Sr. Reg. Counsel @Paradigm. Posting tech law & policy, baseball, and dogs. Former @RopesGray, @UNC_Law, & @YaleBaseball. Opinions somebody’s.

Washington, DC
Joined January 2012
A big week in crypto regulation got even bigger today with the @USOCC’s release of final GENIUS implementation rules. @USComptroller and his staff deserve tremendous credit for delivering, ahead of schedule, on the promise of stablecoins while staying true to their mission.
At the @USOCC, we have worked diligently and expeditiously to deliver the GENIUS Act final rule ahead of schedule to support President Trump's vision and @SecScottBessent's leadership to grow the economy and lead the global digital currency revolution. Today marks the birth of a new industry having a federal framework for payment stablecoins in the digital age. It also brings us back to our original mission when the OCC was charged with the responsibility for organizing and administering a system of nationally chartered banks and a uniform national currency.
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There will be lessons along the way – there always are. But the best teacher remains the market and the best time for learning is now. We look forward to continuing to work with CFTC to ensure American leadership in AI, and you can read our full blog and comment: paradigm.xyz/writing/paradig…
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Lastly, we don’t need a special regime. We tried that with carbon credits, only for CFTC to conclude just last year that they “should be evaluated in the same manner as any other derivatives contract.” Same here. CFTC has a framework in place; let the market work within it.
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CFTC wants to know that the market can standardize compute across chips, location, etc. to support a tradeable contract. It’s a fair question, but not a new one. Oil varies by grade, sulfur and location as well, so the market built standard benchmarks. Compute can too.
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Same goes for the physical delivery that ties cash prices to reality: less than 1% of crude futures are delivered, but the possibility anchors the whole market. And compute is even better, since a standardized cluster provisions in minutes without shipping and storing like oil.
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Today, @paradigm and @andromeda_ai responded to @CFTC’s request for comment on compute derivatives. The market for compute is big, and only getting bigger. But unpredictable prices mean higher costs, slower builds, and a diminished AI stack. Compute derivatives fix that.
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Stefan Schropp retweeted
This week, @fund_defi, @jump_ ,@paradigm, @SolanaInstitute and @Uniswap submitted a comment letter to @USTreasury on its proposed GENIUS Act Section 3 implementation rulemaking. The GENIUS Act established important statutory protections for DeFi and developers of blockchain technology. We believe that Treasury’s final rule must respect these statutory boundaries.
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A big week for regulations kicked off yesterday, as Paradigm partnered with @fund_defi, @jump_, @SolanaInstitute, and @Uniswap to comment on Treasury’s proposed rule regarding who can issue, offer, and sell stablecoins in the US under the GENIUS Act. Congress struck a careful balance in GENIUS: rules for issuers and intermediaries, and protections for decentralized infrastructure developers and providers. Treasury’s proposal is a good start, but blurs that clear line in key places.
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Next, when the penalty for unlawful issuance is a felony, the limit should be more clearly defined than a “close temporal nexus.” Treasury should instead ask whether someone actually helped the issuer distribute, and add a safe harbor for independent secondary trading.
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And lastly, keep “issue” tied to the creation of new rights. Routine bridging shouldn’t count as a new issuance. Clear lines are the key to building with stablecoins in the U.S. We are grateful for our coalition partners, and you can read the letter and our post: paradigm.xyz/writing/paradig…
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Stefan Schropp retweeted
Replying to @KolemanStrumpf
This was more or less my reaction: the NFL seems to agree that prediction markets can offer sports contracts, but only if they regulate them like the NFL wants. Set aside whatever I think on the merits, that doesn’t seem like a helpful argument for a cert grant?
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Stefan Schropp retweeted
So 39 states and DC marched into the Supreme Court today, asking the Justices to bless their power to treat prediction markets as illegal gambling. I can’t really explain just how wrong I think this is. These are federal financial contracts, traded on a federally licensed exchange, and they belong under one regulator: the CFTC. Their entire case leans on one idea: gambling is state turf, hands off. But that skips the only question that matters, which is what these contracts actually are... and what they are is financial instruments. Contracts on inflation, interest rates, Fed moves, energy prices. Even the Ninth Circuit, one of the rulings these states lean on, agreed those sit squarely with the CFTC. Federal. And here’s where I plant the flag: sports contracts belong there too. A contract on who wins the World Cup or the Super Bowl is fully collateralized, it trades on a federally licensed exchange, it clears under federal rules, the same plumbing as every other contract on the platform. Calling it a “bet” because there’s a game involved doesn’t move it out of federal hands. The venue and the instrument decide who regulates. Not whether a state wants to call it gambling. The Third Circuit got that right. Then the part that gets me. Flip through their own brief and they admit it, over and over: it’s chaos out there. Courts split three ways. A “turf war.” “Hopelessly confused.” Twenty-plus rulings pointing every direction. It IS a mess... but think about what that proves. One financial product, on one federal exchange, and fifty states each want their own rule for it? That’s not a reason to keep fifty referees on the field. That’s the best argument I’ve seen for one. Congress already picked it. The CFTC. These are federally regulated contracts, on a federally licensed exchange, overseen by the agency Congress built for exactly this. Saying “gambling” a hundred times doesn’t change what they are. One regulator. One rulebook.
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Nothing like talking derivatives with 400 of your closest friends @FordhamCrypto! Huge thanks to @xethalis for letting me wander on to a panel, to @GKalbaugh for keeping us on track, and to the rest of this illustrious group for a lively discussion. Can't wait for next year!
The tenth and final segment of the day is Derivatives and Prediction Markets with a monster lineup of Gary, Colin, Ryne, Olivia, Stefan and Yvette.
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Stefan Schropp retweeted
people need to stop pretending that there's going to be a post-scarcity world where you guys turn off and relax. many ppl on twitter are the type who will always find something to be stressed about. you are not chillers. and you don't actually want to be! you love to work
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There’s a reason CBS (and CNN, Fox, and CNBC) are doing these partnerships: they know that peer to peer, transparent, real time markets mean better, faster, and more accurate info for their viewers. Prediction markets are for everyone, not just traders.
We’re partnering with CBS News to bring prediction market data to their midterm elections coverage.
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Meet the Gall family, founders of Sleepy Bay Salmon. They fish Prince William Sound and the Copper River flats for King, Sockeye, and Coho, with family roots in the Chenega Tribe going back thousands of years. They deliver wild Alaskan salmon straight to customers around the world. Diesel is one of the biggest costs of the season and one of the hardest to predict. Right now, diesel prices in Alaska are at an all-time high. When fuel prices rise, profits shrink, and until now there hasn't been much a small operation could do about it. So Sleepy Bay Salmon is using Kalshi to hedge Alaska diesel prices. If diesel prices climb, their trade pays out and helps offset the higher cost of fueling the boat. If prices come in lower, they lose on the trade but pay less at the pump. Order direct: sleepybaysalmon.com/
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I'll have some of my usual legal nerdery on the Sixth Circuit opinion, but does anyone actual believe this? That sports--in America and in 2026--have "only" downstream financial consequences? Forget the evidence otherwise - how do you write that with a straight face?
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I mean, what??
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