nterpretive dance video and not a not a speech it might be because of the headphones kevin you might have to take off your headphones and uh just play it through the speakers all right has a little bit of an update on my work in the state legislate can you help can you hear that yep okay cool play chair so let's get right to it because i know there's a big long agenda tonight and maybe you're watching later on so i introduced my first two bills in the last couple weeks the first one being h163 in case you want to look at up about the Vermont legislative website it's an app relating to enhancing equitable learning and workplace environments and public schools in Vermont and the purpose is to really require and fund state partial funding like 50-50 match from state to local anti-bias professional development training for every single person in the school meaning all educators all staff and all school board members so that we have high quality anti-bias training um anti-bias professional development i should say because it's more than training for folks that meet school districts where they're at and really moves the conversation tour around equity everywhere in the state because not every school district is working on equity in the same way my second bill is a labor bill numbered h239 it was just introduced today actually and this is an omnibus bill which means a sort of like a catchall for a few different worker protection concepts there's three things in here to help stabilize jobs for workers it first requires employers to provide reliable schedules for employees this would be a great benefit to folks who work in the hospitality and restaurant industry as well as retail who often get work schedules days a day or hours even before they're to begin and it creates great instability and ability to find child care that's reliable as well as work other jobs and just really um uh live lives that are not tethered to what the work schedule might be and the second thing in this this workers bill is granting workers the just cause termination rights which means that workers when if they were to get fired would have to be um they would have due process and ability to have um not be fired for any particular reason but to have a defined reason why um they were being terminated so they had sort of uh rights in the workplace and um better protections around termination and the last piece would be requiring employers this idea actually came from a constituent here in chitin six two a few weeks ago but would require employers to reimburse workers for certain home office expenses if they're working remotely there's actually six states that already require this including our neighbor new Hampshire and so this would be um important um adaptation of early relays as we look to um continue to live through this pandemic and after the pandemic when there might still be remote workers out there um just a couple other things to just highlight for tonight um and that would be that the house commerce economic development committee for which i'm a member of is starting to dive into the budget around um allocations for running around economic development uh worker workforce development um looking at issues that um for programs that v-sac funds for example looking at community development efforts that comes to the agency of community and economic development and so i'm really always trying to bring an eye towards equity and really trying to center folks who um had trouble accessing resources so far through the pandemic um who own small businesses who might have started a business who might have businesses that don't have formal you know financial departments to help them um uh advocate and access grants and loan programs that have already been offered through the federal and state government so i'm bringing that eye there and in particular if you if you're a small business owner if you know folks especially women and bi-pop businesses that had trouble with the first rounds of pandemic related grants or loans please put them in touch with me because we'd love to incorporate that perspective into testimony and decisions around future grants that the state might put forward to help businesses recover and most importantly by extension help workers recover and um whether this pandemic and then the last thing i just want to end on is this very big issue of unemployment um data breach that some folks in june 62 have unfortunately experienced where the department of labor sent out incorrect 1099 g tax forms um it is uh something that impacted only for monitors who used two of the pandemic related unemployment programs the lost wages assistance program and the short term supplemental program um the department labor is getting better but they're still needing to improve a lot of their communication with folks i know this i've been hearing from all of you um to make sure for monitors have what they need to understand what you need to do and what the state's doing to remedy this problem so there's now a fairly decent f.a.q um site up on their webpage i've been told they're working to translate it i keep pushing them to make sure that they're communicating more frequently with um impacted for monitors and making sure that language is accessible to everyone and not just rely on email to push out information to folks because this is way too important um it's not an email about what people need to do but the most important thing if you're one of the folks who are impacted by this data breach is to know that the state will now offer you free credit monitoring services for a year again free to you um but you also should take steps to freeze your credit and look into the steps that require to kind of monitor um your identity so that there isn't identity theft out there so i'm going to leave you just with one resource to call if that's all strange to you or you've never done it before um because the attorney general's office state attorney general's office through the consumer protection program cap can help you through all of that um and they are also a free service to every remonder so you can call them at<PHONE_NUMBER> or email them at ago.cap at vermont.gov they also have a website which you can google but again you can email them at ago.cap at vermont.gov or call them at 1800-649-2424 so do be in touch if you have any questions feedback ideas i'm always open and i'm really trying to prioritize constituent emails over anything else in my legislative work so you can reach me at evolvanystanek at leg.state.bt.us or give me a call at<PHONE_NUMBER> so thanks neighbors i hope you had a great mpa meeting sorry to miss you and take good care thank you all all right so with that i think we can call it a wrap um thank you everyone for being here i have a question for emma i'm just kidding just kidding hi everyone thank you thank you bye thanks leah


the right care and support, at the right time, in the right place, for you. Across Wales we have changed the way we do things, making your care and support the best it can be, to help you live the life you choose and stay independent for longer. This video explains the way councils assess your care and support needs for children, adults and carers. If you think you need care and support, you should contact your local council. They can have a conversation with you. They can give you information on what's available to you, and can give you advice and assistance. Your assessment will start when you contact the council. Contacting your council. You can contact your local council. Someone can contact them for you, or someone can refer you. If a person appears to need care and support, the council must carry out an assessment.  You will have a conversation and agree the right care and support for you. You will discuss what you could do independently, or your council could assist you with, what is available in your community, how your council could help and support you, how your council can help and support you. They can give you advice and assistance to find people and organisations that could help you, how your council can help and support you. If some of the solutions can only be managed with your council, they will create a care and support plan with you. The right plan for you. Your plan will reflect your needs and will be created with you. So you have the right care and support at the right time in the right place for you. Please contact your local council if you would like to discuss your care and support needs.


whole take away of the exercise biggest take away I would like to focus more on the design aspects how we approach this whole exercise how we define the problem how we scoped it out and how we ended up executing it and what are the key takeaways from that. So yeah for some of the old timers you would recognize curly from the three stooges. This is the kind of situation we found ourselves at the startup I was working at we were just six months old but we were in a very rapid phase of growth and already some of the ad hoc initial systems we had around events and analytics based on elastic search already they were not sufficient you're not scaling up so if that was the situation just six months down the line when we are doing POC then if you do well you know it was a scary scenario so that was the time when we actually sat down very very broad mandate was given to create some system which can scale over time at least for the next two years and it was very broad mandate no definition of what data is there so everything was open to discussion starting from what kind of data we need to capture what kind of capabilities we need to provide and how we'll end up executing it and so the company to give you brief about the context on who we were again it was a fintech startup lot of transactional data lots of profile information and it was very in a rapid state of growth so that was the context and along with it comes a lot of requirements about you know where exactly can you store the data the data needs to be localized you can't really put it in the cloud because you have sensitive credit card information you'll have personally identifiable information and then there are other concerns around you're a startup you don't really know where you will grow so you need to have a flexible system you can't invest a lot in a particular technology meant for a particular product because you don't really know where you will evolve so a lot of design decisions were based on that thing that we need to be flexible over time if the business model changes we need we shouldn't incur a very heavy cost because of upfront capital investment so coming to the problems that we identified from the very start we had a lot of people with any good and well justified opinions about what kind of systems should be used to create a generic data lake but I think we realize that that is a problem we often do we look at a solution we get excited and we execute it and then we realize that it is not solving the problem because we didn't really define the problems up front so the first very first step was identifying the problems that we were facing and in the near future that we could face again being a startup we couldn't over engineer we didn't have the luxury of either money or time so the minimum thing that can get work done for the foreseeable future the very first problem that companies in growth face the face is probably proliferation of data silos every new product of feature or team starts storing the data it expands and over time you'll find 20 different systems maybe different technologies with their own experts with their own understanding data representation and it's a very difficult task to actually get them together the problem with data silos is not just duplicate effort and the complexity but also that now you cannot get higher intelligence by combining all the data together for people in one team cannot understand the data in the other team because they all are you know structured in a different fashion there is no single language that they talk about so exposing data silos duplication effort if you look at production systems you'll need a different DevOps team specialized for each different system they could be a edge-based cluster they could be Cassandra's cluster and these are you know real-life cases that I'm talking about that we faced over time we had n-numbered different systems and experts for every different system and still you cannot bring all that information together and do really interesting analysis yeah one the last one is an interesting one data outlays tech very often it is said that one of the key differentiators or advantages Google has is the data it has it has data for several decades obviously the technology that they are using to store the data has changed over time and that will happen in your organization also so very often we look at a solution and then we are constrained by how that solution stores data represents data but we need to decouple the two things we need to look at information how to structure it and then we need to map it to one of the storage solution so that in the back end even if the technology changes my data representation in the capability should not so having identified the problems then we started defining the solution you know exactly what technologies what stack and what architecture should be used to solve it but before actually jumping into execution we need to define the problem in engineering fashion and when I say engineering fashion we need to define both the functional specs like what kind of data you have do I have very structured strictly defined data or do I have free text schemas which I don't know how they will evolve or I want to find a middle ground that I'll have free text schema but it can only be hierarchical like a tree adjacent tree so I need to take that call and define what kind of data representation I want to support so that those are the functional specifications what kind of data how much data what are the what is the complexity of the data and so on and second is the performance specification those are also the kind of things you need to define before you can choose a solution because a solution like post-graeme may seem obvious when you have 50 gigs of transaction data which is the order of data we had in the beginning but just one and a half years down the line we actually had a seven and a half terabyte of elastic search cluster so you don't really know how things will evolve so you need to have those discussions and you need to define the performance and all these specs you know what is the maximum latency of data that you can live within your systems to give an example if an event is raised is it okay if it reaches 100 milliseconds later or 10 seconds later or one hour later because that's cost of a solution between a 10 millisecond storage solution and a one hour storage solution could be 1000x so you those all are the kind of specifications you need to define as you implement and especially in a startup you can refine those numbers over time but you need to write them down so that everyone is on the same page and it really helps to choose a technology like when we wrote some of these solutions down at the very onset we were able to discount many of the six solutions out there because they did not meet one of these criteria or we were able to for example be used edge base for one of the storage systems then we had to really edge base is a big table storage format and it's a key value store and we used it to store rich deep json objects so at the onset we knew that we need to have some transformation layer you know to translate this to that so you will not be caught by surprise later in the end if you write all your performance and function specification at the very onset so that is one thing we did we defined the problem broke it down in this style then we defined the data model data model is forget about how it is stored on the file that is just the storage representation how you think of data in your head is it like a relation schema key values or is it like a big table schema or json schema and we also looked at how other people are solving problems so it identified that we need something like events something like entities like a rich profile a user profile is an entity we'll have metrics we'll have logs and what are the common behavior all of these have and can I have a single data representation so that I don't have to create four systems for this can I have a single pipeline for all of them and have a single data representation for them and you know some annotations or some way in which wherever necessary I can fork them up into different systems in the edge not and have a common in the middle so try to reduce duplication that was the theme and yeah in general not be a vision should never be blocked by the implementation so that was one thing we always try to look at the specifications that we have defined and try to create a solution out of that not based on a particular technology that we have chosen and then based on that we see you know what all data we can fit should be the other way around coming to the implementation is a very rough kind of a I didn't have enough time to create a proper architectural diagram but it is a typical pipeline where at the source you have multiple you know sources for data it could be a mobile apps they could be a million users using your mobile app creating events and doing all those modifications and logs and you we had a microservices several hundred instances of microservices running and creating all these data objects logs metrics events entities and then we were able to create a single unified data representation model and we used kinesis as our data pipeline people use Kafka kinesis there are a number of solutions out there kinesis work for us and we had interesting experience with scaling it optimizing it so yeah we can have that discussion later if you have any performance or scaling you know aspects that you want to discuss so we were we implemented kinesis that allowed us to decouple the destination from the source as long as the source has given handed over data to kinesis we know that robustness durability has been taken care of because it is a hosted service on demand scaling we knew that we can scale up to easily thousand x ten thousand x and we'll only pay for the amount of capacity that we are using and data sinks we created our own microservice distributed markets microservice architecture where we could add instances at real time and they read from kinesis the relevant data and they push forth the data to individuals sink a sink is a data destination it could be a persistent store like we had elastic search we had hbase for a while we had s3 for disaster recovery cheap storage or it could be other consumers like we had API consumers which we used to for example read data from here and we did a poc where we were sending data to amplitude a third party system so yeah that was the glue here that read from kinesis and sent to data sink and we were able to achieve isolation if one of my technology clusters is down elastic search it will not affect any of the other things so back propagation of failure or data logging so all those issues were taken care of isolation between sinks and scaling so yeah that was the essentially implementation each of these technologies or pieces is complex enough to have a complete talk by itself so yeah if there are any specific questions at the end I can feed no no so data lake is effectively this one way of implementing this data pipeline is how your data is coming from n number of different sources technologies and flowing into this while taking care of scalability latencies throughput you know all those aspects so data lake could be just to give you an example a data lake could be simple hdfs cluster using let's say parquet file format where I have dumped all the data it could be entities events logs metrics in different file hierarchies and I just need to create a layer of data governance and data isolation so that if someone wants to look at logs they only look at that hierarchy and for example I can put a sequel layer on top of it to query it so data lake is just a way of storing data and making it in enabling people to query it that is just this part yes right so it's a good question the context is that as a startup initially we didn't want to create n number of systems but this gave us enough flexibility to later for example if you wanted log data to go elsewhere there was a different consumer for it which was pushing data to a different destination it could be the same elastic search cluster it could be two clusters or it could be two different destinations altogether so in terms of plumbing we had conceptually speaking four different pipes one for logs one for betricks one for events one for entities and we can just change the plumbing here to send data to different destinations I'll fill that question later just because okay yes yes yeah so one thing I haven't shown here is this plumbing basically the data collector what we called which read from the persistent queue and pushed into a different whatever the destination is so think of it that there are different destination there is s3 which is for backup and which stores everything there is edge base which only has events there is elastic search which has events and entities each of them has this application has different instances running and it's a distributed application so you can create a thousand instance each instance knows that I only have to read logs and I have to store it in s3 another instance knows that I have to read logs and I have to store an elastic search so you know there is that blue over here which this diagram does not represent that takes care of it and any business logic about filtering that comes here we actually had business logic of doing some amount of data health checks and rejecting dirty data so key wins some of the biggest takeaways that went well based on the design and over the next one one and a half years we validated them in production when we scaled up to I don't know 100x the amount of data volume and size one was that because we have defined the standards clearly and even though there were different types of data model there were only a there was a simple for example JSON format in which we had published that this is how data is stored so everyone knew both from the developer who is storing data as well as people who are querying data what to expect and how to expect the data as well as the performance guarantees we had told that in the worst case you can expect this much of latency so even product managers knew that when doing some analysis they should not complain if they see latencies up to this so standards was one thing that really helped communicate implement two standards it helped us not create a lot of band-aid fixes because sometimes you want to do x but a technology doesn't provide that so you do a lot of hacks on top of it to make it work but that haven't heard was less duplication so we just had a team of two three devops which was handling this whole infra because there was only a common data pipeline in the middle and yeah these were the key wins some of the things which we did not cover were scaling of metadata basically that was one thing we were going to do next as your data grows your data dictionary also grows and then it is very hard to figure out what data have in a system only then can you actually query that data so data dictionary was the next logical evolution step that we did not tackle and data health was one thing which we underestimated over time for example mobile clients did not have a way of logging so they started using events for logging information and then we had debug logs in events so more data is not necessarily good if you have data for for example events data if 90 percent of the data is noise effectively your no one will use that system so data health is something that you need to define as part of spec you know how do you have just like unit test you need to have all the tests for your data health and at all times you should be able to visualize your score and take proper steps to keep your data neat and clean so that a for example business results come out right it should not happen that your city name has small d for deli and sometimes capital D for deli and sometimes new deli and then someone doing an analysis sees three different categories so all that data health check really bite you hard later on no so that is something we did not do that is something we had to build here and data governance we created distributed async data pipeline so if there is any unexpected error it is very hard to propagate it back or even to realize whether it is a recoverable error or a not non-recoverable error because yeah and do we have time no so yeah that is all from my side maybe we can take one or two questions yeah we we had a health report where whenever there was a failure notification send out to devs which means me and we used to have basically classify them and then take a call and over a period of time we were able to classify most of those recurring issues in either actual errors or not but yeah no advanced system classifications yeah all that was taken care of that is a basic kinesis data consumption patterns yeah yes I can feel any questions offline yeah


And so even that fig leaf, even that APA that says that they have to consider public input and they have to have a notice publicly of the proposed change and then have a 60 day or so comment period where they accept feedback from the public, even that is being ignored in this case. So it really is a sort of failure of democracy. As the world turns and the Biden administration gets going, one regulatory holdover from the Trump era is drawing a lot of attention. Is this the end? Probably not, but we'll get into it. I'm Adam B. Levine and this is Speaking of Bitcoin. For today's session, I'm joined by the other host of the show, Stephanie Murphy. Hi. Andreas M. Antonopoulos. Hello. Jonathan Mohan. Hey, hey. And special returning guest, Peter van Valkenburg, director of research at Coin Center. Peter. Hi guys. Thanks for being here today. Yeah, thanks for having me.  So, Peter, I've been hearing a lot about the Finns and comment period over this self-custodied wallet ruling that they will be making soon. And a lot of people seem to be up at arms. And quite a lot's happening in the world right now, both with the election, the Bitcoin price and the lockdowns and just winter in general, such that, you know, it's kind of hard to find oneself to care about anything, especially when it's something that seems so banal as the government is asking for comments because later they might say something you might not like, just in the realm of all the things that could happen and potentials that are occurring. It just seems so far off and distant. And I know that a lot of the people who are really looking into the such as yourself are really passionate about engaging on this problem so that we get the best outcome. What is going on right now? And why should we be concerned? So, you know, a lot of people are upset, I think, you know, first of all, because this all happened over the holidays, we got an announcement from Finnson the Friday before Christmas in December that there was going to be a 15-day comment period, as you said, for a proposed new rule that would affect Bitcoin exchanges, cryptocurrency exchanges in a pretty serious way. And so Finnson is this agency in the treasury that deals with financial surveillance. They deal with so-called anti-money laundering policy, but I prefer the term financial surveillance because it's really just warrantless data collection about all your financial transactions. That's the law that they deal with is the Bank Secrecy Act. And so this comment period was to solicit public feedback in all of 15 days over the holidays and the new years on this proposed rule change, which would say, hey, if you're a crypto exchange, if you got customers and you're holding Bitcoin for them or other cryptocurrencies, you're already subject to the Bank Secrecy Act. So you already know your customers, you already file suspicious activity reports, but we're going to require some new reporting requirements and some new record-keeping requirements about your customers, some of which that apply to other financial institutions like the kind of reports and records that banks need to keep, but some of which are actually more strict, more information that we want you to collect than we even require from banks. And there's one particular requirement that they were proposing in that rulemaking that basically would be very, very difficult for exchanges to be able to meet. And so it would lead to exchanges effectively choosing probably not to transact in certain ways because what that requirement was was this. It says, if your customer is starting a transaction or receiving a transaction on, say, the Bitcoin network or any other cryptocurrency, you need to know that the transaction is either coming from another financial institution like Kraken to Coinbase or going to another financial institution, Coinbase to Kraken. And if it's not, you need to know the name and physical address of the individual that it's coming or going to. So we're talking just a regular old Bitcoin wallet that I might have on a ledger or a Trezor or something like that or just on an iPhone touch. If I'm sending transactions from that wallet to Coinbase, Coinbase would need to know my name and physical address. And I mean to a customer at Coinbase, a person who I'm actually paying. And as I don't need to tell you guys at all, that's not how the Bitcoin network works. The Bitcoin network has Bitcoin addresses and it has signatures to prove that you are the sort of rightful person to be controlling the funds in those addresses or to control the UTXOs to be more specific. So there's no name and physical address field in a Bitcoin transaction. Right. In fact, it doesn't even have to be a flesh and blood person receiving the transaction. It could be a smart contract and something like that. Exactly. Good luck finding the name and physical address of any kind of payable machine or smart contract on any of these cryptocurrency networks. So can we just put Vitalik Buterin, one Ethereum foundation, no? That doesn't work? For all smart contracts. For all smart contracts. He's going to have quite the dossier at Treasury. Yeah, no. So this breaks the way these networks work. And you could say, well, exchanges could just allow you to transfer to your own wallet that you host yourself. And then you could go and interact with smart contracts. But this is sort of like an added level of complexity to using something like a smart contract or paying an individual who's not yourself. And it's not just an added level of complexity and bad for that reason. It's bad because it's not equal treatment with traditional financial institutions. So when you remove cash from your bank account, or even when you send a wire from your bank account, the record-keeping requirements are flexible. The bank has to record all of the information you gave them about the transaction. But there's certain fields like the recipient of the transaction where they only need to record the name and physical address, for example, if that information is available. And so the law makes these excuses, if you will, for incomplete information at traditional financial institutions like banks. So why would we not get the same excuses at Bitcoin financial institutions? And it seems as though there's just was an interest in providing that kind of flexibility to the crypto world that there is in the traditional financial world, where most of the money laundering actually takes place. But also, I mean, showing its true colors, where customer surveillance or consumer protections comes into play, seems like the state tends to choose surveillance over consumer protections. Because, you know, as much as we tell everyone to custody their own coins, there's a large percentage of people who are a lot safer with their funds on an exchange and sending it back and forth to regular people. And so taking that group of people that don't have any of those best practices and telling them now, hey, the only way for you to send or receive money is for you to self-custody your coins, we're going to see a lot of very unsophisticated people losing a lot of funds. I think that's right. And consumer protections about shielding people from loss, consumer protection should also be about protecting their privacy to some extent, right? And the minute you start creating these reports and these records of who owns both name and physical address, which Bitcoin address is the minute you create a fully searchable record of people's full financial history, because you take that name and physical address information, you match it with blockchain analysis, and you can see every transaction that's ever happened. Like consumer protection is not the point. It's not when it's FinCEN. And that's not really FinCEN's fault. Their focus is narrowly as sort of one part of a fragmented government approach to regulation that we have in the US. Their focus is narrowly on financial surveillance.  That just seems strange to me. We've already seen the fallout from this type of problem, but just a fraction of it with the hack of the sales website of the ledger company. It leaked names, phone numbers, and physical addresses of 290,000 people. Now, just with that, we've already seen phishing attacks against text messages and emails. We've seen sim swapping attacks attempting to hijack phone numbers so they can break into exchange accounts and other things like that. They use them as two-factor authentication. But we've also very warringly seen phone calls and threats and letters being sent to the physical address of these people, threatening that they will come and invade their home. Now, what we're talking about here is collecting a honeypot that is maybe two orders of magnitude bigger. The one saving grace of the ledger hack is that out of the 290,000 people, you have no idea who actually has and how much they have, which means that the type of high-risk, low-return attack of a physical invasion of their home or something like that doesn't make sense, because they may have five bucks and you've just taken a huge risk for a very small return. But what we're talking about here is all of that information plus balances or at least transaction history that can be used to reconstruct balances, at which point you sort the list by richest, load up the shotgun, and you start robbing them one after the other. It's very little consolation that this is going to a secure government facility. We've seen that they couldn't even keep the office of government management to whatever is called the OMB, database of clearances and background information for their own OPM, or the NSA information that was leaked. And frankly, just recently, Finsen itself had leaks of suspicious activity reports. And so, we would be talking about similar reports being made for crypto transactions and these name and physical address fields being filled with respect to people who aren't even the exchange's customer. And this is something I want to point out as particularly egregious. And we point this out in our comment. We drafted a comment in a hurry, although I think we did it in an excellent job laying out all the privacy and constitutional arguments and process deficiencies in that comment. And we filed it. And in that comment, we talk about the Fourth Amendment, which, if you're familiar with constitutional law, the Fourth Amendment says the government's not supposed to search your private papers and effects without a warrant and particularized individual suspicion of a crime. And the Bank Secrecy Act is this law that says, hey, if you're a bank, you need to, on behalf of the government, collect everybody's financial records without individual suspicion and without a warrant and give them to us. So the question is always, why is the Bank Secrecy Act even constitutional if it's this massive warrantless dragnet? And the answer comes in the form of the third party doctrine, which is this notion that when you hand your information over to a third party, whether it's a bank or whether it's like an email provider like Google or something like that, you lose your reasonable expectation of privacy over that information, which means, according to the Supreme Court in the 1970s in California Bankers Association versus Schultz, the government doesn't need to have a warrant in order to get that information. But there's something interesting about the third party doctrine. Recently, in a case called Carpenter, the Supreme Court came out and said, yeah, so cellular phone providers have a lot of location data on customers. But the customers didn't voluntarily give that information to the third party, and that third party doesn't hold it for a legitimate business purpose. So actually, we think even with the third party doctrine notwithstanding, a warrant should be required for law enforcement to get your location data from a cellular provider. And so you take that and you apply that to this situation with the Bank Secrecy Act, where they're collecting this information about their customers. They're also, under this new proposed rule, they're obligated to collect information about their customers' counterparties, the people that are paying their customer and the people their customer are paying. And those people are not voluntarily handing their information to Coinbase. Just by making a transaction from my personally hosted Bitcoin wallet to Coinbase, I didn't sign up for this kind of surveillance regime. I didn't hand my information over. I retain a reasonable expectation of privacy in the very important data, which is that linkage between my real identity and my Bitcoin address. And forcing Coinbase to effectively collect that information and search and surveil me is basically like forcing Coinbase to come into my home and take a piece of very important paper or information from my home. And so I think there's actually a really strong Fourth Amendment argument that this proposed rule is unconstitutional. And that's one of several arguments we made about why this rulemaking should not go forward. From a layman's sort of perspective, when we come to talking about old things to politicians so they can understand it better, is there a material difference between sending your Bitcoin from an exchange to somebody else as it currently stands and going to your bank and getting a money order? Because as I understand it, a money order doesn't have a recipient. It's paid for in cash. You give it to anyone. That person goes to any bank and then they get cash. And to the best of my knowledge, they just show identity documents that say that they're the person on the money order and then that's it. So is this the type of thing where if a money order was trying to get made today, the government would make it illegal? Is there a double standard here? Is the government going to ban money orders? I'm just trying to process in what ways this is different than that. And why is there a different treatment? Yeah, you've hit the nail on the head. There's different treatment here. And that gets to further arguments as to why this is inappropriate. Because Vincent has always taken a technology neutral standpoint where it's just same risk, same policy, same business, same policy. And this breaks with that. It says special treatment for certain types of businesses, even if the risks are the same, because you're spot on that a cashier's check, many types of money orders, even a personal check, if it's they got endorsed to several other people along the chain because you can do that, you can sign a check over to someone else, you can make a check out to cash. These are all effectively bearer instruments. And the bank has no idea where they're going to end up, which is why the regulations are flexible with respect to the information the bank needs to collect about those transactions. Now, there is a special report that is triggered when you deal with these so-called bear instruments or monetary instruments. And it's called the currency transaction report. So if you take more than $10,000 in cash out of your bank, or you ask for a $10,000 or more cashier's check, or you get one of these money orders to cash that's over $10,000 in all those situations, the bank isn't going to know who you're paying. And that's accepted and acceptable by the regulator. But the bank is going to be obligated to file a report saying, hey, my customer just moved a lot of liquid funds. And that's going to raise suspicion about your activities. And we can argue about whether this is good policy or not, but that's the way things are for similar instruments to Bitcoin. And so if all of this rulemaking was doing was saying, let's apply the same currency transaction report requirement to Bitcoin transactions, it would extend the surveillance regime. And so that gives me an agita, if you will. But at least it would be equal treatment. Instead, this is saying, let's have the reporting requirement for transactions over $10,000. And for any transaction over $3,000, a completely lower threshold, you also need to know the physical address and name of the person you're customers ultimately paying with those funds. So it's just unacceptable that it's this unbalanced playing field. I think there's another little hidden nugget in there, which is the $10,000 amount. And now the $3,000 amount. Because when the BSA was passed in, what was it, 1971, the amount was hard-coded, not indexed to inflation, not adjusted for purchasing power, nothing. And so, yeah, sure, $10,000 in 1970s dollars, huge amount of money. Now can't even buy a quarter of a car, according to the latest statistics. So what's changed is that they put these hard-coded numbers in there and then let inflation do its job so that essentially the banks are playing this regulatory limbo where the bar keeps getting lower and lower and lower and the banks are contorting themselves for a greater and greater and greater percentage of the transactions that go through them simply through monetary inflation. And they're doing the same thing with the $3,000 today, but 3,010 years time is going to be two lattes. Yeah, especially with the quantitative easing that's going on. Andreas, what we should really be asking for, although we'd never get it, is that they hard-code the numbers, but in Bitcoin as the numerator. You know what? I'd like a different one. Let's hard-code the numbers so that the multiples of federal minimum wage for an hour. So what you say is you have to do a suspicious activity report if it's more than 700 hours of the federal minimum wage. We'll watch them have to change that too. So we've actually already averted the worst-case scenario, which is good news. The worst-case scenario was that Secretary Mnuchin, former Secretary Mnuchin now, his treasury would finalize that rulemaking 15 days after it was announced, which would have been before the new administration came in, the Biden administration. And once that rulemaking is finalized, it becomes effectively like law. You'd need to create a whole new proposed rulemaking to overturn it. There'd be a whole process. And even if the incoming Biden administration is less hungry for this kind of record keeping, which there's arguments that they might be a little less focused on this particular rule, they would have to go through this process of reopening and changing something that's already lost. So unlikely to happen. Now, fortunately, in part, I think because of the deluge of comments and many very good comments that FinCEN received in the rulemaking, we filed two. The Electronic Frontier Foundation filed a great comment. DCI at MIT filed an excellent comment. And there were, as I said, 7,000 comments in total, which is more than FinCEN's ever gotten. FinCEN normally only gets comments from a few financial institutions. I remember reading somewhere that in the past 10 years, this one comment period has received 70% of all public comments that FinCEN has ever received. That sounds right. And the reason why this is important is they're obligated under the Administrative Procedure Act to read and consider every comment. Now, they could claim that they've hired a whole bunch of temps or something, I suppose, but it starts to look very disingenuous if after a 15-day comment period you come out with a final rule a day later and say, yeah, we read all 7,000 comments. So in part because of the number of comments, the quality of the comments, the arguments raised, maybe the Fourth Amendment argument, maybe the procedural arguments, which is that normally comments take 60 days. Banks have sometimes had six years to offer input on new record-keeping requirements. Because of these several arguments, I think, they decided to extend the comment period. And that meant that the comment period got extended into the next administration. It's also worth noting that it was probably as short as it was 15 days because it was meant to fit at the very end of the administration, not for some actual real public policy concern. And so once it got extended into the Biden administration, the Biden administration, before they even came in, announced, look, we're going to put a freeze on all pending executive actions. So all rule makings included. And this, along with lots of other things that were in progress from the last days of the Trump administration, got frozen. And that is very promising because it means that folks at Finstan, for example, who are more career staff rather than political appointees, who may have had reservations about the rushed nature of the process, will be able to have their say with a new administration and say, look, there are a lot of reasonable comments that just came in. We're taking them all in. Maybe we should just seek equal treatment with traditional financial record-keeping and reporting requirements and not go for this extraordinary record-keeping requirement. Or maybe even better, it just gets dropped because the Biden administration says, look, we're not going to continue this. It was a product of the last administration. We might do something on our own down the road, but we're going to drop this one for now. I have some insights into why Mnuchin chose to do a 15-day comment period. It has to do with the background of former Secretary Mnuchin. And you see, most people don't remember that Mnuchin is the same s*** who made millions and millions of dollars from robo-signing mortgage foreclosures and then managed to get away with it without engineing up in prison, as he very much should have. So maybe what he was thinking was that he could robo-process all of these comments with the same degree of disregard for due process, common decency, and humanity, as he did when he was previously a s***. That's just my interpretation and opinion, of course, just in case we forgot who he was. Thank you for that, Andreas. What is the process for making a comment in a public comment period such as this? Like, do tweets count as a public comment, or do you have to like write them a letter? I had the same question. I asked if you can attach images. Yeah, I'm curious about that. You could submit a PDF with some images if you wanted. It's a good question. Sometimes they just open an email address and say email us. They didn't in this case, which made it a little tricky to get them to be deluged with comments because it would have been easier to just set up a form that manufactures emails. This time it was a really difficult to use probably PHP form on a website where you can upload a PDF. Just in general, on the process of soliciting comments, so to your listeners who aren't familiar with the administrative law procedures, this is a way to really get the numbers juiced on your subscribers. We appreciate it, Peter. For people who aren't familiar, you say, like, what is this? I thought Congress makes laws. You are right. Congress is supposed to set policy. Congress is supposed to be the democratically elected people who are accountable to the public, who decide important consequential things about the way our government works, including things like whether your privacy is going to be violated or not, right? Well, unfortunately, Congress kind of abdicates its job quite often, creates a broad statute that empowers a branch of the executive government, so treasury in this case, with sort of a lot of power to rewrite rules. And that's not technically lawmaking because that would be wrong. That would violate the separation of powers. That's the job of the legislature, not the executive. But it's basically what's happening. And in the 1950s, in response to the explosion of the administrative agencies and the number of rules that were being made by people who aren't democratically elected representatives, we passed the Administrative Procedure Act, which says, look, if we're going to have these technocrat bureaus making law effectively, it at least needs to be done in a transparent process that respects input from the public. It was sort of a fig leaf for democracy because honestly, they just get to listen to your comments. They don't have to really take them to heart. There's no voting involved here. But it was at least something in a process that was otherwise a complete black box as to how new rules get put in place. And so even that fig leaf, even that APA that says that they have to consider public input and they have to have a notice publicly of the proposed change and then have a 60 day or so comment period where they accept feedback from the public, even that is being ignored in this case. So it really is a sort of failure of democracy. I think that this demonstrates the anti fragility and growth of Bitcoin because the last time Bitcoin was attacked by a website written predominantly in PHP, it was Mt. Gox. So Peter, this has been great. We really appreciate your time today. And as we wrap, I'd like to get you to take on one thing. So Janet Yellen, former Fed chair and current nominee for treasury in the new Biden administration recently said something to the effect of, I think crypto is mainly used for illicit financing with specifically a reference to terrorist activity and things like that. This comes at a time when tensions are kind of high around what's going to happen with Bitcoin. And it comes sort of as a contrast to what we've seen from some of the industry surveillance companies out there like Chainalysis, which in a recent report basically said that about 0.34% of all activity across Bitcoin is actually illicit activity. So I mean, what is your expectation for the approach that we're going to see from this new administration? I appreciate that I'm asking you to pull out your crystal ball here. So just best guesses only. No, it's a totally fair question. But I think the quote that is being spread around as sort of ominous, as an ominous sign for what we'd expect from a secretary Yellen going forward, is an overstatement of her position in her written testimony and in written responses to additional questions about digital assets and things like this. She took a much more balanced view. She said, and I'm quoting now, we need to look at the potential they have to improve the efficiency of the financial system. We know they can be used to finance terrorism, facilitate money laundering and support malign activities that threaten US national security interests and the integrity of the US and international financial systems. And I think we need to look closely at how to encourage their use for more legitimate activities. So this is the kind of typical balanced approach we would expect from a regulator who is tasked with stopping money laundering and stopping terrorist financing to say, look, there are legitimate uses. There's ways to encourage responsible innovation. But they're going to be focused on these things. And that's their job and that's reasonable. And it's the job of organizations like Coin Center to effectively lobby them. We don't lobby on behalf of any companies. We lobby on behalf of the raw technology itself, the protocol that's so well documented to describe by Andreas. That's what we go to do is to educate people about how the tech works and why there are really promising use cases, why this is something that will ultimately be a boon for human dignity and privacy and a healthy America. And so I did want to get in a quick plug before you let me go. If you are interested in supporting our work at Coin Center so we can keep churning out comments over Christmas holidays and doing our other activities. We're really excited to announce that through the month of February, Grayscale Investments is going to be doing a matching campaign for every donation put in. You'll double your money through Grayscale, basically, up to a million dollars of a donation to Coin Center. So now is a really good time to support us if you think the work we do is important. Send Janet Yellen a Valentine's card this February by funding Coin Center.  So what you can do is donate in the name of Janet Yellen to Coin Center. Peter, just to clarify for those who are thinking in the past calendar year, that matching program last through December of 2021. No, no, no. It's through February of this year. It's just the month of February. Peter, if people want to find the website, if you want to support the work, where should we be going to? You can find all our public policy resources and make a donation on coincenter.org. And Coin Center is 501c3, right? Well, no. We're 501c4, which allows us to do more direct lobbying of folks, but it's not tax deductible to the donor then. Okay. So then you're not giving any additional tax write-offs to Janet Yellen should you donate in her name. So go ahead and do that. And then for those who have not been following Coin Center as heavily as they should, they have been one of, if not the most prominent, long-lasting advocacy groups that are nonpartisan for the betterment of Bitcoin in the cryptocurrency community, sort of bar none. And I'll say that in the early days, we all thought that that might have been the Bitcoin Foundation. And a lot of what Coin Center came to be came out of what people thought the best of the Bitcoin Foundation could be. And I'm telling you, Peter, in hindsight, though, you know, I won't betray my past self, I do wish right now I had 3.5 Bitcoin to give to Coin Center instead of the lifetime membership I got to the Bitcoin Foundation. And that's a wrap on another episode of Speaking of Bitcoin. Today's episode featured Peter VanValkenberg, Stephanie Murphy, Andreas M. Antonopoulos, Jonathan Mohan, and myself, Adam B. Levine. This episode was edited by Jonas, featured music by Jared Rubens. Thanks to all the hosts for the time today and to all our listeners. Stay tuned for our next episode.