In Coin Metrics State of the Network Issue 226, we provide an examination of the current Bitcoin mining landscape through the lens of Coin Metrics’ data
How George Washington’s failed Canal Ambitions led to the Constitutional Convention
I am republishing this newsletter entry, first published two years ago in my short-lived newsletter, Murmurations. Murmurations was published on Twitter’s newsletter platform, Revue, which has since been deprecated. Because I like this piece, I am posting it here for posterity. Keep in mind this was intended for a smaller, more intimate audience.
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I grew up in the swamp. Well, more precisely, I spent most of my formative years in the suburbs of Washington, D.C. The question of where I’m “from” is a bit more complicated. I touched on it a bit in my blog On Writing (Ok, I have to come clean — to my embarrassment, I learned later that Stephen King had written an entire book with the same title and some of the same lessons, but of course from the position of a much accomplished writer. I later listened to this on audiobook with my dad on a 1,500 mile drive from Boston to Miami and thoroughly enjoyed it. I can’t recommend it enough.)
Did any of you get the joke in On Writing (the above blog post post referenced, not the book)? I’m not sure anyone did. In the post, I’m scolding myself, as well as my readers, for derailing the process of communicating information from your brain to another — telepathy, as Steven King describes it — with overly flowery language. My point was that vanity impairs clarity. But the post itself is full of unnecessary rhetorical flourishes. So it’s a classic case of myself not being able to take my own advice.
“Vanity of vanities,” says the Preacher; “Vanity of vanities, all is vanity.”
George Orwell is actually guilty of the same in his famous essay Politics and the English Language. He makes many of the errors of writing he insists a good writer should not commit. But we still love his essay. So I’m developing a new thesis: perhaps the flourishes are why readers stick around. No one wants to read robotic, syntactically optimal prose. Fair warning: due to a lack of an editor on this new project, I plan to fully indulge in digressions, flourishes, parentheticals, footnotes, asides, and needless rhetoric. Consider this my natural undiluted self.
Back to the swamp. Well — one point of clarification. Washington D.C. was never actually a swamp. George Washington picked it quite deliberately for the nation’s capital as he knew the area well given its proximity to his estate at Mt. Vernon. While D.C. is built around the Potomac, and as any resident knows, the soil in the region is virtually all clay, inherited from the river’s journey over the centuries, the city itself isn’t particularly swamplike. The swampiest era in the history of the nation’s capital came after the Civil War, when poor farming practices caused mudflats to emerge on the outskirts of the city. These were later transformed into the reflecting pool, the Tidal Basin (the place with the cherry blossoms), and much of the national mall where you can find the Lincoln and the Jefferson Memorials (my favorite). If you’ve ever visited, you will know that it can get extremely hot and humid, especially in the late summer months. But it’s no swamp.
By the way, there’s an incredible 18-mile bike trail from Alexandria, VA to George Washington’s estate at Mt Vernon. One of the best things about D.C. is the abundance of fantastic bike trails, many of them running along old canal towpaths or converted from trolley trails. I spent a couple years cycling to work from Bethesda (12 miles north) to downtown D.C. on a fantastic trail called the Capital Crescent. Downhill on the way in, following the curve of the Potomac down to Georgetown. Then uphill on the way back. There’s nothing like cycling uphill in the dark, sometimes in the rain or snow, for 12 miles after a long day’s work. At the time I worked for a magazine covering corporate law of all things. I think I earned around $40k/year at the time but I was quite content.
As any DC resident knows, there’s a spectacular natural landmark not far from the city. I speak of Great Falls, a series of enormous rapids 14 miles upstream of DC. The falls drop 80 feet in under a mile, including a 50 foot drop over 1/10 of a mile. The flow rate increases dramatically as the Potomac is crammed into a narrow gorge. It’s quite breathtaking, especially when the river is engorged after a rainstorm. These are Class V+ rapids, with only the most experienced kayakers able to traverse them. Fatalities are not uncommon. Swimmers in the area also frequently drown. Gigantic signs adorn the banks of the river grimly warning of the number of drownings in the area. The rapids are so dangerous that kayakers are cautioned to attempt them only during off-peak hours so as not to attract attention from park visitors who get dangerously close to the river in their enthusiasm to watch.
There’s a great trail with fantastic views of the falls on the Maryland side called the Billy Goat Trail (Section A is the one you want). It has plenty of scrambling over rocks for those who enjoy that sort of thing. Growing up our family must have done it a dozen times at least, maybe more. My dad had a habit of doing the relatively demanding trail in flip flops. Invariably one would break and he would march on, stoically, with one foot bare, insisting that he was just fine. If you ever visit D.C., take a break from the monuments and give the trail a shot. The first half winds right along the river on the sheer rocky banks, and the latter half takes you back along the canal and towpath.
This is where George Washington features again in our story. Washington, aside from being a general, nation-builder, statesman, and one of the largest landowners in the U.S., was also a huge aficionado of canal-building. Long before he commanded troops in the revolutionary war or assumed the Presidency, he pursued canals with a passion. In 1748, at the mere age of 16, the youthful Washington was hired by his mentor Lord Fairfax to join a surveying expedition in western Virginia. (Washington’s surveying career spanned his entire life; he continued to undertake surveys up until his death in 1799.) This first trip convinced Washington that a series of canals around the Potomac’s impassable rapids was the key to linking the coast to the fertile Ohio valley. He would spend the rest of his life, political career permitting, attempting to realize this vision.
In the wake of the Revolutionary war, Washington formed the Patowmack Joint Stock Company in 1785 in pursuit of this dream. The Company through great adversity eventually completed five canals, including a canal skirting Great Falls, which opened in 1802.
To build the locks descending alongside Great Falls, Washington’s canal required black powder to blast out the rock, one of the first engineering projects in the U.S. to use this technique. Given the general lack of modern engineers in the country at the time, this work was slow and arduous. In the end, the Patowmack Company made a 218-mile stretch of the Potomac somewhat passable, with boats taking the river most of the way, and using the canals and locks to descend impassable portions. That’s why it was called a ‘skirting’ canal — it didn’t replace the river but rather supplemented it during the rockiest bits. The system was nevertheless somewhat rudimentary. As the national park service relates:
Some years there were only about 45 days when the water reached a sufficient level for the locks to operate. The Potomac itself was unpredictable and often tore up boats in rapids and whirlpools. Because no one could pole against the strong current, boats had to be broken up in Georgetown and sold along with the other cargo. A more effective way was needed to navigate the Potomac.
In the pre-steamboat era, traveling upstream on the Potomac was basically impossible, so the direction of travel was one-way. The vestiges of some of these canals and locks, including the ones at Great Falls, still exist and can be visited today.
Economically speaking, the Patowmack Company was not a success and folded in 1832. Its operations (and some of its locks) were incorporated into the more substantive Chesapeake & Ohio (C&O) Canal, which ran parallel to the Potomac. The C&O canal, completed in 1850, linked the coal mines of Cumberland, MD with Washington D.C., operating until 1924. The C&O Canal was passable in both directions, with mules towing boats along the towpath. Today the towpath running along the 184-mile length of the canal (or its desiccated remnants) remains intact, thanks to Richard Nixon’s 1971 designation of the Canal as a national park.
This is a picture of the ‘Little Falls’ section of the original Patowmack canal, later folded into the C&O canal. The present day C&O canal and towpath looks like this along much of its length. In the summer it’s chock full of turtles sunbathing on logs, fish, and birds, which are attracted to the warm, placid waters.
For his part, Washington had to abandon his canal-building plans in order to preside over the Constitutional Convention in 1787, which would end with him assuming the role of the presidency in 1789.
A man, a plan, a canal
But Washington’s work on canals was not wholly distinct from his nation-building ambitions. Indeed, it could even be said that his desire to unite the interior frontier of the country with its coasts led to the constitutional convention itself. The canal was a multi-lateral endeavor; the canals along the Potomac were bordered by Maryland and Virginia and thus both states had an economic interest in the project. Postwar relations between the two states were anything but harmonious, though. Washington took on the unenviable task of persuading the assemblies of both states to support the canal. With the help of a convention hosted at his estate in Mt Vernon, he was able to reach an accord. Future ideological opponents James Madison and George Mason also supported the canal and associated convention. There, delegates from Maryland and Virginia agreed on the Mt Vernon Compact, which governed river navigation rights, fishing rights, and the sharing of toll duties from canal passage.
After the success of the Mt Vernon Convention, the future-framers decided to invite other states to the discussions, broadening their scope from simple questions of river tolls to commerce more generally. In 1785 letter, Madison urged Washington to take advantage of the traction from the Mt Vernon conference:
It seems naturally to grow out of the proposed appointment of commissioners to Virginia and Maryland, concerted at Mount Vernon, for keeping up harmony in the commercial regulations of the two States. Maryland has ratified the report, but has invited into the plan Delaware and Pennsylvania, who will naturally pay the same compliment to their neighbors.
Thus in 1786, Madison organized a second conference, this time in Annapolis. The objective was to “take into consideration the trade of the United States” and “consider how far a uniform system in their commercial regulations may be necessary to their common interest and permanent harmony.” This time, delegates from Virginia, New York, Pennsylvania, Delaware and New Jersey attended. Among them were Madison, Alexander Hamilton, and Edmund Randolph, future Secretary of State under Washington.
At the time, the nation was in deep recession, and the incipient Confederation was unable to finance itself through taxation nor able to devise a consistent trade policy. Shay’s rebellion, a populist uprising in Massachusetts triggered by a postwar debt crisis, was also underway at the time. The political atmosphere was grim. Thus at the Annapolis convention, Hamilton became convinced of the need for a wholesale reimagining of American governance. He proposed a subsequent convention in Philadelphia the following year, “to take into consideration the condition of the United States, and to devise such further provisions as shall appear to them necessary to render the constitution of the Federal government adequate to the exigencies of the Union.”
Thus it could be said that Washington’s canal ambitions set off a causal chain that led directly to the Constitutional Convention in 1787. National Geographic in their June 1987 issue described the Patowmack Canal as the ‘waterway that led to the constitution’.
Constitution or a Coup?
There’s a strain of revisionist history, which I am partial to, that treats the constitutional convention, and the ensuing establishment of the United States, as a kind of bloodless coup. The Confederation was certainly ineffective, but it had not failed entirely at the time of the convention. And if you compare the Constitution with its predecessor, it was considerably less democratic. Curtis Yarvin puts it plainly:
The Constitution is an elected monarchy because the Constitution was installed as a right-wing coup. Its goal was to replace the chaotic and ineffective Congress of the Confederation with an effective government that was monarchical and national, while retaining the cosmetic appearance of a federation of sovereign states. Later this fatal, unresolvable ambiguity produced a war; it worked quite well for most of a century.
adding,
In America, something like pure, decentralized democracy lasted roughly from 1776 to 1789. The Congress of the Confederation worked so poorly that Americans airbrushed our first national government out of our own history books.
Indeed, the colonies did organize a government between the end of the revolutionary war in 1783, and Washington’s first term, which began in 1789. The Continental Congress had no fewer than ten separate presidents (although these presidents had little executive power, being part of the congressional body). This government didn’t function particularly well, but it existed.
Now to Yarvin’s question, if you went to school in the U.S., how much time was devoted in history class to this era in history? I would venture that you recall an unbroken narrative from the Declaration of Independence straight to the framers, with no discussion of the 13 year interregnum. Was the name of John Hanson, the first individual known as ‘President’ in the United States, mentioned at all?
There’s a very detailed book on this topic called The Framer’s Coup, by Harvard Law professor Michael Klarman, that casts the Constitutional Convention as a kind of reprisal of the elites against the incipient democracies that existed at the State level. Indeed, it’s quite clear that the U.S. Constitution was much less democratic than the Articles of Confederation. The Constitution established the Senate (at the time, Senators were chosen by the States, rather than being directly elected), the Electoral College, clearly intended to insert elite discretion into the presidential selection process, and firmly entrenched the Federal government as superior to the States.
So why did the Constitution include such apparently anti-democratic measures? Klarman argues that, post revolutionary war, these State-driven democracies had embraced populist policies imposing a kind of economic class warfare designed to disempower large landholders and benefit poorer farmers and the working class. He lays it out in a 2010 talk:
The Framers’ constitution was mostly a conservative, aristocratic response to what they perceived as the excesses of democracy that were overrunning the states during the 1780s.
The Framers were trying to create a powerful national government that was as distant from popular control as possible: very long terms in office, large constituencies, indirect elections. They thought of democracy as rule by the mob. They didn’t think poor people could be trusted with the suffrage. They didn’t think women should vote.
A lot of what the original Constitution was about was constraining the power of the states to pass laws beneficial to debtor farmers in a time of economic distress and expanding the power of the national government to that it could efficiently raise taxes in order to pay off government bond holders, who often were merely speculators in such debt rather than initial suppliers of credit.
According to this reading of history, it may well have been the case that the Founding Fathers were motivated by a desire to reign in loose monetary policy that was benefiting debtors (by inflating away the real value of their debt) and harming the creditor class (which they, as a kind of American landed gentry, by and large consisted of).
This is a monetary theory of the Constitution not often advanced, but one that seems to align with many of the Framers’ stated views on monetary policy. Jefferson for instance once claimed that “paper is poverty,” describing it as “the ghost of money, and not money itself.” He additionally sought to advance an amendment abolishing borrowing at the federal level. Washington was no fan of fiat either, writing in a letter: “paper money has had the effect in your state that it ever will have, to ruin commerce, oppress the honest, and open the door to every species of fraud and injustice.” James Madison was equally aggrieved, claiming that “paper money is unjust,” adding: “it is unconstitutional, for it affects the rights of property as much as taking away equal value in land.” (And if you read Madison’s Federalist 10, it seems he isn’t a huge fan of direct democracy either.) Virginia’s rampant currency printing and devaluation during the revolutionary war likely affected Madison, Jefferson, and Washington, as they were all Virginia landowners. They would all have likely dealt with losses stemming from the inflation, with Jefferson hit particularly hard.
In this context, the ‘elite economic reprisal’ theory promoted by Klarman seems rather persuasive. The New Republic further elaborates on the theory:
Not surprisingly, common people began to use their new political influence to create economic policies that were favorable to themselves (and disadvantageous to creditors and wealthy citizens), such as inflationary monetary policy and progressive taxation. The Constitution, according to the economic interpretation, was the 1 percent’s revenge, a countermeasure designed to undermine the democratic governments in the states, thereby returning power to wealthy elites and insulating them from popular opinion.
The notion of the founding of the nation as an elite-led reprisal against democracy, motivated at least in part by concerns regarding excessively loose monetary conditions, is an idea that tickles me no small amount.
I’m generalizing, but Bitcoiners by and large aren’t noted fans of democracy. We tend to vote with our wallets. Granted, it’s hard to be a fan when democracy created for us the worst debt overhang in peacetime in the history of the nation. We are at wartime debt to GDP levels, without having fought a war, and without any clear way out. The government commands the largest role it has ever had in society when measured by expenditures as a share of GDP. It’s not hard to see why we might be disenchanted with the electoral process.
I have long considered Bitcoin a bit of an inversion of prior populist monetary movements. Historically, populism generally entails a demand for loose monetary policy and the easing of credit. Jubilees and the cancellation of debt as Graeber relates are among the oldest political traditions in existence. So when I think of populist monetary movements I think of William Jennings Brian and his ‘cross of gold’. His ‘free silver’ movement aimed to expand the money supply, thus softening the currency and bailing out indebted farmers. Bitcoin, representing a hard money, low time preference, high interest rate ideology is the opposite. But how often do you see populist monetary movements in favor of hard money? I’m not sure I can think of one.
Some of the critics are right, I think. Well, partially. Any political description of Bitcoin will be both overly broad and incomplete; Bitcoin is a gigantic tent and is used by likely north of 100m individuals worldwide; no single idea unites them. The protocol is cold and unfeeling and manifests no ideology. It’s the collision of this neutral system with the established political world that is revealing. And certainly, groups of bitcoiners exist with definite political ideas.
For instance, the popularity of Bitcoin in the developed world could well be interpreted as an elite reprisal against the current populist desire to loosen monetary conditions, collapse asset prices, and eliminate general indebtedness, especially among young people. If you wanted to be dramatic, you could say that we currently face the choice between becoming a permanently indebted nanny state like Argentina or undertaking a hard money reset, such as the founding fathers engineered. In other words, default or austerity. I have my preferences, but I don’t think they’re widely shared.
Back to the canals. Something Washington’s economically unsuccessful canal project makes me think about is the importance of timing in tech investing. His travails are a stark reminder that being a visionary with regards to the progress of technology is not sufficient; you have to execute at the precise right time too. The challenging thing is that knowing when a technology is “due” is impossible a priori and without experimentation; thus tech innovation is necessarily built on the back of many prior failures that were directionally right in their thesis. Gwern puts it well in his stellar essay, Timing Technology: Lessons from the Media Lab:
Technological forecasts are often surprisingly prescient in terms of predicting that something was possible & desirable and what they predict eventually happens; but they are far less successful at predicting the timing, and almost always fail, with the success (and riches) going to another.
Gwern points out that accurate technological predictions are abundant, but what is unknown are the precise conditions and timing that will give rise to economically viable technological outcomes. In the case of canals, it may have been the most obvious thing in the world that transporting goods via waterway was more efficient than by cart and ox; but the the skills and technology required to build the ambitious canal projects of the late 18th century U.S. were virtually absent in the burgeoning republic. Thus it took Washington’s company 17 years to build the 1,800-yard canal at Great Falls (one of five in the Patowmac plan). He would not live to see it completed.
As someone who is paid to predict the future, or at least to try to anticipate trends before they are obvious, I think about Gwern’s essay quite often. It has a vaguely fatalistic tint to it. Founders may know the future, but the only way to learn whether it’s time for the future to arrive and whether conditions are economically suitable is to throw themselves at the problem. In practice, ‘transformative’ technologies involve numerous failed attempts before one finally hits at the right time. But the tragedy is that you have to be irrationally optimistic to have a chance at hitting. Almost definitionally, winners will be attempting to pull off a similar idea which has failed many times before.
This is why Gwern says that the future is built “by individuals acting suboptimally on the personal level, but optimally on societal level by serving as random exploration.”
In Washington’s case, he couldn’t achieve sufficient political buy-in to get the multilateral canal project off the ground as the returns from a canal were not sufficiently obvious in the pre-industrial era and serious canal-building technologies were not yet available. The subsequent C&O canal did much better, as transporting coal to the coast made a lot of sense — although it’s worth noting that the C&O canal was nearly obsolete upon completion in 1850, as the B&O railroad had already reached Cumberland by that time. So canals were a kind of cursed technology, at least in the agrarian and industrializing USA. When they were really needed, they were impractical and costly to build; and once they could be built economically, railroads quickly supplanted them.
All of that said, the towpaths along the contemporary remnants of the canals, especially the C&O Canal, make for a really nice crushed gravel bike path today. I like to think that Washington, an itinerant rambler at heart, would have felt that it worked out quite nicely after all.
For our second episode in the Stables 2.0 miniseries, Peter Johnson, co-head of Venture at Brevan Howard Digital, returns to the show to talk about his latest theses on stablecoins. In this episode:
The origins of Peter’s interest in stables
We review Peter’s prior stablecoin predictions
USDC versus USDT market share trends
Peter’s main takeaways from the Relentless Rise paper
Martin Carrica, cofounder of Mountain Protocol, joins us to discuss their launch of their USDM, permissionless interest-bearing stablecoin. In this episode:
Martin’s story and origins of his desire to create a stablecoin
Obtaining a registered digital assets company in Bermuda
Martin’s review of regulatory options worldwide and how they ended up in Bermuda
How Bermuda has distinguished itself from other financial hubs in the Atlantic
How reinsurance is like stablecoins
What it takes to get licensed as a digital asset business in Bermuda
How Mountain Protocol’s USDM stablecoin works
How rebasing stablecoins work – and how they integrate in DeFi
How USDM differs from on-chain T bills and other interest bearing stable products
How USDM was able to achieve a permissionless structure
How Mountain avoids US clients
Why the market for stablecoins is mostly ex-US
Stablecoins as a backend for emerging market fintechs
Different exchange rates in Argentina
How Argentine firms use Argentine ADR stocks to manage their corporate cash
How street moneychangers on the street in Argentina work
Milei and the prospects for dollarization in Argentina
The importance of a stablecoin being issued out of a bankruptcy remote structure
Disclaimer:
USDM and other Mountain Protocol products and services are not available for U.S. persons as well as other restrictied jurisctions.
For more information and disclosures on Mountain Protocol, please refer to the Terms and Conditions.
In Coin Metrics State of the Network Issue 223, we explore predominant collateral types in DeFi lending protocols and evaluate their liquidity & volatility characteristics to determine their desirability as collateral
We sit down with Lee Bratcher, President and Founder of the Texas Blockchain Council. Lee is one of the primary architects of Texas’ Proof of Reserve bill, now in effect. In this episode:
The origin of the TBC
Why Lee is moving their Summit to Ft Worth
Notable legislative successes by the TBC in Texas
The importance of getting the UCC to recognize digital assets
The importance of Bitcoin mining
The origins of HB1666
Why PoR legislation benefited from the industry spontaneously adopting the standard
How the TX PoR bill emerged as a compromise
How Lee expects this to become model legislation in other states
Comparing PoR to established financial statement audits
The importance of frequency in Proof of Reserve
The lack of accounting firms that are willing to supervise PoR
How would PoR dealt with issues at Gox, Quadriga, FTX, or Prime Trust?
How are companies operating in Texas reacting to the bill?
Future legistlative directions
The role of stablecoins in upholding the role of the dollar
The lost authority of the states in chartering banks
In Coin Metrics State of the Network Issue 221, we provide a data-driven overview of halvings and their implications in anticipation for Bitcoin’s upcoming 4th halving
In our new special insights report, we utilize a balance sheet like methodology to contextualize the health of DeFi lending protocols through the lens of two recent exploits on Aave and Curve Finance
In our new special insights report, CM lays out the key fragilities of stablecoins and how on-chain and market data can help monitor these risks for the future of digital dollars to materialize
In this special edition of State of the Network, we are excited to share a new report that translates the legal language of securities framework for digital assets into objective, measurable criteria from “on-chain” data
In this episode, we hosted Richard Meissner, CTO of Safe, to illuminate the state of adoption of smart contract wallets following the roll out of ERC-4337 (an effort to standardize account abstraction on Ethereum). Our conversation covers:
The limitations of smart contract wallets in a multi-chain universe
Account recovery and hybrid custody using traditional institutions
Combining account abstraction with intents and AI
Worldcoin’s use of Safes and adoption of smart contract accounts
Find additional content by Safe on account abstraction here.
Public blockchains have been touted as cure-alls by enthusiasts over the last decade. Promoters have promised faster securities settlement, decentralized social media, instant payments, cheaper remittances, and everything in between. And indeed, these benefits may come in time. But there’s one domain in which blockchains clearly outperform their traditional counterparts today: accounting.
Blockchains track debits and credits to accounts on a ledger, just like an ordinary accounting system, but in a real-time, transparent, and immutable fashion (once transfers are settled). The existence of any asset that resides on a blockchain—whether a tokenized security, or a digital commodity like Bitcoin—is fully verifiable at any time by anyone with an internet connection. The entire supply of Bitcoin, down to the tiniest unit—one satoshi—can be verified in real time by anyone running a node. What’s more, any entity can prove mathematically to any third party that they own a digital asset via a cryptographic signature, without the need for any guarantor. This isn’t the case for traditional assets or commodities, which rely on a network of intermediaries to attest to their existence. In practice, this means financial assets end up concentrated in large custodians, like the DTC with equities, or gold with organizations like the LBMA. The high cost of auditability for conventional assets tends to have a concentrating effect.
This remarkable auditability property of digital assets has enabled crypto platforms to build attestation tools enabling end users to verify that their assets are actually being held in reserve, and don’t simply exist on someone else’s ledger, subject to error or fraud. And these tools are long overdue. For as long as crypto exchanges and custodians have existed, they have let down their users with a series of spectacular failures—one crisis after the next from Mt. Gox to Bitfinex to Quadriga to FTX and, most recently, Prime Trust. Those of us who believe in the promise of digital assets are fed up with this grim status quo and have begun to demand more transparency from the exchanges we all rely on.
As a result, exchanges and custodial platforms today are coalescing around a simple idea: What if these platforms could indisputably prove to users that they control funds held for users? This is known in the industry as a proof of reserve, or PoR. The concept has existed in the digital asset context for around a decade, and it has been continually refined ever since. Effectively, it involves a custodial platform providing signatures attesting to their unique ownership over some digital assets on-chain, combined with a disclosure of client liabilities. By publishing these datasets, and giving end users—and even interested onlookers—the option to actually verify that a given liability corresponds to some assets, clients can gain strong assurances that the platform is sound.
Legislative initiatives both at the state and federal level have focused on asking exchanges to segregate client and operating capital, and to give clients assurances in the case of platform liquidation or bankruptcy. This is necessary, but only part of the solution. Prime Trust, which recently revealed it had lost $82 million in client assets and hid those losses for years, was a Nevada Trust company. The architecture of the Trust Charter, ironclad from a legal perspective, unfortunately did little to reveal the loss of assets. A monthly—or even higher frequency—attestation, as is the standard with PoR, would have forced divulging the loss when it first occurred, because Prime Trust would not have been able to provide valid signatures for user funds held. This would have also been the case with Mt. Gox, Quadrigra, and FTX. These were all drawn out insolvencies, concealed for months if not years. An exchange engaging in PoR attestations isn’t immune from losing customer funds or being hacked, but the PoR does reveal these losses when they occur, limiting further fallout.
In the wake of FTX, PoR is now being voluntarily adopted across the industry. Many of the largest exchanges worldwide, including Kraken, Binance, Bitmex, Derebit, Kucoin, and OKX, now conduct these attestations with frequency, covering tens of billions of dollars in client assets.
Lawmakers in the U.S. and abroad have begun to recognize the importance of PoR. In March, Texas passed the landmark HB1666, which requires firms with money transmitter licenses to carry out PoRs, starting in September. At the federal level, Sens. Cynthia Lummis (R-Wyo.) and Kirsten Gillibrand (D-N.Y.) included in their reintroduced Responsible Financial Innovation Act mandatory PoR and a request for PCAOB to standardize the procedure.
Since 2021, Wyoming has made reference to proof of reserve in the state’s Digital Asset Custody Framework. Dubai (see Reserve Assets) and Singapore (see Regulation 16C(11)) have also made reference to similar on- and off-chain reconciliations in recent guidance. Canada has recommended since 2021 that exchanges engage in PoR as a best practice. Bermuda, which is distinguishing itself as a premier crypto-focused regulator, has maintained an explicit reference to proof of reserve in its Digital Assets Custody Code of Practice since 2019. PoR is neither new nor limited in its reach to a handful of enthusiasts. It has existed for years and has already been embraced by regulators worldwide.
That doesn’t mean PoR is without its critics. Sens. Elizabeth Warren (D-Mass.) and Ron Wyden (D-Ore.) have engaged in a campaign of harassment leveled at auditors who service crypto firms. They aim to stymie the crypto space by stripping it of CPA firm services, which are necessary for platforms operating in compliance with MTLs and similar regulatory regimes. In a recent letter to the PCAOB, they attacked PoR and called it a “sham audit.” The PCAOB duly released an advisory letter warning investors about PoR attestations. Frightening audit firms away from a fit-for-purpose form of assurance is the opposite of what a reasonable accounting regulator should do. For its part, the AICPA has demurred on issuing any guidance on PoR even though it’s progressing on stablecoin attestation standards. This uncertainty has had the effect of leaving most CPA firms unwilling to supervise these procedures. We in the industry are pushing for more sunlight, but some lawmakers in Washington aim to leave us in the dark.
The standard critiques of PoR have largely been addressed. PoR is not contemplated as a substitute for standard audit types but rather as a complement. Mindful of this, the Texas legislation blends traditional and crypto-native assurance, asking for PoRs but also for CPAs to supervise them. Specialist CPA firms have emerged with expertise in overseeing these procedures. Traditional assurance is fine, but it’s no substitute for a high-frequency proof to end users that custodians have their funds. And while early PoRs ran the risk of leaking client data, innovations—such as zero-knowledge proofs—allow PoRs to be done safely.
We are not asking crypto exchanges to be held to a different standard from conventional custodians. In fact, a frequent proof-of-reserve attestation provides far more transparency than conventional custodians can offer. It’s not a substitute to standard audits but rather a more narrow complement—it enhances conventional audits. Together, the two provide a level of assurance not otherwise attainable. We ask simply that Washington stop undermining the industry’s efforts to clean itself up, recognize the validity of PoR, and facilitate its proliferation across the industry. Lawmakers should encourage the accounting standards setting bodies, like the FASB or the PCAOB, to ratify industry efforts around PoR so audit firms feel empowered to supervise them. And they should recognize the good work that custodians are already doing to make themselves more transparent and accountable.
The crypto industry is working hard to gain back trust. If PoR becomes widespread and standardized, we will exceed the level of assurance that custodians can offer with traditional assets. This is a worthy goal, and one that Washington should support.
Nic Carter is the cofounder of blockchain-focused investment firm Castle Island Ventures and the cofounder of blockchain data company Coin Metrics.The opinions expressed in Fortune.com commentary pieces are solely the views of their authors and do not necessarily reflect the opinions and beliefs of Fortune.
In this issue of State of the Network, we dive deeper into Grayscale’s trusts and discuss the evolution of the digital assets investment landscape with the anticipated arrival of spot ETF’s
Amir Haleem, the founder of Nova Labs (formerly named Helium, Inc) joins the show. In this episode we discuss:
The origin of Helium and the Helium network
Amir’s views on L1 blockchains and the path that the company took in evaluating building its own chain versus building on an existing L1.
Decentralized Physical Infrastructure (DEPIN) and Decentralized Wireless (DEWI) as emerging categories demonstrating real-world applicability of public blockchains.
The various tokens in the Helium ecosystem and how they interact.
MVNOs and how Helium Mobile is positioned.
The regulatory landscape in the United States and how Helium has navigated these waters.
In this issue of State of the Network, we assess Bitcoin’s resurgence and gauge market sentiment amidst a rapidly evolving digital asset landscape marked by regulatory ambiguity and external macro events.
Wyoming state senator and Minority Floor Leader in the Wyoming Senate, Chris Rothfuss joins the show. We cover Wyoming’s crypto efforts to date to create a stable and secure digital asset ecosystem. In this episode:
Senator’s Rothfuss’ pre-politics career and how he came to grapple with the crypto space
Why Wyoming has an opportunity in digital asset policy
The origins of Wyoming’s blockchain select committee
How the NY Bitlicense inspired Wyoming’s efforts
Why crypto policy isn’t politically polarized in Wyoming
Wyoming’s foundational move to recognize digital assets under the uniform commercial code
The origin of the SPDI charter
Is there a future for the SPDI given that the Fed is denying master accounts?
How Wyoming’s SPDI emerged as a consequence of Chokepoint 1.0
Is the Fed blocking state charters unconstitutional?
Wyoming’s Stable Token Act and the prospects for that product
How the WY Stable Token could be a huge windfall for Wyoming – and where the revenues would be directed
How Wyoming is thinking about the permissionless qualities of the stable token
In this issue of Coin Metrics’ State of the Network, we analyze the impact of token unlocks and free float supply shocks through the lens of various unlock events to explore the behavior of participants under different market conditions
In this episode, we sat down with Lili Infante, Founder and CEO of CAT Labs. Lili shared:
Her experience spearheading the formation of the crypto taskforce at the DOJ
How the crypto-enabled crime landscape has evolved and become more sophisticated
Investigating cases where crypto is used and the unique challenges in establishing a chain of custody
Products CAT Labs is building to more effectively recover digital assets and protect against situations where assets are compromised in the first place
Learn more about Cat Labs in Fortune and on their website.