James Murphy: The Banks Collapse and Regulating Crypto

actually there's plenty to talk about. The problem is there's too much to talk about. Trying to narrow it down to what we're going to talk about, but man, there is so much going on. Of course, we've been talking about the financial system melting down, the FED raising rates, they're draining liquid o the system until something breaks like the banks. Of course, the Bank's broke. We talked about that last week. If you've missed that, go check it out on the podcast. Just search the Mark Moss Show

on the podcast. But there's another thing at play here. There's like this dangerous undercurrent that's going on. So while everybody's witnessing the FED and all eyes are on the FED and the raising rates, and then we're witnessing the banks going down and SVB had to get billed out. And then you know, now the Treasury and the FEDS that are going to backstop all the deposits now Jane

Yell and the Treasury said they're not going to. And there's all this, right, all this distraction going on, There's like something else going on down below the surface, something that's deeper and darker and more scary. Now, this week came out this report called the Economic Report of the President. It was a long report. I wouldn't necessarily recommend that you read it unless you want to and carry some

brain damage. It's about almost four hundred and fifty pages long, four and frety pages for the Report of the President. The Year in Review, the Years Ahead, confronting new global challenges with strong international economic partnerships. Investing in young children's care and education. You already know what's happening to the kids education at school. You don't want to know about that. Chapter five, Building stronger post secondary institutions, So apply challenges

in the US labor markets. Man, this is all just simple. Just tell the government to stop get out of this competition in the digital economy, new technologies and old economics. Chapter eight Digital Assets, Relearning, economic principles, relearning economic principles. I think they're the ones that should go back and relearn economic principles. Chapter nine Opportunities for better managing weather

risk in changing climates. And then there's some appendages Report to the President on activities of the Council of Economic Advisors, Statistical tables relating to income, employment, production, and more So, while all of this, I like to think of it like a magician. Right, most of you probably know. I hate to ruin it for you, but magic isn't real.

It's slide of hand. Hey look over there while they do something over here, And that's sort of like what seems to be happening where all of this stuff is going on. And in the meantime, I'm they're like trying to ram a bunch of stuff through. Now. In the previous segment, I talked about two different open source protocols, a monetary protocol and an information protocol. It's going to

change the world. Closed systems are going to continue to get more closed, but open systems are going to continue to compete for those and we're going to move more to the open systems. If you miss that, go check out on the podcast player. Just search Mark Moss show you can catch that. But going back to what the government's doing. Something I've been talking about for a while is this Operation Choke point two point zero as we're

labeling it. There was a one point zero. Lots of people in the government got in trouble under Obama, the Obama administration, Lois Learner I believe ahead of the IRS had to step down and all these things. But in this economic report, well so now with this choke point two point zero, and it looks like through the fog of war, there's a lot of casualties. So we had this banking collapse, and it was silver Gate Bank, then it was Silicon Valley Bank, and then it was Signature Bank,

the three s's. The one thing that seems to tie all three of those together is that they were all very crypto friendly banks. Silver Gate was one of the main crypto banks SVB, which of course Silicon Valley Bank, a lot of Silicon Valley was in crypto projects. And then Signature Bank, which was another very crypto friendly bank. Now why did those three banks go down? And we've talked about it extensively. You know, they got a bunch of money deposits because the FED created so much money,

their deposits swelled up. They put them into US treasuries. The FED raised rates, the treasuries lost value. The banks didn't have money. Somehow a bank run got triggered where a lot of people wanted to go pull their money at the bank. The banks didn't have it, And that's the story that we're told, and that's actually what happened. But why did those things happen is the better question to ask. Why was there a bank run triggered on SVB putting out on all the other banks. Every bank

is in the same situation. This is not just unique to those banks. They're all in the same situation. So why was there a bank run? Now, you know, I'm no stranger of dipping my toe in the conspiratorial waters, if you will, because I'm trying to make sense of all this and I just don't understand why those banks got attacked. And like I said, it just so happens that the three of them were very heavily into cryptocurrency companies.

Now into that after the two thousand and eight banking collapse, there was a whole bunch of new regulations that were put in place. One of them was called the Dodds Frank Act, and one of the original writers of that, Bill Dodds, put put out an article saying that he doesn't understand why and regulators at the FDIC didn't understand why Signature Bank was taken over. It wasn't insolvent. There was no reason why I should be taken over. So why was it taken over? Why was it taken over?

The other two Signal two s banks, Well, and they're all related to crypto. Now, if we go back and read this economic report of the President, it starts to give us a little bit of a better picture. Now, they had a very scathing report, let's say, to talk about cryptocurrencies as a matter of fact. And of course it came during this growing industry concern that federal regulators are looking to debank these crypto companies. So you know, the narrative that they're trying to control is that these

banks went down because they were doing risky crypto assets. Well, first of all, they didn't lose money on crypto. They lost money because they put their money into the US treasuries. But it looks like part of this chokepoint, you bueno, where they're trying to take away the banks that these company us. Now, the report that this came out said that many cryptocurrencies do not have a fundamental value. Okay, well I would agree. Now, of course, I'm very clear.

I like to say bitcoin not crypto. What do I mean by that, Well, I'm not saying that bitcoin is not a cryptocurrency. What I'm saying is when I'm talking about bitcoin, I'm talking about bitcoin only, and when I talk about crypto, I'm talking about crypto everything else other than bitcoin. So we always want to make those two things very clear. But what is a fundamental value? Typically you might consider that be called like an intrinsic value,

which there's no such thing as intrinsic value. All value is subjective. But they say that it's argued that crypto assets may provide other benefits, such as improving payment systems, increasing financial inclusion, and creating mechanisms for the distribution of intellectual property and financial value that bypass intermediaries that extract value from both the provider and the recipient. Looking under the hood at these arguments, however, shows a more complicated picture.

So far, crypto acids have brought none of these benefits. End quote. That's what the report said. I talk about this all the time. We're gonna get this a little bit later when I can talk about some other news headlines. The number one threat to our democracy, the number one threat that they talked about a Davos in Switzerland at the World Coming Forum in February is supposedly is misinformation and disinformation. But the but the irony is that all

the misinformation comes from the government. I don't want to say all. A good majority of it comes from the government itself. So how can they go and say this, How can they go and say this? So bitcoin hasn't done anything to increase financial inclusion. It certainly helped in Africa. Over eighty percent of all bitcoin transactions under a thousand dollars are being done in Africa where they don't have access to banking. It says that they said it could

bypass interminiaries that extract value. Well, that's being done. It's it's doing payment remittances all over the world right now and bypassing the extraction of these intimitaries. So it's doing that. So looking under the hood, it shows that it's exactly done. Just that they've nailed it exactly except for of course,

the Office of the President is lying to you. If you're just tuning in to listen to the Mark Moss Show, talking about, of course, the decentralized revolution, running through some of the latest breaking news headlines of the week, and looking at the attack on the banking sector and the crypto sector. I got a very special guest coming up when we come back, an SEC attorney. We're gonna talk more about this attack. You don't want to miss this. I'll be right back in a second. Don't go away,

all right, Welcome back. If you just tune in, you're listening to the Mark Moss Show. Of course we're talking about some of the latest breaking news headlines of the weeks, you can understand what's going on. And before the break, I was talking about how this banking crisis is all the rage. Everyone's focused on that, but then there's like

these dangerous undercurrents at the same time. Some of it's sparked by this economic report of the President that came out and this kind of choke point two point zero that I've been talking about. I have a very special

guest with me right now. I got James Murphy. You can find them online at Meta law Man he has a securities attorney, and we're going to talk about what potentially is going on here now, James, I had you on before, and you know, I was kind of talking about how I thought we were going to continue to see a massive push into more regulations on these crypto assets.

They would be labeled securities, and you know, I was even going as far as saying as a category, we might not see another bull run in cryptocurrencies again, not bitcoin, and so far that seems to be what's happening. And there's a lot of things happening really quickly. We're really seeing the SEC step up enforcement. A lot of data points that dig into. Let's start with one that that broke this week that seemed to be really big and it was coin base being hit with this wells notice.

Break that down for me a little bit. Yeah, sure, So a wells notice is a standard part of the process when you are under investigation by the SEC. It typically comes near the end of the process US where the staff within the Division of Enforcement, which is a part of the SEC, says to the target of the investigation, we the staff of Enforcement, intend to recommend to the

Commissioners that they approve a lawsuit against you. The purpose of the wells notice that communication is to give the target an opportunity to rebut the allegations of wrongdoing and to convince the Commissioners not to follow the recommendation of the Enforcement Division and instead decline to approve the lawsuit. So that's where it is in the process. That's generally near the end. There's been a couple weird things about

how this has happened. One, in the communication, the sec declined to inform coin Base which tokens they believe our securities, which tokens they're going to assert our securities in a potential lawsuit. So that makes it a little difficult on coin Base to rebut the contention if they're not told which of the tokens are allegedly violative. Yeah, of course. And the second weird thing about it is they only took two depositions of uh, you know, executives at coin Base.

That's weird. I've handled many of these and you could see dozens, particularly on a big case. You know, this is to the advantage of the Division of Enforcement to get people on the record under oath as much as possible. So it feels, you know, I'm not representing anybody, and it feels like it's a little bit rushed, even though they've been threatening. Gary Gensler has been threatening to do this for ever since he took office a couple of

years ago. So those are those are two unusual points in and it's possible that the one or more of the commissioners will be uncomfortable if the if the Division Enforcement continues to refuse to say which tokens that are listening on coin Base are securities? Yeah, do we know that it's specifically about tokens that are listed that could be securities? Or could it be because of like yield products that they have some of that we've already seen

happen with Jim and I. Yeah, great question. I'll tell you what. The disclosure by coin Base was the most thorough disclosure I think I've ever seen of a Wells notice. You know, actually, Mark, there's some disagreement at the securities bar as to whether a public company is required to disclose the fact that they have received a Wells notice. It is the safer course of action to disclose by

a public company. But in any event, they went in a great detail about the whole process leading up to this wells notice and all of you know, there are many interactions with the SEC trying to head this off, trying to establish, you know, a regulatory framework that they both could agree on. But in any event, they said it. They said it's about some of the assets they have listed, and it's about a yield product as well. And so we've seen that kind of case before. So we kind

of know that we've seen what happened with Gemini. They paid a fine, they listed it, they were kind of okay. But now you're saying coinbase is saying it's actually because of some assets. Would that be strange that gem and I didn't get hit with assets that it has, it only got the yield product. Would it be weird that they already went after an exchange and only went after yield and now they're going after an exchange for both And would they then go back to Jim and I

or how does that work? Well, you know this fits in the under the rubric of prosecutorial discretion. Now they're not prosecuting crimes. The SEC prosecute civil claims against people, not criminal, but they get to pick. Why did they pick coin Base? I don't know, but you're one hundred

percent right. They could bring the identical case against Gemini on listed assets if they want to take the position that some of the tokens qualify as securities and therefore they're running an unregistered securities It doesn't some of this set precedent though, So like, for example, if they go after coin Base for listing these tokens, but then Jim

and I has the exact same tokens listed. I mean, wouldn't coin Base go Wait a minute, how come you didn't go after them or vice versa, Like, I mean, isn't there press there. Yeah, they don't have to go after everybody at the same time for the same claim. Your use of the word precedent is exactly right. I mean, you would expect that if they win against coin Base,

and let's just make up a number. Let's say they're ten tokens that a federal judge declares are securities that have not been registered, then you would expect I don't want to go too far, but you would expect that other exchanges operating the United States might delist the very same tokens very quickly. Yeah, they go, shoot, they may they may be coming back to us. Yeah, I saw that it was a coin Bas's statements that were prepared.

We prepared for this disappointing development, and they talked about how they've tried over and over and over to kind of get to get kind of approval and they just got silence back. I'm curious. I know, we're seeing lots of things. We saw then Just and Son was sued. Tron was also sued for securities and mark of manipulation. Um, so I guess they're saying the TRX and BTT are

under unregistered securities. So then I guess those tokens, if they're listening on either of those exchanges within be a problem, right, Yeah, it's it's got to be, uh, something that they would be discussing in the in the compliance legal and compliance function within every exchange. These developments they're they're they're following closely. And I guess the biggest, most obvious example is XRP, you know, and and when the sec went out after ripple and uh the XRP token it did get delisted,

so um, yeah, they're paying attention. Yeah, if you just tune in, you're listening to the Mark Moss Show, I'm talking with James Murphy. You can find a mind online at Meta law Man. He is a securities attorney, and we're talking about some of the potential of what we're going on Choke point two point zero, how the government seems to be going after crypto banks and cryptocurrencies and the sec is bringing enforcement action. We're gonna cover a

lot more when we come back. We're gonna take it just a quick break, don't go away, We'll be right back. All right, Welcome back. If you're just tune in, you're listening to the Mark Moss Show. We're talking about, of course each and every week, the decentralized revolution running through some news and I'm joined by James Murphy. He's online at Meta law Man, is a securities attorney, and we're talking about some of these security issues and where that

puts the state of cryptocurrency. We talked about coin Base, we talked about Tron. Another thing I want to ask you about is the New York Attorney General. So we know in the crypto space, New York is like the most aggressive government state against cryptocurrency. They have kind of had their own New York bit license that they've had for a long time, so we know they're very restrictive.

But the New York Attorney General father the lawsuit against coucoin, so another exchange, but also said that ethereum is a security. What's going on with that's a that's a really really

good question. So that a little background. As you undoubtedly know, Bill Henman, the head of corporate finance at the SEC, years ago, said bitcoin is not a security, and athereum, if it ever was, the security is no longer a security because it had arrived at a sufficient level of decentralization where it would make sense to apply the security's laws anymore to ethereum. And that's kind of what everybody

thought was, you know, the SEC's position. But then when Gary Gensler came in, you started hearing more of like, is it is ethereum really in the clear here? So what happened was a lawyer in San Diego sued the SEC last November, asking a federal judge you'd simply declare ethereum is not a security. The SEC countered and said this case should be dismissed. There is no case or

controversy here. It's not right for any adjudication because get this, we have not decided yet whether we think Ethereum is a security is literally in a brief they file. Now, in my opinion, that's embarrassing because Ethereum, you know, its started eight years earlier, twenty fifteen, eight years, Yeah, that's right, um, and they still hadn't made up their mind. That collides with Gary Gensler's standard position that it is clear as a bell under Howie, that these are all securities. You know,

what's a security, what's not is clear. And so for the sec to say, we just haven't decided yet, and they want to backpedal away from the Henman thing. So that was embarrassing. That happened, you know, a few months ago. And then suddenly the New York Attorney General instigates an investigation of coucoin. They use an investigator in their office. So there's an investigator signed to the New York Attorney General's office and he was told go open an account

at coucoin, which doesn't have a bit license. It's an offshore exchange from the Seychelles Islands. And he managed, as a New York resident to get an account there, which is a no no. And so they told him apparently coucoin lists seven hundred tokens mark they told him go buy atherium, so he bought ethereum, sold ethereum, therefore traded

ethereum as a New York resident. And that is now the basis a basis for the lawsuit that a theory is an unregistered security and coucoin was not properly licensed in any event to deal with New York residents. But the underpinning of the case is Ethereum is a security. So one wonders if there was any communication between the SEC and the New York Attorney General to instigate an interesting timing in terms of let's go after ethereum specifically,

and by the way, coucoin. They served a subpoena on Coucoin. Coucoin did not respond. The Attorney General believes and I believe, that there's a good likelihood coucoin will not defend the case, in which case the New York ag may find that it's you know, it's got a clear fairway to get

you know, what they want. And that is a declaration from a judge, a New York State judge that ethereum is a security and boy mark that would be a really really big deal when you consider, you know that it's the second largest market cap and all of these thousands of projects built on the Ethereum network. So a couple questions I have with that. So one, you're saying that if coucoin doesn't doesn't defend that, then nobody's left

to defend Ethereum except for the Ethereum Foundation. Okay, So I mean so so people, I mean so somebody could step up to defend ethereum. Potentially, absolutely could. And this is for lawyers like me. This is fascinating because you would think the talk and the Foundation would be all

over this because the stakes are enormous. Even though the United States is just one country, it's a pretty important country when it comes to you know, the digital asset ecosystem and Ethereum in particular, and all of these thousands of projects. So far, we haven't heard anything from them, and they have a conundrum. Mark for the way is fascinating. I don't know if it's fascinating to your audience, but

this is fascinating. If the tallic and the foundations step in and defend the case, it helps the New York Attorney in general to say, well, see see what I mean is it is? Yes, it is centralized, There is control here, you know exactly, and so they've got a little bit of a conundrum here and have to make a really important decision. Back to that Henman thing, is

it possible? It seems like it would be possible that, to his point, potentially could have become decentralized enough, but the merge seems to push it way back to being centralized again. So it's is it possible that it did go from centralized to decentralized but then also then went back to being centralized because of the merge, a common enterprise driving the results of you know, their labor and because of the staking that they're doing. Okay, so I'm

not going to offer an opinion on that. What you have just said is something that is a theory that is definitely out there and being discussed. Now, I'm oh yeah, oh yeah, yeah yeah. Well, I mean you've seen staking, We've seen staking cases. That's why that's why krack And took off. You know, their staking product was declared you know, the contended by the SEC and that it was an investment contract. And and so krak And said, uh, okay, we're not going to defend it. Here's thirty million dollars

and we'll we'll stop doing this for US customers. I tweeted that out that settlement and said Krackin agreed to stop the staking staking program, and the CEO tweeted back to me and said, well, to be clear, it's only in the United States. The rest of the world will continue as before, you know, with this staking program. And so I think we're seeing a lot of that happening where businesses are making a judgment that it's no longer safe to engage in certain kinds of uh, you know,

cryptoactivities here in the United States with US citizens. If if the state of New York were to win that lawsuit, and if here and would be deemed a security by in New York, what does that mean nationally federally? I mean, oh boy, that you know, that's a that's a great question. Uh. There is a premise in the US Constitution that other states are supposed to respect the judgments of one state. I don't know if you remember this, but a few years ago there was you know, states began to change

their laws to accept and endure same sex marriage. And so this is the same issue. Is if it's okay in New y work, does Mississippi have to recognize, you know, the same sex marriage. These are very two, two very different things, but the legal concept is the same. So I'm not going to say how that would definitely work out, because of course, of course it hasn't. It hasn't spread with like the marijuana laws for example, right, so it doesn't always work out that way. But I'm curious if

that sets precedents for the SEC. But before you answer that, I gotta we're gonna take a quick break. If you're just tune in, you're listening to the Mark Moss Show. We're talking about the cryptocurrency space, that the crackdown, the choke point two point zero and what could happen with Ethereum, we're gonna come back speculate with that a little bit more. I'm gonna be right back with more talking about the SEC enforcements on crypto. Don't go away, I'll be right back,

all right, Welcome back. If you just tune in, you're listening to the Mark Moss Show, and I am joined by with James Murphy. He's an securities attorney. You can find him online on Twitter at Meta law Man. Now we're talking about before the break, about if if the state of New York deemed ethereum of security. What does that do for other states? And you're saying sometimes states kind of respect that, but maybe not always like we saw with marijuana. But I'm curious what that means then

for the SEC. You know, going back to like precedents and that sort of a thing. Does that we've seen in the past, Like obviously, as I already kind of opened up with, like New York has been very restrictive and so a lot of things you can't do in New York that you can do across the rest of the country. So if they did that, would it be sort of like always is well, new York's restrictive, you can't do a theem in New York, which you can do it to to the rest of the country. Or do

you think the SEC then probably picks that up? And I know this is all speculative, Yeah, it is. So the SEC, the New York AG is suing under a New York statue you'd called the Martin Act, and its requirements in order to prevail are are pretty easy to establish.

And so no other state has the Martin Act, So that might be a little bit of a barrier for recognition of an outcome where ethereum is declared a security, perhaps, but the top appellate court in New York has said that in New York state courts, we will look to the federal law to determine whether there's a security here, and so you will see in New York state cases they're talking about the federal case, the Supreme Court case

of Howee. So you know it will be influential perhaps and will certainly be cited by the sec in every case if if they were to prevail. Now, one thing I would say that makes this even more unusual is there is a agency in New York that is responsible or determining whether digital assets are securities and whether they could be sold to New York residents. And that's not the New York Attorney General. It's the New York Department

of Financial Services. The New York Department of Financial Services granted bit licenses to Gemini, coin Base, PayPal, Fidelity and others to permit them to trade a number of tokens in fidelities cases just too bitcoin and ethereum, but all of them we're specifically permitted by the regulator who's responsible for making this decision. They were permitted to allow New

York residents to trade ethereum on their platform. So the New York Attorney General's argument collides with this agency that's supposed to be the expert on this question. So that's a little weird and will be interesting to see if the New York Department of Financial Services enters the fray and says, hey, wait a minute, we looked at this really hard. We have the most stringent requirements for permitting trading of digital assets of any state in the United States,

for sure, and we permitted US trading of ethereum. We disagree. It'll be interesting. It'll be political because it's New York, but that's going to be interesting. Wow, that is interesting. And then it looks like, I mean, I saw you tweeted out earlier again check them out online apt meta law man you tweeted out earlier back to this kind of President's economic report, that there might be something in there that might also help out some of these crypto

security things, regardless of the label used. A crypto asset, maybe among other things, a security commodity derivative or another type of financial product. Depend on the facts and circumstances. So is that something else where now? Maybe potentially the executive branch might also disagree with that. Well, I know, well,

I don't know. I presume that Gary Gensler is unhappy with that language, and I'm a little surprised that it was allowed in there because it significantly undercuts his position, which is, all of these tokens, you know what, however many there are now on coin marketcap, I have no idea twenty three thousand or whatever. They're all securities under

my jurisdiction here at the sec except for bitcoin. And so clearly that statement it collides with that point of view and says, these digital assets, these crypto assets, could be commodities, could be securities, could be other financial instruments, or could be something else. Entirely, it was a it was a non exclusive list of the options that these

things could be sorted into. And so that feeds into an argument that most of these entities that have either issued a token or trade tokens on a platform have said, and that is, there's no clarity as to which of these our securities. And that's required under our constitutional concept of due process. You're supposed to know ahead of time what is prohibited so that you can steer around stuff that's forbidden, and I mean you can't go back and

like retroactively do things like that. Well, I mean you think about that. Well's notice you know, they said, please, you've completed here investigation, tell us which tokens are securities? And their answers no, we're not. You know, you'll see it in the complaint, I guess. And then in that case in San Diego, I mentioned, hey, judge, the sec will not tell me is ethereum of security? Please, I you know, engage with the Ethereum network. I'm now speaking

as the plane. If there somebody's got to tell me if this is illegal, if this is an unregistered security, I need a declaration. And the response was, you know what, we haven't made up our mind yet after eight years of looking at it. So that's that is definitely inconsistent

with due process in this country. The problem that I have with that is, I mean problem with the whole legal system is to your to your point, m the laws are supposed to be laws, not rules, but laws, and we're all supposed to know what those laws are in advance, so I can plan my life and you can plan your life, and we can plan our lives. Off those laws. Now I've taken the stands. I had to kind of put mister wonderful Kevin o'leriy in his place on the bitcoin desk last year at the conference

because he was like begging for these regulations. I said, hang on, hang on, hang on. Like you're Canadian, I get that. I'm American. In America, we're free. So that means that we're free to do anything that we want unless there's a law that prohibits us from doing that. So we don't ask for laws to give us permission. Everything is we're permitted to do everything unless there's a

law prohibiting us. And so back kind of to the point that you're making, if there's no law specifically prohibiting them, then then we should be free to do it. Now, I guess it gets it. You know, there's the ignorance of the laws, no excuse kind of a thing, right, So there is that. Um, I guess the problem is the gray area that's here. But yeah, it seems like when these companies like coin base are saying, look, we we've specifically asked them, they haven't. You know, they've let

us proceed with this. I mean, they got a public listing like it should have been caught at some point. And so you know, I think, like to your point, you can't really go back and retroactically change those laws. And so that's going to be a problem. It's gonna be yeah, absolutely, And look it's not hidden, it's not tricky. What needs to happen. Look at Europe, of all places.

I rarely use that phrase, look at europe An example of anything, but twenty seven countries within the European Union got together and said, all right, we need comprehensive laws about what is going to be permissible in the issuance, distribution of trading of digital assets, stable coins, etc. How the custody is going to work. You know, how people need to prove their reserves, how clients assets need to

be custodied and segregated. All of this isn't shrined in law, and they're rolling it out next month with like a year and a half of you lead time for companies to adjust their operations, stop doing things that are violative of these new laws. That's how you do, or you don't, or you don't and you just let them let them go, right, or you don't. If you're just tune in, you're listening to the Markmas Show. I'm talking with James Murphy. You

can find them on line at Meta law Man. If you want to stay up the date with what's going on in the legal space, because it is changing fast and you should be up to date on that. We covered a lot something to watch. Check him out at Meta law Man. He's a security's attorney. I should be clear about that and be safe out there. That's what we've got. Thanks so much for listening.