrace Tara co-founder doe Quan is out on bail that's right his 428 thousand dollar request was approved by a court in Montenegro Juan and his CFO are now on house arrest in Montenegro which is incidentally what a lot of people would call a vacation Juan couldn't get the bail until he verified that he owned property worth millions to be fair no one doubted that this claim was true they just weren't sure if he met millions in Luna or millions in actual currency with actual value in that Quantum his CFO both have to pay is approximately two hundred thousand

dollars each which is incidentally the same as four years of private college I think this is apt since in the last four years it doesn't seem like either of them have learned the bail is supposed to incentivize Quan to stay in the country which really shouldn't be an issue why would he leave he's wanted in literally every other country the pair is set to be monitored closely by the police in Montenegro which to be fair seems like an appropriate job for a cop sure have fun watching Quan last his ass off while he spends the next two weeks counting his money and trying to beat SBF at Diablo 4. thanks so much for joining us today to learn more about Emily and the ongoing lawsuits against binance and coinbase check out the show notes for this episode Unchained is produced by me Laura Shin with help from

Kevin Fuchs Matt pilchard Zach Seward Juan aranovich samsher run Jenny Hogan Jeff Benson Leandra Camino Hima jamdar Shashank and Margaret Correa thanks for listening thank you