RULEMATCH Spot On – Delivering on Digital

How do you lay the foundation for fully digital capital markets? How far has work actually come in integrating a central bank digital currency into efforts towards tokenization?

And how is Switzerland pushing the industry forward in the next evolution of financial markets?

In Part 2 of this RULEMATCH Spot On episode, Ian Simpson and David Newns, Head of the SIX Digital Exchange (SDX) discuss the different ways that Switzerland has played a leading role in the development of the digital assets industry globally – with the support of the Swiss National Bank and others and with close input from FINMA.

 

 

Episode show notes:

(1:57) – Project Helvetia and why “equivalence” is a victory for Switzerland

(5:59) – The evolution of banks’ capabilities with digital assets

(9:24) – How banks are opening their minds to new use cases

(10:38) – Growth in number of member banks on SDX

(11:50) – Banks building or offering custody services for digital assets

(13:02) – Details on custody setup on SDX

(14:12) – The chicken-egg topic of dealing with crypto and digital assets

(16:13) – Looking at SDX’s crypto custody and repo services

(17:26) – How custody will enable crypto collateral mobilization from banks on SDX

(20:49) – Why collateral and lending with digital assets is critical in capital markets

(21:59) – Regulatory advancements (in Europe and Switzerland) and their implications

(23:51) – The significance of USDC/EURC MiCA approval

(24:42) – The challenges of DLT securities in Switzerland

(27:57) – Switzerland’s “central” role in global CBDC projects

(33:07) – Why Switzerland is still “winning the digital assets race”

(35:34) – A “sea change” in digital assets moving things forward

 

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Episode transcript:

 

Ian:

But Switzerland is still winning the race…

 

David:

So despite all of this, so also clearly everyone is carrying out POCs and experiments.

And then the ECB has three experiments around this as well.

 

Ian:

But nobody has built exactly what we have built in Switzerland.

David:

As far as a Western developed economy, there’s nowhere else in the world where you have security transactions in wholesale CBDC, where in a production environment you have the central bank issuing tokenized central bank money.

And the fact that they’ve now made that statement that this will…they’ll continue to support this and issue central bank money on chain in two years, expand the scope, include more members…

That’s a huge statement.

 

 

START OF FULL EPISODE:

 

Ian:

I’m your host Ian Simpson and today we bring you the second instalment of my conversation with David Newns, who is the Head of the SIX Digital Exchange (SDX).

In Part 1, we discussed the development of SDX and its focus on digital securities and some of the “under the hood” aspects of SDX, including its distributed central securities depository and the trade-offs between “precision settlement” and post-trade settlement with netting as well as the need for proper regulation and a riskless payment currency for wholesale settlement between banks.

In Part 2, we discuss the ongoing development of SDX and wider topics and developments in Switzerland and beyond, with the involvement of SDX, the Swiss National Bank and many other players.

 

David:

So here in Switzerland, there’s been a multi-year project, five-year plus now, called Helvetia, which has been the SNB’s initiative to explore this whole concept of tokenized central bank money.

So having issuing central bank cash on chain with Helvetia 1, looked at, technologically was it feasible?

And that was a BIS, SDX, SNB initiative.

Helvetia 2 involved a swathe of market participants, large and small banks. And then that proved out that operationally and from a regulated perspective and from the perspective of integration into core banking systems, so actually watching the flows- go all the way through from tokens being issued to settlement occurring and being recorded in banks, internal systems.

You could achieve that with central bank digital currency.

And then Helvetia 3, which was a landmark in capital markets globally, was the first time that central bank money was ever issued on chain in a production environment for the purposes of settling transactions.

We have now settled over 700 million francs worth of transactions on SDX in wholesale central bank digital currency, which that in and of itself is, it puts Switzerland at the very forefront of the adoption of digital assets on a global basis. So that level of innovation is really quite staggering.

And it doesn’t stop there because two weeks or so ago the central bank announced that they were going to prolong the support on the CBDC on SDX for a minimum of two years with a mechanism for rolling that on forwards and that they will expand the participants to anybody who is eligible for an interbank clearing account at the SNB and is a member of SDX and in addition over time increase the scope of functionality so we can address all the other pieces.

Because what we have now is rather limited in scope in terms of what we can do with the CBDC to all the other kinds of operations that get conducted in CBDC and capital markets on FMI.

So that, actually, kind of catapults Switzerland not just to sort of stay at the forefront, but it’s a huge leap forward.

And there really is no other developed Western economy that stands at that point in the adoption of digital assets.

And if I go back to that structure that we’re putting together, where we have this, the right regulation, a regulated blockchain, we have interoperability with the traditional infrastructure, we have a network of member banks on that platform who are carrying out activities.

The sort of the third leg to a stool was going to be the riskless settlement asset being available on chain, so that you now built up this infrastructure – this architecture which is going to be strong and stable enough to be able to then facilitate the use cases that we are all excited about.

So we’ve now achieved equivalence.

Hooray.

So with all those pieces in place, you absolutely can do everything that you can do on traditional infrastructure, but now using blockchain and tokenized instruments.

Again, nowhere else in the world has this been achieved except for here in Switzerland.

And I think that the Swiss financial center should be appropriately proud and also excited about this opportunity that it’s availed itself of.

It really will, I think, ultimately be a massive differentiation for the Swiss financial center when it comes to its place in the world.

 

Ian:

Going back to a topic that I wanted to come to earlier with the members on SDX and working with this infrastructure, obviously they’ve given lots of input in how it’s built, but then they themselves have also needed to build up their capabilities to interact with this, to be able to read this decentralized CSD, and then also to work with custody, right?

How has that process gone and where are members and maybe banks more generally in adapting and getting ready for this next digitalization wave?

 

David:

So, it’s a very interesting question because it also has to an observation that this is, or an implication that this actually is a heavy lift.

And I would say that it is a heavy lift. We’re talking about a whole set of new technologies a bank is not familiar with.

Now, if I look at the first part, the first members we had of SDX, so our pioneers, UBS, ZKB and Credit Suisse, who came on board back in 2021.

Obviously, at that point, but we’re both learning and typically, this was their first experience of any interaction around blockchain technology being used in this particular way because we’re kind of unique in the world and still to a great extent are.

So that hasn’t changed a vast amount.

What you need to do as a member when it comes to accommodating this technology is ensure that all of your business support functions get comfortable with it.

And that is quite a significant lift.

So from a risk and legal…and compliance and technology perspective, you need to have these guys get comfortable, adjust or accommodate digital assets, tokenization, blockchain technology, cryptographically secured assets, management of private keys, all of that needs to be, and then integration into the core banking system.

These are all massive lifts, but either in terms of people or technology.

They all need to work to accommodate this technology into their control environment and technology environment and so on.

So one of the reasons why it takes us quite a long time to onboard a member is because the workshops we need to carry out with representatives from these firms are pretty extensive and very involved.

Because this is the first time that they’ve encountered this very frequent, very often, that’s first time they’ve encountered this sort of thing.

What you end up with afterwards is now you have enabled the capacity within that member, within that bank, for them to take that learning and that understanding and that technology and apply it to other contexts outside of SDX and SIX.

So I think that it’s an incredibly beneficial exercise.

For us, on the one hand, we were very concerned that clearly this is a big lift for a bank to start talking to actually get their hands around this.

What we didn’t understand, and the feedback we got from the banks was what a valuable lesson that actually is for them because it gives them this massive expansion of capability and understanding and capacities within their organization that they can apply to other contexts.

It’s another way that we – that SDX and Six Group – has played a role within the Swiss financial center is issuing digital bonds.

And I don’t really think that we’ll even…

We’ll stop marketing the fact that we have issuances of digital bonds when they happen anymore because it’s becoming par for the course. When you stop talking about it, it is a massive day, I think, because it’s become commonplace.

And that’s really because the members, the community here has reached a degree of sophistication and understanding that this has become something which is every day for them.

That is not the case in other jurisdictions.

And I think that capability can be, as I said, can be transferred to other contexts and it’s a capacity that is going to benefit the entire Swiss financial centre because now we’ve moved to, that was three banks back then, we more than tripled our membership last year.

So we ended last year with 13 members.

We should at least double it again this year.

And that will also include bringing on our first US banks, more international members.

We…Commerzbank was the first international member that we onboarded at the end of last year. We also…and they were also the issuer agent for the World Bank bond.

So we’ve really kind of crossed a- I think – a chasm in terms of the number of, and the kind of members that we’re now onboarding to the platform.

But if you look down the list of banks in Switzerland, all the top banks are now onboarded onto SDX and then the next tier and probably the next tier as well.

That again represents a capability in the regulated capital market space in Switzerland that hitherto was only within the non-regulated sort of “Crypto Valley context.”

That’s where that understanding, now that understanding has spread to the regulated sector as well, which I think is a huge benefit for Switzerland.

 

Ian:

When we talk just about custody, that was one question that came up in my mind. banks always face that “build or buy” kind of conundrum, right?

And yeah, it takes a long time to build up the internal processes and understanding of things. Then when it comes to custody and handling, there’s many companies working in the cryptocurrency custody space, some also working in the tokenized securities space and in some cases those capabilities cross over.

Do you think banks will outsource some of that capability to other companies? Will some of those banks turn their capabilities into a service for other banks?

How do you think about it?

 

David:

I think all of the above, yeah. I think it depends on the organization and its appetite for providing different kinds of service. And it’s history.

I mean, it could well be that it builds up a competence and gets excited about actually pursuing commercial activities represented by digital asset custody.

In the context of SDX, the wallet infrastructure is integrated into the nodes that they run so that they simultaneously host the nodes, they run the nodes – also manage the wallets, they manage the private keys in the wallets.

That’s actually a requirement of our members.

They do not outsource back to us, for instance, because legally they have to manage their own private keys.

So far, as far as I’m aware, none of them have outsourced that service to, that requirement to a third party.

Now, in the future, when we’re talking about digital assets more broadly and including custodying of security tokens or governance tokens of cryptocurrencies in that context aware these tokens are from they represent holdings on public chains and there are now third-party custody platforms that you could potentially leverage that or third -party custodians that you could use your sub custody and so on.

I think that yes, it’ll be a variety of different approaches will be taken by banks as to whether they choose to outsource or insource that activity.

 

Ian:

So, some people have said, and you talked about it a little bit earlier, there’s a lot of innovation happening in the crypto space, and then you learn from that and apply the lessons.

Some people have said, well, those who maybe offer cryptocurrencies and trade cryptocurrencies today will be some of the first that move into tokenized securities in a more regulated capital markets standpoint.

Do you think that’s fair to say or is it not necessarily the case or is there going to be learnings that some banks take from here and apply here or not necessarily?

 

David:

I think that it’s certainly very helpful to have the experience, mentioned before, of what it means to leverage this technology in the context of SDX and digital securities.

That will certainly, I think, put you into a more comfortable position because you have expertise in-house about that.

To your point about custody as well in this context, I can see that in the short term, certainly the demand for using third-party custodians is going to be extremely high.

Because even though we need you to do custody of your private keys and so on for digital securities, the complexity of running custody for a multiplicity of coins, that gets really significant really quickly because they’re all a bit different and they all have different requirements, especially when it comes to coins that have governance processes built into them where you expect to vote on certain matters associated with the chain and how you do, you need to do that by the custody platform.

There’s a lot of changes that need to be accommodated to actually facilitate that.

If your customers are asking for new coins and the processes that you need to go through can be very heavy in terms of determining whether you should include that, which is one of the reasons why…

So we do provide crypto custody-as-a-service to our members as well outside of our FMI structure.

So if I move and look at our cryptocurrency offering specifically, that is very much orientated around a custody offering.

And there’s two areas I think are really interesting.

One is this getting your hands around “crypto custody” is a challenge for an organization.

So here is an institutional grade custody solution built on top of Fireblocks.

It’s a hybrid solution in that we also – we manage the operations related to the private keys on that platform, which sets it apart from other providers of custody where those private key operations are still managed on cloud very frequently rather than on-prem on technology that we actually own and operate ourselves as SIX Group, which is much more akin in many ways to us managing the enormous vault that we keep real gold in, right?

We’re good at looking after things that are incredibly valuable, where processes and controls are absolutely critical.

So we have that as a service, but also historically since the CSD is also essentially a custody platform.

The need that we see based upon how we see the CSD being used for, as we mentioned before about collateral mobility – the CSD on the traditional infrastructure has innumerable sets of different kinds of services.

But one of them is the “tripartite repo service” where you as a customer manage the collateral frequently that you have under custody at SIX SIS to manage credit lines with other platforms.

Now, with platforms that you then trade on – in the context of some of our customers, the collateral that is being deposited is collateral from their customers.

They want to be able to keep an eye on the collateral that their customers are depositing with them, so they can then extend credit lines to those customers, enable them to trade on third -party platforms.

In the context of crypto, those third-party platforms are typically crypto exchanges.

And in the context of crypto, the customers of that, of the consumer of that service, the collateral management service, those customers are frequently crypto natives.

And oddly enough, a lot of their collateral is digital, not securities.

So you have the situation where this is a facility which traditionally we’ve been doing for years in the traditional world of helping customers manage collateral to extend credit lines.

But in this context of crypto, where credit lines are everything when it comes to transacting on platforms, if that collateral is digital, then you might have a challenge.

But because SDX has a crypto custody platform, we can take in that crypto custody and immobilize it on our custody platform, represent that collateral inside SIS’s existing collateral cockpit so that within one view, a customer, market participant, can see collateral – whether it is traditional securities or crypto – and manage that effectively to ensure that they completely comfortable and managing credit lines in the most effective way possible in that tripartite repo context to enable the maximum credit lines to be enabled between their customer and that trading platform.

So that another example of interoperability and I think something that’s just kind of rather unique in this space and something where an FMI can play a really interesting role because it’s extending its traditional role again into new markets in this case into crypto because of its ability to provide regulated trusted infrastructure from a party which traditionally has done this as their bread and butter.

 

Ian:

Interesting. I could see that being a very interesting development in the space. Again something not so, shall we say, sexy as far as innovation, something in the capital markets that is very, very…

 

David:

In capital markets, this facility drives capital markets.

I mean, your ability to manage credit lines so that you can actually trade in the first place is absolutely critical.

You do that by posting collateral. If you can only post a subset of the collateral that you have available to you because half of it is, or more of it, is crypto, then that’s inefficient. Whereas if you can also include crypto in that, we extend the ability to provide that to do external credit line.

More trading can occur in that context of regulation of safety, specifically everything that the institutional world requires to conduct these activities.

 

Ian:

Then we could imagine even more crypto foundations, people with these kinds of assets, high net worth individuals and so on, flock into Switzerland and take an advantage of this.

 

David:

Exactly, because we know that again some of those foundations now manage, they hold both crypto and traditional securities in their portfolios so they can again leverage that entire set of instruments for the purposes of activity trading.

 

Ian:

Let’s go back to the topic of regulation, not to go too deep and heavy into it. MiCA just came online, so to say, in the last week or so, but before we get there.

There’s also been some advancements in Swiss DLT law in the last few years.

What do you think about that and how would that apply or not apply to what SDX is doing or wants to do in the future?

 

David:

So those two bits of regulation are interesting.

I think MiCA going live very recently – in terms of coming into law – that I think is of enormous significance.

The fact that you now have the world’s second largest economy with effective, sensible (for the most part) regulation around crypto assets.

And again, specifically, it’s crypto.

It isn’t digital securities.

There, there’s still a little bit of a hole in terms of cross-jurisdictional regulation.

Or basically, there isn’t any cross-jurisdictional regulation in the EU that covers digital securities, which is an interesting fact in and of itself.

And what we’re going to see is, again, that’s a catalyst to adoption and to the institutional space when it comes to participating in the crypto universe, as it were, with that as an asset class.

So it’s, again, different to leveraging blockchain to add efficiencies and open new capabilities within the existing capital markets.

It’s like it’s a new economy as it were.

It’s like encountering a new country and then being able to actually invest in that country’s economy.

And the things I find exciting this year have been, yes, MiCA.

And a good example of something that’s already happened, which is I think again, a sort of a milestone is the fact that Circle – for USDC and EURC – was granted a license, an e-money operator license earlier this week.

So congratulations to Jeremy, Dante and team for achieving that world first.

I think that’s really significant.

I think as significant as Switzerland actually extending its CBDC – essentially on a path to full production.

And that will act as a catalyst, I think, for broader adoption because once you have that sort of regulatory certainty then you can build on that.

 

Ian:

And regarding the Swiss regulation, there’s a DLT securities…

 

David:

So I think really innovative…

The challenge that we have with DLT securities and I think that’s one of the reasons why the market isn’t sort of swinging over to DLT securities like any pace, is that?

It doesn’t really address the sort of the UX issues as people refer to them.

One of the benefits, and I’ve got to go back to this notion of interoperability…

If, as an investor, to hold a kind of an instrument requires that you accommodate, embrace, implement an entirely new kind of infrastructure.

And here we’re talking about wallets and connecting those wallets to public chains and then managing your private keys in those wallets.

As an institutional investor, that is an enormous lift and something that at the moment is not easily facilitated by your custodians, except for in a small number of cases.

I think in the future that will change as custody platforms either get provided by third parties such as ourselves to banks or the banks themselves ultimately roll out their own custody platforms to make the process of holding those securities more seamless to the underlying investor.

Because what you don’t want to do is just make it more difficult and add risk to that underlying investor’s world.

They want to focus on what they’re good at, which is determining what assets they want to hold in their portfolios and managing those assets as effectively as possible.

They don’t want to be worrying about implementing and managing wallets and keys.

Digital securities being natively digital on public chain are a bit challenging to consume at this point in time.

That’s the intermediated securities that are more traditional, the way that right now the majority of value that’s represented in terms of digital securities is being held, has been issued and being held in Switzerland.

But I do think it’s really interesting step forward.

There is some questions around how as an institutional client, you might hold that.

I see that being a bit problematic in terms of the DLT security is meant, it should be considered a security under the law, but it’s a bit in contradiction to the BIS’s treatment of crypto assets, which says that permissionless tokens are crypto assets and again, and should be treated essentially the same as a cryptocurrency like Bitcoin.

So as a bank holding that asset on your balance sheet will incur a 1250% capital charge, which makes it very uninteresting as an instrument to hold on your balance sheet.

 

Ian:

That’s a topic we’ve covered with a couple of guests already, the capital requirements. I think it’s not going to go away and hasn’t quite gotten cleared up or solved in that sense.

Let’s, as we move towards the end of the session, just talk about in the general context, and you talked about it before, Switzerland being very much at the forefront and everything that you’ve built at SDX really set in the standard very high for the rest of the world.

I had a conversation briefly with Thomas Moser from the SNB just about how other central banks look to the SNB to be involved in these bigger, broader global projects, which I think he and they are quite proud of.

Is there really mobilization based on what you’ve done at SDX to replicate this and build interoperability across jurisdictions and other places? And how is Switzerland positioned in that?

 

David:

98% of central banks around the world, according to that WEF study, the report that came out in April, which I thought was really good, by the way – and not just because we were heavily involved in being asked lots of questions about that on a wholesale CBDCs.

So 98% of the world’s central banks are conducting experiments in central bank digital currencies.

For all the reasons I mentioned earlier.

I mean, it’s that whole, if the world goes tokenized, they need to have something that is tokenized central bank money for all these reasons. there are other use cases.

But essentially, what we’re seeing as well is a wholesale CBDC is really being focused on I think more and more this year.

It feels that the whole retail CBDC thing is kind of dying away a bit especially for developed Western economies the eurozone. it is a bit different. I think they’re still pursuing digital euro with some degree of, asort of tenacity

But with this if you look at the plethora of CBDC projects that exist around the world today – it’s really, really remarkable.

So we have not only, again, that almost every central bank in the world is doing some sort of experimentation or pilot or POC in CBDC, but you have these super national initiatives that have either ones that have been going on for quite some time or that have been recently announced.

Here in Switzerland we have, we did some pretty substantial super national activities already.

So we did Project Jura, which was between the central bank, between the Swiss National Bank and the Banque de France conducting wholesale cross border payments in CBDC – again, leveraging the SDX platform to facilitate that.

There’s been Project mBridge in which is another BIS initiative which is CBDC cross border between the UAE and HKMA and China.

Recently Saudi Arabia joined that initiative.

There’s some enormous number of observers as well to that.  I think Thailand is involved as well.

Then more recently Project Agora, which is the BIS’s most recent initiative in the space, which is the seven central banks that represent the largest currencies by trading volume in the world.

They have all signed up to this initiative to do cross-border payments, this concept of the unified ledger that the BIS has previously talked about.

In Singapore with the MAS announced in November of last year at Singapore Fintech Festival, the Global Layer One Initiative, which is also really interesting.

I the G3 are involved in that. JP Morgan is involved.

And then there are private initiatives like Partior, which is a cross -border platform that is, again, JP/ Temasek backed initiative out of Singapore.

Then there’s the, I have two more, the Regulated Liability Network, which is Citibank’s initiative, Tony McLaughlin sort of being the godfather of that over in their digital asset department.

And the US equivalent again backed by Citibank, but with a host of other banks involved called the Regulated Settlement Network…same thing, different name.

And then Canton, this recently announced layer one, which is public permission blockchain, has many of features that look like it can also facilitate exactly the same use cases, but coming entirely from the private sector, but with this notion of a governance structure that makes sense in this particular context.

 

Ian:

And Switzerland is still winning the race, despite…

 

David:

So despite all of this, so also clearly everyone is carrying out POCs and experiments.

And then the ECB has three experiments around this as well.

 

Ian:

But nobody has built exactly what we have built in Switzerland.

 

David:

As far as a Western developed economy, there’s nowhere else in the world where you have security transactions in wholesale CBDC, where in a production environment you have the central bank issuing tokenized central bank money.

And the fact that they’ve now made that statement that this will…they’ll continue to support this and issue central bank money on chain in two years, expand the scope, include more members…

That’s a huge statement.

And actually, not just means that Switzerland stands at the front, but I believe that that really pushes us ahead.

And it’s something which is hard to replicate. just because we’ve achieved so much and we’ve built so much already.

But the structure in Switzerland between the Swiss National Bank, as mentioned earlier, this mutualized infrastructure, which is member-owned, the relationship between SIX and the SNB, I think that’s a private-public partnership, already entails our support for the RTGS platform that the SNB operates, the repo platform the SNB operates, and also having a regulator such as FINMA and having informed individuals over there.

I think we have regular constructed dialogues with the likes of Matthias Olbrecht on the FinTech Desk there, really informed individuals who are themselves, I think, pioneers in this field.

The individuals and as well as the organizations that they work for, that capacity, that capability, and that pioneering perspective and that awareness to maintain our edge as a center of financial services that provide the most innovative but also the most safe and secure and trusted services in the world as Switzerland…

That does require that we are pioneers in this new space and we are pushing forward to these new horizons.

And it’s very, very satisfying to see that demonstrably that is the case.

 

Ian:

Definitely. definitely.

We have one question left. We ask every guest that comes on the podcast.

Is there something both at SDX or more broadly in the market that is happening that people aren’t talking about, that you can think of, maybe give us a hint to watch out for in the next 6, 9, 12 months.

Something that will be very interesting to see develop.

 

David:

Well, I talked about how it feels like there’s been this sea change and the visible manifestations of that, think, are Circle being granted an e-money license in Europe – the largest economy in the world, largest market in the world, now regulated through MiCA.

The CBDC initiatives here in Switzerland, these are visible indicators of something that’s happening.

What we’re feeling at SDX as a result of the momentum that we’ve seen following the announcements and the background, sort of the tailwinds from the adoption of assets more broadly, but also the support of our stakeholders such as the SNB and our members.

The flurry of new onboardings we’re having at the moment, what we’re seeing different about the conversations we’re having now is that our members are bringing us use cases that they want to actually leverage our blockchain to deploy, to actually further their own digital ambitions.

So it’s no longer the case that we are trying to persuade people that there’s something special about blockchain and that now “Why is a digital bond better than a traditional bond?”

That conversation has changed to “I see that you have digital bonds available on-chain, you have a central bank digital currency available on-chain within the context ofwhat you can provide to the market I want to be able to facilitate these use cases, I have this requirement for you guys to actually do, to actually enable me to take advantage of…”

And they are around collateral mobility and fractionalization.

So being able to hold fractions of assets in customer accounts, which we can do.

So our CSD has unlimited capacity for sub-accounts, numbers of sub-accounts on the ledger.

Instruments that previously have been too lumpy, so the minimum size to hold has been too large, those can be fractionalized on our blockchain, on a piece of mutualized infrastructure – and then provided into and then held at the sub-account level so that you can actually enable new instruments to be held by customers – which as an asset manager previously you couldn’t do.

Again, then following on from that, there’s a whole bunch of other use cases that come out of that as well around programmability.

So you can then manage the distribution of assets held in a portfolio based upon a number of parameters which you can program onto the blockchain which will then automatically manage the holdings, these fractions and then the programmability.

They begin to see how the natively inherent functions of the blockchain are being exploited by our new members who are coming on board.

And I believe in the next six to twelve months, we’ll begin to see production implementations and examples of totally new innovative solutions being provided to ultimately the underlying investor.

And that also comes in a cost-effective fashion.

So we believe that that is where you really begin to see the benefits of all this building work that’s been done.

You’ll begin to see that superstructure of the skyscraper in all its gleaming glory begin to sort of appear having done all this hard work of building the foundations.

That’s been carried out over the last five, six years here in Switzerland.

 

Ian:

Super – very, very interesting. We’ll be looking for that.

David Newns, thank you very much.

 

 

RULEMATCH Spot On – Making a Market

Consistent liquidity in crypto markets has never been more important than now. With the shift away from purely retail-driven buying and selling, market makers take on an even more essential role.

But as new financial products with crypto underlyings come to market – and market structures and trading models evolve, how the dynamics change? Will RFQ models and CLOBs exist in parallel? How will opening and closing times in TradFi influence market movements?

RULEMATCH Spot On host Ian Simpson welcomes Flow Traders Global Head of Digital Assets Michael Lie to the podcast to discuss all this – and more.

 

 

Episode show notes:

(:47) – Intro and crypto history at Flow Traders

(4:59) – Understanding market making

(6:35) – Crypto and TradFi market making compared

(7:40) – Evaluating the risks and opportunities in a new market like crypto

(10:05) – Mitigating counterparty credit risk with exchanges

(14:42) – Adapting to a lack of post-trade settlement and low latency infrastructure in crypto markets

(19:17) – HFT activity in crypto – past and future

(20:45) – How Flow Traders makes a market across different crypto market models

(25:50) – Transparency for institutional players in crypto markets

(27:42) – Advantages of post-trade over atomic settlement

(30:13) – The particulars of price discovery in crypto

(31:49) -Regulation and the development of spreads in crypto markets

(34:39) – MiCA, stablecoins and the euro stablecoin project of Flow Traders

(43:09) – A look back at spot BTC ETF launch in the US

(46:25) – Thoughts on an ETH ETF

 

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Episode transcript:

 

Michael:

Well, yeah, I would say that most large trading companies have joined this space already.

But now that, for instance, you see the low -latency exchanges, like also RULEMATCH has a very high -performance technology stack.

Of course, this becomes more important – that people have not just the knowledge, but also the network behind it to be able to compete at that level.

 

BEGINNING OF FULL EPISODE:

 

Ian:

Hello and welcome to another episode of RULEMATCH Spot On, the only podcast focused exclusively on the institutional crypto and digital assets industry.

I’m your host Ian Simpson. And if you want to know what banks, hedge funds, market makers asset managers and other institutions are doing in crypto and how they’re doing it – this is the place for you.

My guest today is Michael Lee. He is the Global Head of Digital Assets at Flow Traders .

Flow Traders , as most people would know, is one of the leading trading firms and market makers across various asset classes, also in crypto and digital assets.

And again, Flow Traders , one of our partners at RULEMATCH, is one of the designated and regulated market makers on the trading venue.

Of course, good to mention that nothing which you hear today is financial advice or an offering of any kind.

Michael, welcome to RULEMATCH Spot On.

 

Michael:

Thank you, Ian. Looking forward to discussing the crypto markets from a market maker perspective.

 

Ian:

So let’s start today with some high level questions, kind of background a little bit.

At Flow Traders, you are an experienced market participant, market maker, trading house, liquidity provider across different TradFi asset classes, and also now crypto and digital assets.

I’d be interested to know a little bit of the backstory, some of the flavor of how Flow Traders  decided to get into the crypto space. Can you tell us about that?

 

Michael:

Yeah, so Flow Traders has always been at the forefront of market making and actually already quite some time before we officially ventured into crypto.

We had people being active on exchanges like Mt. Gox on their personal account. So that got us a little bit of first-hand experience. And since then we were following the market.

So similar to how we expanded into other asset classes like fixed income, precious metals, we also saw an opportunity within the crypto markets that there was also potential for institutional interest.

So I think it was a combination of the entrepreneurship within the company, our experience in market making, but then also very importantly, the vision that we had around crypto, that it was an asset class that could grow and had a potential to get institutional interest.

And that’s why we decided to join.

 

Ian:

Was there something particularly about crypto that appealed to you? I can imagine maybe the volatility is an interesting aspect from a market making perspective?

 

Michael:

Yeah, that was definitely an interesting one and one experience that we learned very early on. Also prior to joining the crypto business, I was actually on the European ETF desk.

So I remember well when Brexit happened.

And this was an event that we had been preparing for weeks in advance for a scenario where actually a Brexit would happen.

On that day that it happened, we saw a lot of panic and chaos in the market. It was kind of unexpected.

And we saw asset classes moving more than 20% down. So because of our experience in market making, as well as the preparation displayed well into our hands. for me, it was one of the most memorable, rewarding days.

Then when we looked at the crypto markets, this is what we saw happening on a much higher frequency.

So we actually started in 2017 and it was myself starting out in Excel programming to the exchanges. And soon after, the CME announced they would be launching Bitcoin futures.

 

And we saw a similar type of volatility again.

So the experience that we had from Brexit and other events from our traditional finance experience really helped us then be able to handle such a scenario at a good pace.

 

Ian:

Interesting. Very, very interesting. Just looking at what you do at Flow Traders , I guess people understand the term market making, or at least they think they do, but we also know there are different flavors, different approaches, different strategies.

Without giving away any house secrets, can you just tell us, generally speaking, how Flow Traders  positions itself in the market making space and some of the ways you approach to doing that job?

 

Michael:

Yeah. So when we talk about market making, what we mean is that we are providing liquidity in the order book. So we are in with a bid and an order. And that allows for investors to exit and enter positions in an efficient way with little slippage and tight spreads.

So that’s how we see the role as a market maker. Then when you look into crypto, I think the role of a market maker is even more important because of the state where it’s in – the state at which projects get listed.

Comparing with an equity IPO, the company is typically well established. But for crypto, they launch at such an early stage that they get listed once a chain becomes live.

And the role of a market maker and for there to be liquidity allows, for instance, decentralization, which is important for the platform to be functioning.

So we approach market making similar for any other asset class, but I do think that with crypto, the role of a market maker is even more important.

 

Ian:

So you wouldn’t say there’s any great differences to how you approach, say the traditional ETF business or ETP business to market making in crypto assets?

 

Michael:

I would say we trade based on the same principles, the same trading principles. There are exchanges and an exchange in ETFs or an exchange for crypto, they function the same.

But our approach for each of the asset classes are different.

When talking about crypto, we need to be is to be very adaptable to changing circumstances.

Then you talk about regulation, about the technology, about the credit risk of the counterparties that we face. This has changed over time – again and again in all of these areas.

So our approach, I would say, there is more being adaptable to changing market conditions compared to other asset classes.

 

Ian:

So more flexibility is definitely a key in crypto, I can understand that.

Just going back to the historical part before we dive down into some more details, I can imagine as a regulated company with Flow Traders  being a listed company based in Holland but active globally, it would be a big decision to decide to really move into the space, into crypto and digital assets.

What were some of the evaluation criteria or some of the things that you said, now we need to make sure about this, we need to make sure about this and this. Can you high level go back to when you made that decision to start and give us some of the background?

 

Michael:

Yes, so high level, we identified three key challenges when entering this space. First one was technology, it’s a cloud technology, which is quite different than what we were used.

The second one was the credit risk that we would be exposed to when trading on the crypto exchanges versus more regulated exchange.

There is a large risk.

And I would say maybe the biggest challenge for us to make the decision was the regulatory risk.

Whereas when we entered, there was no regulation at all around digital assets and all the platforms that we would be trading on were unregulated.

So what we did is we proactively went to our regulator and we basically explained the current market structure – what our intention was to do in the market, basically providing markets, being the market maker in a market that is very volatile, but maybe not having the liquidity yet.

We definitely saw a need for us to enter that space from both a liquidity perspective, but also the perspective of maturing the asset class with our experience from trading regulated asset classes like ETFs and equities.

 

Ian:

Okay. So on some of those buckets, I think maybe we could dive down into a little bit more and also think about how it’s developed since you started up until now

As you said, you have to be very flexible to stay up with crypto market developments.

Let’s start maybe with, with counterparty risk or credit risk. That’s something that maybe people don’t talk about in the retail space too much, but of course is critical for institutions.

How do you, as a market maker, try to mitigate that risk?

What are some of the approaches you take to mitigate in the counterparty credit risk?

 

Michael:

Yeah, so maybe first to understand why are there larger risks. There is a big difference in market infrastructure for traditional exchanges and crypto exchanges. So when we would be trading and market making for ETF on the major European exchanges, we would have a bank account and we would be trading through a prime broker that would allow that access to all these different platforms.

So not only are we then exposed to just one PB that is regulated, they also allow us to use our capital on the multiple platforms.

On top of that, we are market maker trading from a delta neutral position.

Given our risk profile, the prime broker also allows us to leverage our capital.

Now when you go to the crypto exchanges, for us and for you, it’s like opening a separate bank account for each of them.

So we need to fund them individually and we are exposed to these risks given the states that those exchanges were in back then, you could argue that there was a larger risk in terms of defaulting than the exchanges that we were used to.

We had a few mitigating strategies there.

First of all, around the onboarding process, we were very diligent, and we did even more due diligence than we would do on a normal exchange – sometimes a bit to the frustration of the exchanges because they were not used to getting so many questions.

But it allowed us to select and filter out the bad and the good ones. That helped a lot in the beginning.

Second, we leveraged the blockchain technology because what the blockchain technology allows is it allows you to monitor the in and out flows of exchanges – through monitoring these type of activities, understand the flows of the retail coming in and out of the exchange.

And also you could see if there were maybe strange moves happening or there was a type of bank run taking place.

This also allowed us to spot some of the risks and events that happened bit earlier than the rest of the market.

Going forward, we are looking to see how we can work together with other partners to mitigate this type of counterparty risk.

For instance, we work with Copper. They provide an off-chain custody solution. This allows us to trade on the exchange, but keep the assets off exchange.

Potentially that moves into a phase where we can also use it for multiple exchanges. So we are actively looking at new solutions and working together with these partners to make changes in the market such that to an extent it looks a bit similar to what we are used to and we can reduce the counterparty risks.

 

Ian:

Okay, interesting.

So, and just to double click on one detail there, when you talk about opening a quote unquote “bank account” at each of those exchanges, that means you’re, basically having to fund in the funds on each of those venues, and have them available?

Because as we know, there’s no post -trade settlement set up like there would be in quite a few other traditional asset classes, right?

 

Michael:

Yeah, that’s correct.

 

Ian:

Like almost crypto exchanges, you would almost have instant settlements. So the moment you trade Bitcoin versus dollar, you immediately get the dollars into your account where – looking at, for instance, the ETF space, you have moved to T+1, but settlement cycles are either one or two days typically.

Maybe we’ll come back to that T+1 topic a little bit later, but one other aspect of your evaluation, you mentioned technology, and I can imagine Flow Traders  is set pretty well on the tech side, also for fast, low latency trading.

How much of that was a consideration for you when you were thinking about using some of the same strategies that you do in TradFi in this crypto space with, as you said, cloud -based infrastructure.

That’s not exactly what you were used to before, right?

 

Michael:

Yeah, I would say it was quite a different environment, something we need to adapt to, but also we saw as a challenge.

So I think a big difference there is latencies and also the indeterministic nature of the latencies that we have on crypto exchanges.

Comparing again to our traditional exchanges, they are built for low latency and we know exactly where they are located. We know how fast they process our orders.

We know how many meters we are away from that machine actually when we co -locate in the same data center.

So we can predict quite well what our latency will be when we’re trading on that exchange. And now when you look at the crypto exchange, when crypto exchanges started off, it was a retail market. It was dominated by retail basically.

For them, it was important to be able to service millions of users. And for that, the cloud technology was perfect because they could easily scale up or scale down the amount of resources they needed to be able to handle such loads.

But what they didn’t focus on, of course, was latency.

So when we entered this space, this was something we needed to understand. And we needed to deal with the unpredictability of the latencies.

Throughout the years, we’ve been talking constantly with exchanges on their technology. And on one end, we’ve learned a lot about the tips and tricks on how this cloud technology works and how we can improve our latencies there, how we can maybe integrate our cloud network within the more traditional network.

So getting the best of both worlds.

Also, we’ve been speaking to them about, okay, how do we set it up actually at the traditional side?

Because a good thing is now with also institutional liquidity coming in, latency becomes more and more important.

So they’re willing to listen to us and we also help them out in getting to a setup that is high performance and the metrics, for instance, are more predictable.

 

Ian:

So as kind of the F16 kind of machine that’s been used to operating at super high speeds, was a little bit of a slow down, at least at the beginning, getting into crypto, a little bit of a puzzle or a maze to figure some of those things out.

Do you think you’ve been successful in pulling things forward faster, kind of moving the cart faster along?

 

Michael:

Yeah, I would say so. If you look also at how we operated, crypto with the Flow Traders, and we’ve always been steadily growing our team. And we have now a team of over 70 people working on digital assets.

And even though the technology is different, I think to be competitive in the initial years, it was also more important that you are efficient with our capital usage.

 

And I would say then it was less important how fast you were, but just being in and being able to understand the products that are being listed, whether it’s futures or the perpetuals, which were quite new in that space, that was at that point more important.

But now you see more and more competition joining and then therefore it’s more of a requirement to be on top of your game on the technology part.

 

Ian:

Of course, small disclaimer here, Flow Traders is one of the designated mark makers on RULEMATCH. I think we speak the same language when it comes to ultra-low latency and how things will develop going forward.

But just scanning the market, do you see more HFT companies coming into the space? Do you think there’s going to more of an opportunity for that style of trading, not just from big players like Flow Traders, but from other smaller companies?

 

Michael:

Well, yeah, I would say that most large training companies have joined this space already because volumes have been very large.

Actually, think in the beginning there were a lot of small players that were entering this space because it was maybe more open, it was less regulated, so it was more easy to enter.

But now, for instance, you see the low latency exchanges, like also RULEMATCH has a very high -performance technology stack, of course.

This becomes more important that people have not just the noise, but also the network behind it to be able to compete at that level.

Actually this may be the other way around. And while smaller players have joined, you see this is getting more competitive and the larger players remain in markets.

 

Ian:

I think we also see the same thing.

Let’s shift gears just a little bit and talk market structure because I can imagine at the beginning, as you alluded to, that was a little bit of a challenge, kind of working through the maze of different venues and so on, but then also the different models of the market, you know.

On retail, so-called retail exchanges, you’ve generally had a central limit order book, but of course spread out all over the world across these different cloud servers.

Then there are other players who prefer to operate more on an RFQ model.

How do you as a market maker, you know, working across the globe in crypto markets, how do you deal with these different market models?

 

Michael:

Yeah. So, so if you talk about the most common market models, it is the central limit order book as you said.

And then you have the RFQ model, making also a slight comparison to for instance the FX market. They are quite a few similarities to the ECN model is very common, and they all serve a different purpose.

And if you look at the central limit order books, this is probably the most well-known model that that people know and exchange by.

So there’s an order book.

People can enter orders in the book and trades are matched if the prices are crossing.

I think the main advantage of this model is that it’s transparent and you have certainty around execution in such model.

Then if you look at for instance, the RFQ model, which is request for quote, this is typically used on a bilateral basis and it’s used when you want to execute a large order.

So if for instance you want to buy 100 million of Bitcoin, when you would go to your exchange, then you may not see that much of liquidity in the book.

The moment that you would try to execute it, either you would pay a lot of slippage, but more likely you would not get filled for the full quote, and you would also show the world basically that you are wanting to buy so many Bitcoins – which may move also the market in the direction you don’t want.

So in a model of RFQ, you would then go to, for instance, a market maker who’s connected to all the major exchanges and can typically hedge also these kinds of sizes in a more efficient way.

And in this way, it would also allow the information to be not exposed to the rest of the world.

Therefore, the RFQ model often works in cases where you want to execute a large size compared to the liquidity in the book on central limit oil books.

Then talking about ECNs, electronic communication networks, that is an execution model that’s often used in FX where makers and takers are split – separated from each other.

Makers are pricing to the takers.

And they don’t have to worry about maybe the very competitive market makers to trade against their quotes.

And this allows market makers also to be quoting tiny, quoting for more size.

So this has allowed the market, in effect, to become more liquid and basically trade at very tight spreads.

Yeah, when do you want to use such model? A nice example around the fit of a model is when the Swiss National Bank had sort of a surprise depeg of the Euro/Swiss franc.

And yeah, we were also trading it by then and we could see the prices, the prices up maybe more than 10%, but we could see the difference in prices on central limit order books and the RFQ and ECN models.

So you could see that firms were shifting to central limit order books because it gives the transparency of where the price should be trading.

And you also were sure that you would be able to execute.

Also the day after it remained a little bit like that. And I think now it has sort of returned in the old proportions again, but you can see how market conditions can change what kind of model is best fit for your purpose.

As a market maker, we are kind of agnostic to the market model and we will basically optimize our model apprising to what we see is basically allowing us to quote tightest.

 

Ian:

So different models for different situations for Flow Traders – it doesn’t necessarily matter. You did mention the word “transparency” in there and I’ll just throw this question in because when you think about funds or some large institutions, institutional money, those funds have a fiduciary duty to trade on best price.

And I’m wondering whether transparency or lack of transparency makes a difference where they are going to go to the market for what they do.

What do you think about that?  Also from a regulatory, fiduciary, legal point of view.

 

Michael:

Yeah, so I guess there are two angles to the transparency in the market.

So one is basically you want to execute a large book. As a market participant, as a fund, you don’t want that information to be published until maybe you’re fully executed.

So that should also determine somewhat which market model is the best fit.

Then on the regulatory side and on the crypto side, this is not that much developed yet.

But typically for other asset classes, there is a sort of time range in which you need to be reporting these kind of outside rates.

So I expect that will come also at some point for general transparency in the market and also being able see if you are able to guarantee the best price execution.

But that will have to wait until regulation is there that sort of forces things.

 

Ian:

Right. And regulation, as we know, is kind of a moving target, but some things happen in there.

And we might come back to that also in just a second.

We touched earlier on the settlement thing, and you mentioned kind of this instantaneous settlement, or some people like to talk about atomic swaps.

It seems like with the move to T+1 in the States for traditional assets, settlement is going faster. I mean, apparently to reduce risk.

But is that really the way to go?

Or do you think there should still be a post-trade settlement?

So maybe not leveraging the full capabilities of blockchain for instantaneous transactions.

 

Michael:

So, instant settlement has its ups and downs, of course.

I would say, if you talk about the counterparty risk, I think you’d almost want to move towards the shortest settlement cycle as possible.

And I think that’s also one of the reasons why you saw the move from T+2 to T+1.

But then if you look at it from a market maker’s perspective, who typically starts the day with the delta neutral position, ends the day with the delta neutral position.

If then throughout the day, the market maker is constantly buying and selling, and the market maker only needs to settle one time per day, then a post-trade settlement window of one day later is actually quite efficient for the market maker, because then almost no settlement needs to happen.

And if you were to have atomic settlement, it does mean that the capital constantly needs to be available for it to settle.

So there are definitely advantages to it and perhaps as liquidity would be more combined into a large pool like the benefits of netting may remain as you shorten the cycle. But yeah, basically in the short term, it will impact the capital efficiency of market participants like market makers quite a lot as you reduce the settlement cycle.

 

Ian:

I can imagine that Flow Traders is staying quite a bit on top of those developments and will be ready technically one way or the other, however it goes.

Let’s dive even deeper a little bit to something that I’m sure matters to market makers, but also the really big professional large trading firms that you mentioned.

One thing is price discovery and the other thing is spread. Just starting with price discovery: people looking on from the outside, from the TradFi background don’t get how price discovery happens. How do you see that process working in crypto markets, global crypto markets all over the world?

 

Michael:

Yeah, so price discovery for me happens mostly based upon where liquidity is and trades happen. So two important factors here. One is where are exchanges located and second, where are the people trading?

In crypto, currently the largest exchanges are located in Asia.

Naturally, this is definitely a big hub in terms of where price discovery happens.

But then to the second point, it does change throughout the day where people are trading.

So you do see shifts in liquidity from APAC to Europe to US. for instance, also when you look at the US ETF lines and the forms that are trading there, you do see shifts in where price discovery happens on a global level.

 

Ian:

And talking about spreads, there’s a little bit of a debate and we talked about this internally.

People say that as institutional money, big money comes into crypto, then spreads should tighten and order depth, order book depth will grow.

At the same time with more regulation and that regulation probably hitting hardest on institutions, costs may go up and there may be other factors that make it more difficult to be really active. How do you see spreads developing in crypto or at least in the major crypto assets, Bitcoin, Ether and so on over the next couple of years?

 

Michael:

Yeah, so I would expect spreads to continue to tighten in the next three to five years. like you said, institutional liquidity is an important factor and also regulation.

Naturally, when there’s more liquidity in the book, when there’s more volume that allows market makes to tighten bidder pricing also likely increases the profit pull.

It allows additional competition to enter.

So this generally will have a trend to tighter spreads and to deep end liquidity in the book. Now, when you look at regulation, it can be a little bit twofold. Definitely it will increase the costs for people to comply to regulation.

So that may impact the spreads in a negative way.

On the other hand, I do think it’s actually in the current state of crypto, it’s enabling institutions to enter the market.

So if done well, regulation can have a net positive impact on the spreads. And I say for regulations, it’s very important to consider these kinds of balancing acts – on how that impacts the market, how it impacts the accessibility.

Because the last thing you would want to see is that liquidity is moving away from a jurisdiction as a result of too stringent regulation.

We are both active on the more regulated part and the regulated part and we’ll always try to maintain the tight spreads and deep liquidity in the books as a market maker.

Of course. yeah, we see it as also as a role to tighten these spreads over the next two, three, five years, perhaps a little bit more similar to what you see currently in FX.

 

Ian:

And let’s move then to the regulatory topic, since you said you’re quite on top of that.

And we mentioned to MiCA before this is a really big thing for the European Union, which includes the Netherlands where you’re based, but is also putting it a little bit differently positioned to other locations around the world.

How much are you really focused on figuring out the rules and getting ready for MiCA at this point? Or is it more of a wait and see kind of approach?

 

Michael:

Yeah, MiCA is there to provide regulatory clarity within Europe around trading crypto assets, mostly to protect retail investors, but also to regulate the virtual asset providers where we’re trading.

Also for us, it has quite a big impact and it’s going live, the stablecoin regulation is going live end of June and for the future asset profile is going live end of the year.

Perhaps we like that there’s still some activities within MiCA whether market makers are in scope or not.

But we do need to be preparing for when these regulations kick in because it’s only six months away.

And also it will have impact on our trading activities if stablecoins are going to be delisted or not based upon whether they are authorized by MiCA.

 

Ian:

Right. And you mentioned stablecoins.

You at Flow Traders  have a stablecoin, a Euro stable coin project together with Galaxy and DWS. Can you give us a high level overview of what that is, where the idea for that came from and what Flow Traders  is doing in that construction?

 

Michael:

Yeah, so I believe stablecoins and Euro stablecoins will be very important for the market.

And especially for Europe, if you look at, for instance, trading volumes in the cryptocurrency market, over 90% of the fiat to crypto trades are done in dollars.

Well, on other things like where the developers are located or how much volume is during the European trading hours – it’s much more balanced compared to US and Europe.

So there is a big opportunity for Europe to have its own stablecoin in euros and also for it to grow its role in the market.

As a market maker, stablecoins are super important for us. It’s simply a better product almost compared to fiat if you look at the use cases where we need it.

So for instance, on our OTC trading, it allows us to instantly settle with our counterparties.

When you look at our own exchange trading, if we need to move funds from one or other exchange, if you need to do it through the fiat rails, it can take a couple of days over the weekend for it to arrive and stablecoins allow you to do it 24 -7.

And even it supports us in our ETF trading business, on the, for instance, the creation or redemption side.

So I believe that the importance of stablecoins is clear and the Euro stablecoin is a good opportunity for Europe to grow its presence in the market.

And as for the AllUnity stable coin that we are launching with Galaxy and DWS, obviously we’ll be providing liquidity for the stablecoin.

DWS will be responsible for the asset management and GALAXY will be leveraging its technology experience for the technology for the stablecoin.

 

Ian:

Do you have hopes or ambitions that this would be a stablecoin adopted by quite a few other market participants, or is this more something that’s just for you guys to do your business in the areas where you cooperate and work together?

 

Michael:

No, it will be a perfect stablecoin. So the goal is really for it to be adopted by all players. And also to see Euro stablecoins present on the DeFi side where we also active.

 

Ian:

So it has a DeFi focus or potential. That’s also something that you’re keeping in mind.

 

Michael:

Yeah, definitely. Also for DeFi, when you want to use stablecoins there, it’s either UST or USC. But for Europeans, there’s not really an alternative to that. So they always need to exchange first to dollars, to be able to experience all what’s currently happening on DeFi.

So definitely this is an important angle as well to increase the pressures there of Euro and Euro stablecoins.

 

Ian:

I’ll just throw in this small comment or also question. There was recently an article in the Wall Street Journal from a US congressman who was very much promoting adoption and, shall we say, legalization of stablecoins in the US.

And his point was that they would be a great buyer of US debt.

That’s a little bit of a different way to look at it as a way to prop up the US government. I suppose that’s not a motivation for this stablecoin from you.

 

Michael:

No, I must say I haven’t really thought about it, but that was not the consideration.

But I do think that also from a US perspective, despite maybe even the resistance they have on the regulatory side, they have  sort of a dominance in the crypto market in terms of dollars.

So I also believe that they will want to protect their share.

Yes, stablecoins are also, think, one of the first things they will be regulating given also the size of the market, but also the importance for the US to have a large share in the dollar versus crypto trading.

 

Ian:

Okay. Yeah, we’ll see how MiCA affects things and how MiCA, I mean, some people have said that it’s kind of like an “iron curtain” coming down over Europe where everything in Europe is going to have to be under “strict lock and key.”

On the other hand, some people think of regulation and I think we share that view that it’s an enabler as well. Do you see it more positively or a bit negatively?

 

Michael:

No, we definitely see it positive and definitely as an enabler for market participants and large institutions specifically to enter this market.

Also, if you look at our ETF business globally, where we are covering all the major global crypto ETF initiatives, there’s often a doubt whether the banks that we work with can support crypto.

And I believe that one of the reasons is that there’s no clarity from regulation around what and what they cannot do.

So the answers of such big framework, it should be positive that there are still bits and pieces that need to be figured out. So it’s important that clarity is given there in the short term, but I hope and I believe that this will positive for the European role in the crypto markets.

 

Ian:

Obviously we can’t conclude the conversation without going back to the subject of our last conversation in Davos during WEF just after the spot Bitcoin ETFs launched in the US.

Flow Traders  was very much and is very much involved there.

Can you just kind of give us a summary how things have gone over these six months or so? What is your feeling about where it has been and where it’s going?

 

Michael:

So the approval and the launch of the US Bitcoin ETF has been very positive for the market, of course.

Having names like BlackRock and also the large banks in the US support this product really “credentializes” this asset class.

I think from that perspective, that’s already added a lot of value. Then if you look at the volumes, the inflows, they have exceeded expectations.

So that has been a big success for the market and it is reflected in the price of Bitcoin currently.

So we’ve been welcoming this product for a long time and we think it’s a very good way to make Bitcoin or other asset classes even accessible in efficient and also cost effective way.

And yeah, we’ll continue to support this and we hope that the ETH ETF will soon be listed in the US.

 

Ian:

Yeah, I think we’re looking forward to that. And our friends at 21Shares were talking about that also recently there very much in that race as well.

You mentioned BlackRock and it was kind of funny to see BlackRock really take a pretty quick jump first into the ETF and now also going forward to a tokenized fund.

Seems like Larry Fink is really jumping into things pretty, pretty fast.

Just quickly from, from Flow Traders perspective, are you also thinking about the potential of market making on tokenized funds, tokenized assets in the future?

 

Michael:

Yeah, like I believe that tokenization is one of the major trends and most talked about topics currently in the market.

And I’d say the most successful example is actually the stablecoins – tokenized fiat. But now you see is also what’s been coming up the last year, our tokenized real world assets and in particular the US strategies. So similar to what BlackRock is offering right now

And it’s almost like a stablecoin, but it offers also the yield attached to it.

In a way it’s a superior product, there are also more regulatory constraints around it. It’s definitely on our mind and also on this end, we will want to support new initiatives coming through. I can imagine.

 

Ian:

Again, Flow Traders  right at the forefront of everything that’s coming along.

Before we finish, I’d like to ask you the question which I asked to all of the guests on RULEMATCH Spot On.

And that is if there is something either at Flow Traders  or somewhere else in the crypto market among institutions in this space that is happening and which we should keep an eye out for something that maybe not many people are talking about yet, but that will become more important in the near or midterm.

If not, that’s okay. Just give you the opportunity.

 

Micheal:

Well, I think it’s talked about a lot and it’s probably well known, the ETH ETF in the US.

It’s really something we are looking forward to and preparing for.

We see it as a big step also in shifting, in little bit the stance of US regulations towards cryptocurrencies.

So it’s not just another product that is listed, it’s a shift we see in the stance of the US politics.

 

Ian:

Okay. Yeah, that is quite a significant step. And I think many people in the space have been waiting for it for a long time and wholeheartedly applaud this small step and also giant leap forward. With that, I think we’ll wrap things up.

Michael Lie, thank you very much for being on RULEMATCH spot

Thank you to Flow Traders for being involved and we look forward to more good things to come. Maybe we’ll come back and have another conversation very soon.

 

Michael:

Thank you, it was a pleasure to be here and looking forward also for future discussions.

Thanks.

 

 

RULEMATCH Spot On – Exchange Power Play

One of the biggest developments in the institutional crypto and digital assets space has been the launch of exchange-traded products for investors. The recent launch of spot Bitcoin ETFs in the US was a milestone hailed around the world.

But how do operations work for exchange-traded products (ETPs) and exchange-traded funds (ETFs) – and what is the difference? What changes to crypto markets can be linked to the the growth of these products?

In this episode, RULEMATCH Spot On hosts Isabella Moessler, Global Head of Distribution at 21Shares, a leader in the crypto ETP/ETF space. Isabell has extensive experience in the financial industry from Goldman Sachs, iShares, ETF Securities and Euronext.

 

Episode show notes:

(00:58) – Intro and the view of a finance veteran

(3:03) – Explaining the difference between ETPs and ETFs

(6:24) – Managing operations for ETPs in a global crypto market

(9:05) – How a new ETP is born

(12:13) – The reason for Switzerland

(14:09) – All about spot Bitcoin ETFs in the US

(18:59) – Market integrity and US Bitcoin ETFs

(21:37) – The implications of a fragmented crypto market

(23:29) – The evolution beyond retail

(25:40) – “Centralization” of custody for ETPs and ETFs

(29:57) – Potential for lending markets

(31:56) – 2nd generation ETPs and ETFs (with tokenization)

(37:05) – Settlement, pre-funding and Delivery vs. Payment

(40:27) – The question of an Ether ETF

(45:41) – Education is (still) key

 

Listen and watch:

 

Follow on social media:

Isabell Moessler LinkedIn

RULEMATCH LinkedIn 

RULEMATCH X 

Ian Simpson LinkedIn

Ian Simpson X

 

Episode transcript:

 

Isabell:

Maybe one area where also the trading is more expensive than other asset classes is the pre-funding.

So, this is really something where, of course, if I send you the coins, but I haven’t received the shares yet, it could be sort of a counterparty risk, if you will.

But you know this then needs to be priced in. I think here we will see an evolution also towards Delivery versus Payment which is more the norm in for other asset classes.

Also, I think this is where you at RULEMATCH come into play and really facilitate this this next step and how can we make these markets more efficient.

 

BEGINNING OF FULL EPISODE

Ian:

Hello and welcome to another episode of RULEMATCH Spot On the only podcast dedicated exclusively to the institutional crypto and digital assets industry.

I’m your host Ian Simpson and if you want to know what banks securities firms, hedge funds, asset managers and others are doing in crypto and how they’re doing it, this is the place for you.

My guest today is Isabell Moessler. She is Global Head of Distribution at 21Shares, a pioneer in the ETP and ETF space Isabell started her career at Euronext and ETF Securities as well iShares and it all got started for her back at Goldman Sachs over 20 years ago.

Welcome to RULEMATCH Spot On, Isabell thank you so much.

 

Isabell:

A pleasure to be here. Thanks for having me.

Nice to have you. So let’s start – just following on your resume a little bit as a veteran of the space and also remembering probably a time when ETFs were also an innovation.

These kinds of products haven’t been around forever. Now things are moving forward and we’re focused on the crypto and digital assets space.

What excites you about how things have developed and how they’re developing right now?

The most exciting thing I think for me and why I also joined 21Shares three years ago is that you really have the advent of a new asset class to really you know be part of that journey very early on and definitely in the crypto ETP space.

You referenced all of my previous roles – sometimes there are many similarities because when I think back to 2005 working at iShares, we were the people in the corner. Nobody really knew what we were doing. What are these ETFs anyway?

I mean fast forward 20 years and here we are and it’s a 12 trillion market. So, you know, it really is little steps. It really is that innovation and especially the innovation that excites me in the crypto space.

 

Ian:

Let’s just set the stage a little bit. Since we mentioned 21Shares lists ETPs and you mentioned now these things that have come along and your background in ETFs.

Some people have a bit of confusion about these two things. Just define it for us – an exchange-traded product (ETP) an exchange traded fund (ETF). What is the difference; why exactly is there a difference. What’s the point there?

 

Isabell:

Yeah, we get this question all the time and it doesn’t get any easier um let me explain.

So the reason you have ETFs and these are funds in Europe probably the majority of products they are UCITS funds and adhering to that very specific set of guidelines set out under the UCITS regime, one of which includes a diversification requirement.

In order to be a fund, you need to have the 5/10/40 rule. You need to hit certain levels of diversification.

The problem is when you just have a single underlying and no diversification. This is why anything with a single underlying has to be classified as an ETP or ETC sometimes.

Just to add to the jumble of acronyms. Yeah so you have exchange-traded commodities and this is actually where it started out. So when you look back at the first spot gold ETP or ETC, this structure was introduced in order to facilitate having an exchange-traded instrument on a single underlying.

So this is really the main difference – the legal structure. So ETFs are fund, ETPs ETCs are debt securities.

You have a special purpose vehicle, bankruptcy remote and all of that. But from an investor’s point of view, it’s exactly the same experience.

You trade them the same, our market makers quote them the same. There are the same listing rules and the good thing is a lot of our investors, when we first started out with crypto ETPs, were already familiar and buying products in the commodity space and in the FX space.

So anything in there needs to be an ETP. The big confusion or even more confusion then happened because this is a structure for Europe.

In the US our products, the products we launched at the beginning of the year, the spot Bitcoin ETF is a fund. It can be called “F” ETF in the US…

 

Ian:

Even with one underlying…

 

Isabell:

Exactly, because it doesn’t need to adhere to the UCISTS rules and the regime.

But it just really created a lot of confusion which we need to explain. We always need to, of course, be transparent what our products are.

We don’t want to misrepresent our products and say it’s an “F” and then people assume it’s a UCITS fund. It’s UCITS eligible but it’s not a fund, right.

 

Ian:

Okay, so there is basically as you said no difference in the trading that you do of the underlying – exactly the same settlement.

So from an investor’s experience it’s the same thing. Of course, 21Shares is quite a global company – you have products in many different countries now also the US with the ETFs.

Looking at it from that geographic perspective and also thinking about crypto as a global market – what are some of the considerations that you have to take into account for your operations, for the trading for the underlying, of these different products around the world?

How do you manage that?

 

Isabell:

Yeah, so here we work very closely with the relevant regulators, with the exchanges as well, where we would like to list. It’s all about education in certain terms, but then also transparency – really demonstrating this is what it is, this is the investment case, this is the risk profile.

I think one of the benefits we have to bring to these conversations is also that we have a track record.

So we have five years of live data. We know exactly how our products have performed through various marco-cycles, big booms and busts and I think that also sets us apart from other issues that are entering this space. Because it’s first of all, it is all we do at 21Shares. And then also the company has grown in this space.

Some of the things, some of the infrastructure we had to build specifically for these products. And in our discussions, whether this is the same in Europe or in the Middle East where we listed on Nasdaq Dubai – or course in the US with the SEC, where it’s been many years in the making.

There’s been many applications by many of our competitors, ourselves. There’s been several rounds of iterations and engagement…

 

Ian:

With that geographic consideration – and then there’s the other element of a 24/7 market for crypto – is that a challenge for you, thinking again just about your trading operations to support the products?

 

Isabell:

Yeah, I mean the ETPs or the ETF adhere to normal market hours, they are on the regulated exchanges, of course, you have the underlying just going 247 – but this doesn’t pose any challenges.

Even when you look at the traditional space, sometimes you have discrepancies due to time zones or I don’t know, bank holidays is always a classic one where you have to make sure everything kind of lines up.

It’s actually almost a benefit having such a liquid 24/7 underlying market and then the products provide access via the regulated routes during normal market hours.

 

Ian:

You have, of course, Bitcoin, Ether and certain products but then also for some tokens that are a little bit more exotic, shall we say, but different, I’m sure you go through a whole evaluation of which ones to list and the liquidity behind those tokens and those different things.

What is that process?

 

Isabell:

Number one is always liquidity as you mention it because the nature of the ETPs really is daily creation/redemption.

So on a daily basis you need to have access to that liquidity. The first hurdle when we look at new underlyings – we get many ideas internally/externally… Clients come to us and really ask us can you launch an ETP on you know token X.

 

Ian:

Dogecoin and Shibu Inu.. No, just kidding.

 

Isabell:

Exactly they would be very liquid, but we haven’t got them.

 

Ian:

You said it’s often the projects or the protocols that are coming to you I can imagine that is most of the demand. Is there ever kind of the demand from more a financial institution that you want a product around this?

 

Isabell:

It was actually so the most recent launch was from the investor side. Yeah, but you you’re right many foundations many partners on that side also engage with us and want to launch their own token.

But again, in some cases – not many – but we really are adhering to that process and sometimes we need to give an answer where maybe the other party doesn’t really want to hear it. But it’s like either it is liquidity concerns or could be some mechanics or it could also be because working with the exchanges, they need to approve the underlying as well.

So Euronext or Xetra or SIX here of course in Switzerland – they need to become okay – “Yeah you’re allowed to list.”

So we need to play by the rules there…

 

Ian:

Excuse me, that’s a nice phrase “playing by the rules”. When it comes to the liquidity is it is it a volume I suppose a volume number that you’re looking at or is it a number of listings across different venues or what is kind of the metric behind the liquidity requirement for something?

 

Isabell:

We are looking at it from an access point of view. So can you get, say for example we get a big creation and our APs, our Authorized Participants need to deliver us the underlying. So that really is the case.

Where can they source the underlying token?

And that could be various different venues. This is the expertise they have on their side. But it really is sort of the first hurdle: can you get access and then also on the way out.

If we have redemptions, do the opposite of the trade.

 

Ian:

And not to go down the geographic/competition/jurisdiction “rabbit hole” too much, but obviously you launched in Switzerland – in 2018 is that correct? Was there a particular reason? That was I guess before your time, but maybe you know some of the company history, a particular reason for Switzerland? What was the rationale?

 

Isabell:

Yeah, so our co-founders Hany and Ophelia, they really traveled the globe to find the right jurisdiction to turn their idea into reality. Many different countries so many discussions with various different regulators on all continents.

Hany always makes the point – it’s like we’ve been on every continent bar Antarctica. So really the due diligence on both parts was immense and then Switzerland became our home because of very forward-looking regulation, very accommodating rules and frameworks, which is something all the institutional players and retail investors said: this is exactly the route we need.

So I really think Switzerland and the approach to crypto and digital assets is really a strong partner. It really has seen the opportunity and has put the foundations in place that many different organizations can build on.

There’s a reason why you have sort of Crypto Valley and you know and this is also – we come to this party as the ETF issuer but then you have custody, you have hedge funds, you have, you know, the whole spectrum.

But because Switzerland has these very transparent rules and is willing to listen and really facilitates the innovation. I think a lot of other jurisdictions look at Switzerland as the leader and then try to replicate – take the best bits.

But everybody has their own approach.

 

Ian:

So let’s go now to the big news and the topic of the ETFs in the States. We talked a little bit about this back in Davos in January when it was very fresh. Now we’re a few months out and things have gone very well I think across the board, also for 21Shares and ARK.

Again going down a little bit deeper level, we discussed before that these were a bit different products in that they were cash-settled. This was a requirement from the SEC based on their reservations about the spot market or perhaps different considerations.

Just walk us through again – what that means… How that’s different from the other products and maybe we’ll ask a few follow-ups.

 

Isabell:

Yeah, so the main difference and I mentioned briefly you what happens when we get a creation.

So in Europe cash-creation is possible as well, but the majority of creations will be in kind. So there our Authorized Participants send us the underlying.

In the US as per SEC requirements – slightly different setup is that the creations are in cash.

So the Authorized Participant will send us US dollars and then the trading of fiat versus Bitcoin happens with us. So, it adds an extra step if you will, but of course as I said before because we built the infrastructure just for this specific product area or for this specific underlying, it wasn’t a heavy lift on our side.

It’s something you know you could say well, ”pros and cons” of cash creation, in-kind creation. Probably if you have cash creation counterparties who currently wouldn’t be able to touch crypto because of their infrastructure and their setup, they will be able to engage and be active in this market.

So, it opens up different routes. If you are more on the “contra side” of the cash-versus-in-kind you would say well it’s less efficient and but I I think both works and both are very established concepts in other asset classes.

So like I say it wasn’t something new we encountered and I’m pretty sure all of our competitors were in the same boat, where, okay yeah, we’re familiar with both.

 

Ian:

And ready to roll with the punches of course. And so, do I understand then correctly from that with the “in-cash” you are doing the trading yourself versus the authorized participants puts a bit more of the trading burden shall we say on you and responsibility on you.

Does that lead to other considerations about risk management and things or not much of a difference?

 

Isabell:

I mean, there again, the way it’s set up is very efficient. Our primary concern really is the quality of the product that it does exactly what you promise your investors it does.

So as I said it was sort of an extra step we needed to introduce but we have this platform Onyx which is the infrastructure we use for our own products. They have not been used by other participants as well, so because we have that in place it wasn’t that much.

From a risk perspective, of course, we need to ensure this is all done also on a trading perspective in the most efficient way, but this is it – it hasn’t been a a big burden for the products on day one this is, of course.

I think I mentioned that when we spoke last, you can do all of your preparation, but really then, there’s that moment there’s a T-0 when you go live and then everything worked as it should. They trade in huge volumes – all of the spot Bitcoin ETPS at tight spreads. It’s been a phenomenal success. We are very proud. In sort of opposition versus some very big established other asset managers. But…

 

Ian:

I think they remain nameless..

 

Isabell:

Exactly.

 

Ian:

I was going to ask a follow-up, then just on the SEC and the cash-settled side. I’m sure you know, of course, and you were having all kinds of conversations with them. Then they said, “Okay, it has to be cash-settled”…was it some kind of feeling about market integrity in the spot market?

Were you making arguments to them? I know some people were making arguments to the SEC about the integrity of the spot Bitcoin market. How did those conversations go or can you say something about that?

 

Isabell:

Yeah, I think the SEC’s biggest concern was the unregulated nature of the spot Bitcoin market and, you know, not being able or not being regulated by the SEC or even the CFTC.

But here the good thing was that there many issuers – we spoke with one voice pointing to the commodity ETPs that are in existence. So you have ETPS on spot commodities.

And the spot commodity market is not regulated by either of those regulators either, so you know it was really a case of pointing out this sort of chain of arguments wouldn’t then apply to a huge part of the market.

And I think also of the fact that CME futures on bitcoin have been trading and established and had ETFs launched on these products. The correlation between the futures and the spot market is so strong where I think then – and I can’t speak on behalf of the regulator – but that probably gave some comfort of “Okay, there is an aspect, but we have no concerns on the spot Bitcoin market, on the underlying market.

It’s huge, liquid – you have I don’t know on a daily basis but huge numbers trading – 20 billion in liquidity with various different market participants.

And then we got the green light for these products which was really significant and the assets that have flown into these products – I think is also a strong sign of the pent-up demand that was there. So, from day one you really had inflows.

I think with a few weeks off in April where media says already “Oh is this the end of spot Bitcoin?”

It’s like no, this is how these products work with the exchange traders, inflows/outflows etc.

 

Ian:

Just double clicking a little bit on the market and market structure and and how they work – kind of “the back end” or “the under the hood” side of things when you’re trading the underlying. The market as we know in crypto has developed in various ways.

It’s fragmented and some people make the comparison to the FX market in some ways. Different venues, different OTC desks or exchanges and, you know, different models: RFQ and and all kinds of different things.

How do you navigate this to support these products for Bitcoin or other assets?

 

Isabell:

This is where the expertise comes in on our trading side, if we do the trades in-house. But also working closely with our partners in the market, with our Authorized Participants who have expertise. And I would say the ETF or the ETP part of the crypto – of their crypto engagement is only part of the overall trading volume they are active in.

You really see that evolution. Maybe coming back to my very first point. You know this is what I’m excited about because there’s so much innovation. It’s not an established market where it’s like: “Well, this is how it is and end of story.”

You know that there are different, like you said, different venues different ways of trading popping up.

I think also here we get a healthy combination of what is good practice in traditional finance and what can be the innovation, because sometimes not every idea is great, and we always need to sort of do the reality check there.

 

Ian:

And thinking about how you support that with trading and markets are there some advantages or disadvantages as the market has grown?

Because we know it started very retail and maybe in 2018 it was, of course, market makers there and liquidity was good, but it is changing over time.

Do you see any changes or developments in that side of things?

 

Isabell:

It’s interesting because I think from my experience for the first time it was really sort of bottom up, retail first.

In many other asset classes or especially in the ETF world, you will see a different path where I don’t know, in thematic ETFs or fixed income it sort of starts with big institutions and then filters down to retail.

Here it was completely the opposite way. We do see changes and I think a lot more institutional players would like to get involved and would like to add these products to their portfolios. And clearer regulation will help.

So here this is really the path because these are big organizations really in the spotlight need to be adhering, of course, to all the rules.

But that’s difficult when the rules are still a work in progress or not really spelled out.

I think in in Europe, MiCA will be a big step in the right direction.

There’s more to come, of course. It’s that work in progress but really something tangible and a tangible result.

And again, coming back to what I mentioned about Switzerland. Here in Switzerland, you see even small pension funds getting or making investments in crypto because they feel comfortable. They understand the risk.

They understand how it fits into their portfolio and they see the benefit of even small allocations in that space. But yeah, it’s gone from retail to institutions.

 

Ian:

And as an institution, I mean you’re becoming an institution actually with all of these all of these different products and with a clear position in the market.

But you know things are developing more and more. Now you said you maybe didn’t want to say too much about custody, but I would ask the question – since holding these assets for these products is a pretty important thing.

There were a few voices that said even about the ETFs in the States that Coinbase being one of the main custodians or a predominant custodian was a risk – or perhaps a problem.

How do you think about the risk of those things? I mean you said custodians in the plural, right so you work with various…?

 

Isabell:

Yes, we work with a number of custodians and here it’s a fine balance, because you don’t want to have too many – that would be a huge operational burden.

You also lose some of the economies of scale. But at the same time you also don’t want to put all your eggs in one basket. It’s again here the process we use to ensure that the product development cycle.

Very much part of that is the vetting of our partners we work with and due diligence on both sides. But also, who are you dealing with?

Here we really have found some great partners have found also partners that are willing to innovate with us in terms of new underlyings, in terms of facilitating the staking aspect and playing by the regulatory rules, who have been really present in the markets where we we need their support.

So a lot has happened here as well and I think that that will continue to grow. But it’s super important really if you think back to the end of 2022 and FTX and all of these events in the market.

What our clients wanted to know was really, “Who do you work with? Is my money safe? Where is it in custody? How does that work? How do you ensure nobody runs off with private keys?”

Everything like that and we really made sure clients do know and it gives them comfort that we’re working with the right partners. The processes are robust and in place even during those times where it was a real stress test.

But we can say and proudly say our products were trading. Nothing was halted. The spreads were given the market events still in a range where it was it was reasonable everything worked and that was not because we got lucky but because it’s by design.

This is really where we thought through, and we really put our heads together speaking with people we work with – just to make sure it’s solid.

 

Ian:

I think it goes without saying then that 21Shares doesn’t custody any assets on exchange, so to say.

 

Isabell:

No, we don’t no and we work with Coinbase – Coinbase Trust which is removed. Same name..

 

Ian:

You mentioned the space evolving and the custody space particularly. Do you imagine any big traditional financial players moving into the custody space – the crypto custody space?

 

Isabell:

Yes, the sort of hurdle of “What is this? Why should we look at it?” – that’s way behind us now.

Many organizations are looking at it and need to also add it to their service offerings. Again because of client demand on a custody side but also on, think of a big organization offering the wealth, the investment banking, the custody space it all needs to work together.

The demand is there so therefore you need to put all the piping in place to facilitate that.

 

Ian:

And on the back of these ETFs, we talked about this also just a little bit in in Davos but also with the other products. I mean it opens up many other possibilities for lending and for more sophisticated strategies.

How do you see this, and will there be some kind of new lending markets developing?

Because, as people have pointed out, holding this crypto, the underlying that just sits there is a little bit counterintuitive to how financial markets usually think. Everybody wants yield. They want to make money even as assets sit there. What do you see or what could you anticipate?

 

Isabell:

Here you have to distinguish what are we talking about on the lending front. So either the ETF or the underlying.

 

Ian:

I’m interested in both.

 

Isabell:

On the underlying none of our products allow the lending of the underlying. That is for several reasons to ensure the integrity of the product to really ensure when we claim “physically backed/fully collateralized” that needs to be true. If you look at the lending of the of the ETPs of the parts of the product – that will evolve.

It’s a huge market in other asset classes and when you have the critical mass of products out there, it’s interesting. People will get into it.

It’s also, of course, in our interest because it adds to the liquidity – it adds to the utility of these products and different strategies you can put in place using those products.

So here it’s in its nascency, but I think there will be quite a lot of development on that front.

 

Ian:

We talk about kind of the first spot ETFs in the US, the first ETPs back then here in Switzerland from you. Now a “second-generation ETP” something that’s more sophisticated maybe more like a tokenized structured product or something like this. Is this something that’s that is being explored?

On the back of other kinds of crypto assets, what do you anticipate?

 

Isabell:

There are solutions and there are these discussions with our clients, because we really don’t want to launch products for just a product’s sake.

Like do you need it and what challenge is this product solving? So yeah, I think there will be products like I said similar to the traditional asset classes, with some capital protection. There are many ideas that could be packaged into the ETP wrapper in the crypto space.

I like it how you call them “second-generation” – that’s great. Where we move away from the sort of plain vanilla to “Okay it’s more ‘results driven’ if you want to call it that.

So I think definitely this is something that will that will happen.

The token part is I think is separate and it’s an interesting development. You see it goes both ways. The ETPs facilitate investment in crypto via the regulated exchanges.

Tokens and of course big buzz word “the real world assets” in token form go the other way really.

You take money market funds and put them into the token wrapper in order to offer them via a different route and it’s exciting to see that because it’s sort of like this is where the the two worlds converge. And both have absolute validity.

It comes down to “What are you trying to do?” How would you like to access these investments?” A money market fund you can buy via the very traditional routes directly with a fund manager. You can go via ETFs. Why not buy it via a token if this is my preferred route?

If I’m very familiar with the crypto space and I do all my trading like that I might not want to go back to stage one. It’s like, “No I want the exposure, but I want it in this form.”

And this is where we have to be really mindful ETPs/ETFs/tokens they’re wrappers. They’re really just the vehicles. What you put in that vehicle is where the innovation happens.

 

Ian:

…can be interesting. Perhaps also as finance moves forward, where your financial world is on your phone not in the office on Bahnhofstrasse or in the City of London somewhere and you are more used to using something like a Revolut or a Bitpanda or something like this – but you want sophisticated things that then should operate “at the speed of light” and so on and so forth…

 

Isabell:

Yes, I think it’s really a great development. We will see more of it because as I said, it’s an access route.

And also, who’s your target audience? Who do you speak to? Do you speak to somebody more traditional, and they have their portfolio in place and they’re quite comfortable going to their bank branch or their financial advisor and sit down and go through this?

Or is it somebody who’s just like “I need this now. I don’t want to speak to a person. I want two clicks.” It’s going to be a generational shift.

Where does the demand come from? At 21Shares, this is our our brand for the for the ETF/ETP space. But then also via 21.co, we do have a token business. We’ve launched tokens with partners. We get a lot of questions and a lot of engagement there, where people say, “Okay can you help us with our token strategy?”

One of the first questions we ask is like “Why would you like to tokenize it? What are you trying to achieve? Do you want to access new investors or a different investor group? Do you want to broaden your distribution? Do you want to optimize internal processes which could be available via this route?

But and this is interesting because there are use cases for all of those.

But I think when you look into the token space, you need to be clear like, what are we trying to achieve? Because if you do it because everyone’s doing it, maybe not the best strategy.

 

Ian:

Exactly. We won’t touch on it too deeply, but there is the topic of settlement and you alluded to it earlier.

Of course, the ETF is settling on one schedule and crypto being what it is with settlement – in different ways and at different stages in crypto markets depending on what counterparties you’re working with.

Is this a challenge? I understand the US they’re moving to T+1 settlement, so is that an adjustment for operations?

 

Isabell:

No, because it’s 24/7 and we already settle T+1 so that’s fine. Maybe one area where also the trading is more expensive than other asset classes is the pre-funding.

So you really have a case of – and this is on the crypto, the underlying – it is “free of payment.” The Authorized Participant would send us the coins before we issue the shares.

This is really something where, of course, then if I send you the coins, but I haven’t received the shares yet, it could be sort of a counterparty risk, if you will. But you know this then needs to be priced in. I think here we will see an evolution towards Delivery vs. Payment which is more the norm in other asset classes.

Also I think this is where you at RULEMATCH come into play and really facilitate this next step. How can we make these markets more efficient, creating networks creating or networks of participants, which will then help to move away from this “free of payment system.”

But there is work to be done. I’m not saying it’s the most efficient yet. sometimes also on the settlement side it can still be quite manual because you want to ensure it all works in the right channels. So sending a test transaction then this gets all approved and then the actual coins get send the shares get issued.

It’s something we’re working on to optimize our infrastructure, but this is still being worked on. It’s still early days. I can imagine as more and more financial institutions come into the space this this regularity or this certainty and different things will become more and more important.

That will help to drive things, which is a good thing and again helps the the investors’s confidence. And I’m not saying we should replicate everything that happens in equities, but some things are there for a reason – clearing houses and things like that, which of course goes completely against the idea…

 

Ian:

The crypto ethos..

 

Isabell:

Exactly, the ethos of decentralization. But I think we can come up with a solution there which would adhere to the decentralized nature but still gives comfort around it.

I think there’s a some very clever brains working on these kinds of ideas.

 

Ian:

Going back to this second-generation ETF or ETP topic – there is a particular generation in conversations right: an Ether ETF in the US now this has certain regulatory considerations.

But also then this next generation of tech- staking of Ether. I think that is perhaps a challenge for you or for these products.

How do you look at that?

 

Isabell:

So we we have an two Ether ETFs actually available for the European investors or non-US investors. Here we have both options, so we have one Ether ETP with staking and one without.

The reason why we have both options is that some of our investors right now are not comfortable with it. They can’t assess it. Their compliance and risk departments say “No no.”

But again maybe this is just a case more of education really understanding what is it, what does it do, what’s the extra layer of risk if you will you would be exposed to. This is the biggest staking ETP on with Ether underlying in the European market and this is for investors who really say “No I want the whole package Ethereum, proof-of-stake network. This is the additional benefit, of course, and I would like to benefit from this.”

So here it comes more also on the part of the custodian: can they facilitate it? We do then reinvest the staking award into the product, so it’s not distributed out.

 

Ian:

Accumulation.

 

Isabell:

Exactly. So on a daily basis it gets added to the NAV, the Net Asset Value of the fund. So it stays within the fund, but of course it reflects in the performance of the product.

So this is as an investor this is how I benefit from it. We also show on our website what are the staking rewards, but also what is the utilization rate.

What that means is, okay it’s our AETH. This is the product so the Ethereum product is fully collateralized and then we stake the assets which doesn’t mean that they move anywhere, but you get the additional yield from staking.

And we need to ensure – coming back to the daily creation/redemption that there is enough liquidity, because when you stake you lock up your underlying for a certain period of time.

So for example, we don’t stake 100% of the ETH in the product. We do calculate what is sort of a prudent margin. What can we stake in order to benefit the investors from the staking rewards but at the same time also what still gives us the flexibility within the product?

Also this is important for investors to understand. First of all, what is it? how do I benefit? How is it done? And reflected in the product, but then also in case I do want to redeem, is there enough liquidity?

We’ve really spent a lot of time trying to determine that utilization rate, just to avoid any issues on that front.

 

Ian:

How long has that product been live?

 

Isabell:

Ethereum was one of the early ones, so actually number one product. Our product was a basket of cryptocurrencies where Ethereum was included. The ticket is HODL. The second one was spot Bitcoin and then spot Ethereum.

It’s been available to trade for many years, back to 2019. Again long track record. Then of course when ETH moved to proof-of-stake in the meantime.

 

Ian:

That was I’m sure a process to figure out how to make that operate and figure that out…

 

Isabell:

Yeah, and if you think about it – also again engaging with the regulators

Explaining, what is it? and what does that mean and how we’re going to deal with it going forward, explaining it to clients.

We spend a lot of time on that, but I think again this is where our “crypto nativeness” really helps us, because we know what this is. Sometimes we get the push back from or at the time push back from the regulator: “But does that this is a fork? But shouldn’t you stick with the original chain?

All of those discussions, we are really happy to have and also explain You can show the pros and cons but this is one was interesting.

It really was also for the ETPs some other issuers took some different approaches.

 

Ian:

Very interesting. Looking into the crystal ball just a little bit and looking forward, I’m sure you are working on many things, most of which you can’t or won’t tell me about, but for our viewers and listeners on the podcast, do you think there is something generally not just with 21Shares but generally in the space happening that probably nobody is talking about, but that we should be paying attention to or that we should be looking out for?

 

Isabell:

Well that’s a huge claim: “that nobody’s talking about it.”

I’m sure people are talking about it and that’s a good thing. It’s really the differentiation when we say crypto or digital assets. What do we actually mean?

I really think here we need to be very clear. We need to create this understanding and also look at different components within the crypto landscape differently.

Are we talking layer-1 blockchains? Are we talking scaling solutions? Are we talking oracles? Are we talking, I don’t, know decentralized exchanges?

Because at the moment, everything is sort of clumped in and we would never do that in equities. We would never say “Equities.”

No – what is it? Automotive or transportation, financial services? Different nuances, different drivers – completely different animals.

If you look at Lido lending protocol or you know Chainlink – it’s different things. So I think the understanding of what it is and moving away from “This is just crypto” because also it’ll become a lot more relevant in people’s daily lives.

So with our ETPs we only look at it from an investment point of view and participating in the innovation – being able to benefit from the returns in that space. But each of those different areas will affect us – digital identity is always a good example.

So I think more knowledge in that space will then also translate into more demand for different solutions and making them investable.

My favorite or if I had sort of the wish list of where is this going is almost like you have in equities like sector ETPs on different sectors of the crypto ecosystem. So a taxonomy or or kind of an asset manager.

Well, we do have that with the Global Crypto Classification where we really split it up. But then more of an adoption, more of an understanding and then also accordingly we can tailor new products.

Of course, we’re completely mindful that if you’re a big institutional investor, crypto will always remain a smaller percentage of your overall portfolio. So how much time do you need or do you have the luxury to educate yourself in all of these different areas?

Probably not. We’re here to help. But you know we all have just a limited sort of mind space for all of these things.

But like I say because it will come out of the just pure investment space or trading space into usage in our daily lives so I think that evolution will happen.

I have always also said that technology needs to merge into the background. I’m not a programmer – understand the technology a little bit, but we can’t get too hung up about it. And let’s be honest some of the user experience – I’m sure you had the same where you think like this is terrible.

There will be no mainstream adoption of this particular function if I have to click 15 times then wait then, “Oh my God did I use the right address? I still don’t have any confirmation.”

There’s a lot that will change and time will tell.

But we’re only very much at the beginning of the road.

 

Ian:

I would agree. Isabell, thank you very much for joining RULEMATCH Spot On. It’s been very interesting to speak to you today. I’m sure 21Shares will be doing many more interesting things, so perhaps in the future we’ll welcome you back as a guest or someone else from the team as there are new developments and new things to talk about.

Again thank you very much.

 

Isabell:

Thank you very much for your time.

Launching RULEMATCH Spot On

Welcome to RULEMATCH Spot On – a podcast by RULEMATCH, the interbank trading and settlement venue for cryptocurrencies and digital assets.

Hosted by Ian Simpson, RULEMATCH Spot On is the only podcast focused exclusively on the institutional crypto and digital asset industry.

Podcast episodes offer wide-ranging, global perspectives and in-depth insights on what banks, hedge funds, asset managers and other financial institutions are doing with crypto and digital assets – and how they are doing it.

With in-depth conversations with people “in the know” on topics ranging from exchange-traded products to banking capital requirements to counterparty risk, prime brokerage and crypto lending, RULEMATCH Spot On is tailored to help subscribers stay on top of the latest developments in the institutional crypto space – and take advantage.

Watch, listen and subscribe below:

RULEMATCH Strengthens Board of Directors

  • RULEMATCH adds four new members of the board with deep experience in trading, risk management, cryptography, blockchain and finance.
  • Chairman of the Board Dr. Martin Hess is joined by Harald Schnabel, Dr. Jörg Behrens, Dr. Christian Cachin and Frithjof Weinert.
  • The new board members help augment the governance of the firm and support its strategic growth.

Zurich, Switzerland; 29 February 2024 – RULEMATCH, the interbank trading and settlement venue for cryptocurrencies and digital assets, today announces the expansion of its board of directors with the election of four new members. Harald Schnabel, Dr. Jörg Behrens, Dr. Christian Cachin serve as independent directors, while Frithjof Weinert will represent the interests of RULEMATCH investors. The new board members join Dr. Martin Hess, who was elected chairman of the board in June 2023. The four new board members, with their diverse experience in trading, risk management, cryptography, blockchain and finance, augment the governance of the firm and support RULEMATCH’s strategic growth plans.

Left to right: Harald Schnabel, Dr. Jörg Behrens, Dr. Christian Cachin, Frithjof Weinert

With his background as CEO of BX Swiss AG (Bern Exchange) as well as CEO of Euwax AG, Harald Schnabel brings extensive expertise in trading and exchange operations, where he has over 30 years of experience.

As a former partner at EY and founder of a risk consultancy, Dr. Jörg Behrens has over 30 years of experience in financial risk. His roles in the banking industry include assignments within board risk committees, e.g. at Cembra Money Bank AG (current) or formerly Leonteq AG, and interactions with various financial regulators.

Dr. Christian Cachin is professor of computer science as well as a widely recognized and published researcher from the University of Bern where he has headed the Cryptology and Data Security Research Group since 2019. During his career, he has worked for IBM Research – Zurich for more than 20 years.

Frithjof Weinert – in his role as CFO of Consensys Mesh, an early investor in RULEMATCH – joins the board as a director to represent external investors. He has 18 years of experience in commercial management, audit, internal audit, accounting & reporting, corporate finance, tax, treasury and finance shared services.

Chairman of the Board Dr. Martin Hess commented: “Governance is always an important subject for financial institutions and the companies that serve them. It is even more important that this governance reflect a wide array of knowledge and experience as we have with our new board members at RULEMATCH.”

Dr. Martin Hess, a partner at Künz Hess MacNab, has extensive legal experience in banking and finance as former legal counsel at the Swiss National Bank and twice expert for the International Monetary Fund, as well as expert advisor in the preparation of several Swiss laws, including as the Swiss DLT Law.

He also added: “With our expanded board of directors, RULEMATCH is well-positioned to serve banks and securities firms with stability and integrity and help power the next evolution of the digital asset market.”

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The information about RULEMATCH is for general informational purposes only and should not be considered exhaustive. They do not imply any elements of a contractual relationship nor any offering. The information contained herein is directed at banks and securities firms. Any person without professional experience in matters relating to investments should not rely on this information.

 

RULEMATCH contact:
Ian Simpson
Director of Marketing & Communications

 

About RULEMATCH

RULEMATCH is the premiere digital asset trading venue for financial institutions. It operates as a market operator for spot trading of BTC and ETH versus USD. RULEMATCH is never a counterparty in trading. Fiat funds are held in fiduciary accounts with a state-guaranteed, AA-rated Swiss bank and cryptocurrencies are handled on fully segregated wallets. With integrated multilateral clearing and post-trade settlement, as well as institutional-grade trading technology, RULEMATCH helps provide ultra-low latency, capital efficient trading and robust market integrity. Its offices and operations are located in Zurich – the heart of Europe. Its participant network is open to banks and securities firms only and limited to select countries. RULEMATCH is not available to US-based financial institutions.

RULEMATCH on Metaco Talks

On Tuesday, 6 February 2024, RULEMATCH CEO David Riegelnig was a guest on the Metaco Talks podcast. The session was hosted by Metaco Chief Growth Officer Seamus Donoghue.

Their discussion focused on the recent launch of RULEMATCH and the developing theme of institutional interest in crypto and digital assets – including some of the often overlooked factors that are important to banks, securities firms and their institutional clients such as hedge funds and high-frequency traders.

RULEMATCH and Metaco are partners and the Metaco Harmonize system fully integrated into the RULEMATCH venue for the secure handling of crypto assets on fully-segregated wallets for both trading and post-trading activities.

During the interview, several key topics were covered:

[1:08] David Riegelnig’s background and experience with Bitcoin and Ethereum

[3:40] Experience of barriers to crypto adoption by banks

[4:49] The key focus areas of RULEMATCH

[6:27] The importance of “playing by the rules]

[8:16] Trust models and market integrity in crypto

[11:04] Counterparty risk and serving high-frequency traders

[14:30] RULEMATCH’s rulebook and approach to fairness

[16:56] Focus on ultra-low latency trading

[20:16] RULEMATCH’s geographical focus

[21:48] Post-trade settlement, netting and clearing

[23:40] Trade-offs between efficiency of centralized trading and decentralization

[25:21] Post-trade settlement and cross-custodial integration

[28:09] Perspectives on stablecoins and overblown “de-dollarization”

[32:26] Massive opportunity for tokenization

For more information about the RULEMATCH trading venue, visit the venue overview page here. For details about trading operations, collateral and margining and post-trade clearing and settlement visit the trading documentation page here.

Watch the full session here:

Interbank Crypto Trading Venue Has Launched

  • The RULEMATCH spot trading venue has begun trading BTC and ETH versus USD.
  • Only banks and securities firms may become RULEMATCH participants.
  • RULEMATCH is never a counterparty in trading on the venue.
  • Integrated post-trade settlement significantly lowers costs for institutions, removing the need to pre-fund trades.
  • RULEMATCH provides the market integrity, capital efficiency and ultra-low latency that financial institutions have been missing.
  • The venue uses Nasdaq technology for pre-trade risk checks, trade matching and market surveillance.

 

Zurich, Switzerland; 14 December 2023 – RULEMATCH has launched BTC and ETH spot trading against USD for its participants. It serves financial institutions, who have already been active in trading cryptocurrencies, allowing them to profit from execution and settlement capabilities not available in the otherwise retail-dominated market today. Only banks and securities firms from select countries may become RULEMATCH participants. Their benefits on RULEMATCH include trading on a central limit order book with execution times as low as 30 microseconds, as well as integrated post-trade settlement with multilateral clearing. This allows for trading with up to 75% less upfront liquidity required when compared to existing trading venues.

RULEMATCH currently counts seven banks and securities firms, including BBVA in Switzerland, a Swiss cantonal bank and DLT Finance as its initial participants.  More financial institutions are in the process of joining the venue.

 

 

RULEMATCH CEO David Riegelnig commented: “Despite often going unnoticed, a growing number of banks and financial institutions have actually been quite active in the crypto market. But, as we all know, they have faced challenges due to the many fundamental deficiencies in existing market infrastructure – capital efficiency, counterparty risk, compliance and latency. On RULEMATCH, these banks and their institutional clients are now expanding their activities and deploying many of the same strategies that they have used in traditional markets. This bodes well for liquidity and development in the market – and also for the next wave of evolution in digital assets.”

RULEMATCH participants trade in an anonymous central-limit-order book with liquidity guaranteed by designated market makers including Flow Traders, who has entered into a strategic partnership with RULEMATCH to provide institutional-grade liquidity. Bankhaus Scheich Wertpapierspezialist with its tech arm tradias also serves as a designated market maker on RULEMATCH.

Michael Lie, Flow Traders Global Head of Digital Assets, commented“As a strategic market participant, Flow Traders works together with platforms that enable the institutionalization of the digital asset market. Working with RULEMATCH aligns with this objective and by being there as day one market maker, we can provide the institutional grade liquidity desired by financial institutions to support the adoption of digital asset and contribute to improving the broader financial ecosystem. We are delighted to be working with RULEMATCH and expanding our partnership in the future.”

RULEMATCH leverages Nasdaq’s pre-trade risk, trading, and market surveillance technology to provide an additional layer of transparency and resilience for institutional participants, enabling them to trade on RULEMATCH at speeds unrivalled in the crypto market today. The matching engine is hosted in two data centers in the Zurich metro area where RULEMATCH participants and their clients may cross connect and collocate.

“We wish RULEMATCH every success as they look to grow their business and help drive greater institutional participation in the crypto market,” said Magnus Haglind, Senior Vice President and Head of Products, Marketplace Technology at Nasdaq. “Nasdaq’s modular and scalable platform helps venues of all sizes get to market efficiently and attract liquidity through efficient and transparent trading. As traditional and digital asset markets increasingly converge, our institutional grade technology is well positioned to support the ongoing development of the digital asset ecosystem.”

RULEMATCH acts exclusively as a market operator that brings together the buying/selling interests of counterparties to execute and settle transactions. It is never a counterparty to a trade and does not offer brokerage or market making services. RULEMATCH does not provide custody except for the settlement process, including collateral management.

RULEMATCH facilitates multilateral net settlement among participants, allowing them to trade in a highly capital-efficient manner. At the same time, counterparty risk among participants is addressed with a strict delivery-vs-payment process and collateral requirements to protect against counterparty default. This allows RULEMATCH participants to trade with up to 75% less up-front liquidity needed, compared to the practice of pre-financing and credit lines currently prevalent in the crypto market.

The combination of integrated, post-trade settlement and ultra-low latency open up new possibilities for institutional clients of RULEMATCH participants, such as hedge funds and high-frequency traders.

RULEMATCH has partnered with Luzerner Kantonalbank AG (LUKB), a AA-rated, state-guaranteed Swiss bank, to handle qualified participant fiat funds used as collateral and for settlement in fiduciary accounts.

All cryptocurrencies on RULEMATCH are handled in segregated blockchain wallets using the Metaco Harmonize system, the institutional standard in custody technology in combination with IBM Cloud Hyper Protect Crypto Services, the industry’s only encryption service based on a hardware security module certified to FIPS 140-2 Level 4. With encryption and confidential computing capabilities from IBM Cloud, RULEMATCH can ensure the security of participants’ assets at the highest level.

Participants and flow of participant funds are subject to stringent controls against money laundering, sanction evasion and terrorist financing. RULEMATCH utilizes Elliptic’s Holistic Lens and Navigator capabilities to screen each and every wallet and transaction as part of its trading and settlement operations for regulated financial institutions. It is also able to screen wallets and transactions for risk in real-time and at scale.

Reference prices on RULEMATCH draw on data from market-leading provider Kaiko to support the integrity of price discovery and market surveillance.

Participants can connect to RULEMATCH via a range of options including cross-connection at Equinix ZH4, AWS Direct Connect and collocation in Green Data Centers in the Zurich metro area. A number of multi-asset OEMS technology providers are connecting to RULEMATCH; Wyden and Axon Trade have already done so.

RULEMATCH is supported by a select group of Swiss and international investors including Consensys Mesh, a company of Ethereum co-founder Joseph Lubin, Flow Traders and FiveT Fintech, formerly known as Avaloq Ventures.

RULEMATCH’s headquarters and systems are located in Zurich, Switzerland, positioning it centrally in Europe. The country’s clear regulatory framework and legal certainty for digital assets provide an advantageous environment for RULEMATCH’s operations.

 

The information about RULEMATCH is for general informational purposes only and should not be considered exhaustive. They do not imply any elements of a contractual relationship nor any offering. The information contained herein is directed at banks and securities firms. Any person without professional experience in matters relating to investments should not rely on this information.

 

RULEMATCH contact:
Ian Simpson
Director of Marketing & Communications

 

About RULEMATCH

RULEMATCH is the premiere digital asset trading venue for financial institutions. It operates as a market operator for spot trading of BTC and ETH versus USD. RULEMATCH is never a counterparty in trading. Fiat funds are held in fiduciary accounts with a state-guaranteed, AA-rated Swiss bank and cryptocurrencies are handled on fully segregated wallets. With integrated multilateral clearing and post-trade settlement, as well as institutional-grade trading technology, RULEMATCH helps provide ultra-low latency, capital efficient trading and robust market integrity. Its offices and operations are located in Zurich – the heart of Europe. Its participant network is open to banks and securities firms only and limited to select countries. RULEMATCH is not available to US-based financial institutions.