Still bullish on #Wyoming and #SPDI legislation despite OCC letter today. Here is why:

1. WY only state with UCC scheme tailored for digital custody. Feds don't write the UCC for states unless they've decided to get in the security interest business.
2. Wyoming still has intrastate trading exemption and no question it applies if your WY LP or LLC is banking in Wyoming.

3. Still have state constitutional protection on taxation. Will you risk custody with California bank and 13% taxes.
4. Wyoming SPDIs don't lend money. The folks who brought you the 2008 banking crisis do. Your money, your risk...

5. Do you risk working with a national bank whose regulatory functions may change on political winds? Or where the winds are designed to be intentionally good?
6. Fed rule making will take a long time once the Washington meat grinder kicks in, and that is assuming there is no US regime change.

7. Will national banks pony up the insurance premium and alter risk models to accomodate digital custody? Or will they outsource it to WY?
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