Former SEC Executive: Regulation & the Future of Crypto Investing

"RAISE CAPITAL LIKE A LEGEND: https://offer.fundraisecapital.co/free-ebook/"

Hey, welcome to another episode of Making Billions, I'm your host, Ryan Miller, and today I have my dear friend Gabe Benincasa. 

Gabe is the chief risk officer and General Counsel of FundBank, it's a new type of bank that is set up to help fund managers with banking, but not in the way that you might think see. Prior to that, Gabe was the first Chief Risk Officer for the US Securities and Exchange Commission.

So what does this mean? Well, it means that Gabe and his team understand funds, regulation and how you and I need to navigate this important part of alternative asset management.

Subscribe on YouTube:
https://www.youtube.com/channel/UCTOe79EXLDsROQ0z3YLnu1QQ

Connect with Ryan Miller:
Linkedin: https://www.linkedin.com/in/rcmiller1/
Instagram: https://www.instagram.com/makingbillionspodcast/
Twitter: https://twitter.com/_MakingBillons
Website: https://making-billions.com/

[THE GUEST]: Gabe Benincasa is the chief risk officer and General Counsel of FundBank

[THE HOST]: Ryan Miller is an Angel investor, former VP of Finance, CFO of an insurance company, and the founder of Fund Raise Capital,  https://www.fundraisecapital.co where his strategies helped emerging fund managers and deal syndicators to report raising over $1B foll

Transcript

Ryan Miller  

My name is Ryan Miller, and for the past 15 years, I've helped hundreds of people to raise millions of dollars for their funds and for their startups. If you're serious about raising money, launching your business or taking your life to the next level, this show will give you the answers so that you too can enjoy your pursuit of Making Billions. Let's get into it. 

Ryan Miller  

What if the same regulators who once hunted crypto could now be its greatest ally? In this explosive interview, a former SEC insider reveals the secret playbook that could turn regulatory chaos into your next billion dollar opportunity. Buckle up, this is how the game is about to change all this and more coming right now. Here we go. 

Ryan Miller  

Hey, welcome to another episode of Making Billions, I'm your host, Ryan Miller, and today I have my dear friend Gabe Benincasa. Gabe is the chief risk officer and General Counsel of FundBank, it's a new type of bank that is set up to help fund managers with banking, but not in the way that you might think see. Prior to that, Gabe was the first Chief Risk Officer for the US Securities and Exchange Commission, where he identified, monitored and mitigated key risks facing the agency and served as a key advisor on other matters such as potential systemic risks to the market. So what does this mean? Well, it means that Gabe and his team understand funds, regulation and how you and I need to navigate this important part of alternative asset management. So Gabe, welcome to the show, man.

Gabe Benincasa  

Welcome. Thank you very much, Ryan. I do want to say that, you know, I met Ryan. It was really under hardship circumstances. We were in the Cayman Islands. It was about 85 degrees, beautiful beach, beautiful water, beautiful setting, very, very, very, very difficult. Uh, place to meet. But we met. I enjoyed speaking to Ryan, and then I found out that he was not only a pleasant person to speak to, but successful, and that he runs a very successful podcast, and since I want to be like Ryan, I said I'm going to join Ryan on his podcast and full full disclosure, this is my first one, so if I don't know what I'm doing, I apologize.

Ryan Miller  

Yeah, no, you're good, man. So we're very, very fortunate to be in the top, I don't know, 2 or 3% now, and it's all because of amazing guests like you, brother. So let's, let's dive in, man. You know, you served as a chief risk officer under Chairman Clayton. What mandates did you see roll out and how did that shape capital markets in America?

Gabe Benincasa  

So, you know, my role at the SEC was newly created, and so it was very interesting. And I really had, really three roles. Chairman Clayton hired me, and what happened was, we had an Edgar breach many years earlier, and Chairman Clayton went to Congress and got this newly appointed position and so I served as the first chief first officer. But I ended up having really three roles within the commission. The first role was, really, was how to protect the commission, right, how to prevent cyber incidents, how to bubble up risks to the chairman so that we can deal with them and prevent risk, just like any other broker dealer or bank is required to have an enterprise risk function, I was creating that for governmental agency. Because of my market experience, I was also put on a what's called the market and activity risk based group at the SEC. And what that is the chairman of the SEC is a standing member of the Financial Stability Oversight Committee, and that the intent of that is to monitor risk within the United States in the financial markets, and to really try and look at what things could pose systemic risk to the financial markets. And then my third was when I got to the SEC we had two years in a row where in our financial statements we had material weaknesses. So I had a role in clearing the material weakness, beefing up the controls that they use. And so we were able to finally clear the material weakness, because the SEC reports financial statements to Congress and the public, just like similar to how reporting companies provide financial statements. So it was a very interesting job, and really enjoyed it. You know, learned a lot about how government operates. You know, the mission of the Securities and Exchange Commission is to protect investors, promote fair and orderly markets, and to promote formation of capital. And that was the mission. It's a commission that had, I think, about 5000 employees, and it's a hard working group of people that is very dedicated. One of the I was there for about a year, and covid hit, and we went into government and covid lockdown on March 9, 2020, of the roles that my office had to play was we brought up this whole, basically, plan on operating in a covid environment. You know, I think the commission did an incredible job and really have to give credit to the leadership and also to the staff in transforming, you know, one of the primary regulators, almost overnight to being almost almost all virtual. And they did a great job, I have to commend all the people that work at the commission, for it was, was not easy, and they continued their their duties.

Ryan Miller  

Yeah, that is brilliant man. Thank you for that. Not an easy job to be a regulator, for sure. And, you know, so you've moved on from that experience, and what a cool experience. I mean, chance of a lifetime for anybody to really have that behind the scenes view. And I love that you're here, because we're going to talk about a lot of the things that you've done and are doing, and really take that perspective as a key member of the SEC and, you know, speaking of that, now that you've moved on, you're kind of on the outside of the SEC looking in, right? And so you've been on the outside observing the past administration, the Gensler administration and its war on crypto. And what has been your observation now, as an outsider of that, I'm curious of what you thought, because that was a, he really drew a line in the sand on that, and some people agree, and some people don't. You know, it's not up to me that we're not, we're not going to go that deep into this. But what I do want to know is, from the outside, but you also had the inside view. What was your perspective on everything that played out from your vantage point?

Gabe Benincasa  

Sure. So you know, when I was at the SEC you know, crypto was really starting to take off. And to show you how smart I am, I went to a presentation of crypto, probably one of the largest platforms now, probably around 2016, 2017 and I'll be quite frank, I didn't understand it. I didn't invest in it. Just, you know, I, you know, I wish, I wish I had paid more attention and invested and tried to learn more about it. I started learning more about it when I was at the commission. And I'd have to say during the time period I was at the commission, you know, the SEC was probably more neutral to crypto, right? We did bring some enforcement actions, but we had Commissioner Peirce, who, you know, very thoughtful, and was probably the first regulator to come out in favor of crypto. And had a, you know, so she became a big supporter. We had Bill Hinman, who's in charge of Corp Fin at the time, who had this famous Hinman speech and they called it the Hinman letter, when it's called, when Howey Met Gary Plastic, and it talked about how something could start as a security, and then, because of how it operated, subsequently, specifically, Bitcoin and ETH would not be securities. That was a very important speech for the industry, because you go from being a security which is highly regulated to a non security. 

Gabe Benincasa  

So I would say the commission at the time period I was there, and I did overlap one year during the new administration, was probably more neutral. I believe, you know, when the new chairman came in, it really died, turned against the crypto industry. And you really have to give the crypto industry a lot of credit for the staying power. I mean, you know, they brought cases against XRP, Bitcoin, Coinbase, right? The chairman kept saying, we do not need new laws or regulations, the Securities Act have cover crypto. And really they use the 1946 Supreme Court case called the Howey case, just defines what an investment contract, which is simply, it's an investment in a common enterprise with the expectation of profits through the efforts of others and through the efforts of others, is probably the key. And really, most of the cases that were brought against crypto were brought with based on the Howey Test. The SEC also passed staff accounting bulletin 121 and now, you know, staffing, one, 121 and I wrote an article in law 360 which basically said, it's, I'm an ex, I'm also an ex CPA, I said SAB 121 was bad accounting and in bad insolvency. Bad accounting for it, because, you know, you've got those books on your shelves. If you give them to me, right, I have to return it to you, right, I'm holding it in trust for you as a bail or bailee relationship. I owe you that book, right? I can't lend that book out, I can't use it for my own purposes. I'm holding it in trust staff accounting bulletin basically said because crypto is inherently risky. Every time a bank or financial institution holds a crypto asset, it must record it as a liability. It's an obligation to return. So what does that do that attracts capital charges? So no matter how I hold it, even though I'm not reusing it right, even though I'm holding it for Ryan Miller in trust. I still have to record it as an obligation, and it attracts, basically regulatory capital, makes it more expensive. And basically that, you know, took out the major banks right or financial institutions for holding crypto assets. 

Gabe Benincasa  

The second thing they did was they, besides SAB 121, really the enforcement agency was really just going after everyone, right, it was, as Hester has been quoted numerous times as saying, it was regulation by enforcement. They passed a rule basically saying that, if you're a broker dealer in order to hold crypto, and I'm simplifying this, you basically have to have, you cannot mix your regulated security business with. The Crypto business. So you really need to have two crypto like two broker dealer licenses. And then the other thing is, all investment advisors have to hold assets in a qualified custodian and the SEC questioned what a qualified custodian is. So really, you know, for all intents and purposes, it made it really complicated the entire crypto market. It went after all the players, and it just kept passing rules and regulations, or wouldn't pass rules and regulations, but any acts that it did take were a contra to the entire crypto industry. 

Gabe Benincasa  

And then if you look also what happened during that time period, when I was at the commission, our budget was 1.9 billion. You know, in a short time period, both fiscal year ending 2025 the budget is up to 2.6 billion. And most of that was the increases were in the enforcement division. Well, if you think you can regulate the crypto market, you really should be doing it via examination, not enforcement. Having regulations through enforcement just makes it you get no guardrails, makes it very expensive. And also, I mean, you're in the, you know, in the financial markets, you raise capital. You know, no investor wants to spend 30-40% of their investment fighting the government through litigation. So what you'll do is you'll find other, you know, safe havens to do, you know, you'll still want to do the business. So you'll find friendly jurisdictions. But it was like a four year time period where, you know, it was constantly, you know, having the enforcement division. And then if you look at there's an interesting case called DEBT Box out of Utah, and you know, the government got a temporary restraining order without notice to the defendants, and the judge ultimately ended up throwing out the case, fining the SEC, and basically found that the lawyers had lied to the to the SEC. And so, you know, these kinds of things when the government comes against you, and then has these pre judgment, you know, in this case, your funds are frozen, you have a temporary restraining order, and then the judge finds, after the fact, that the lawyers lied. You know, the result of that case was, I believe, the SEC was fined 1.8 million, the case was thrown out, and the entire Utah office of the SEC ended up being closed. You know, but the these kinds of actions, you know, what people don't think of, or maybe don't understand, is when the government comes after you, and you are an individual trying to set up a company or whatever you're trying the impact on your life. You have no more assets to spend. You know, you can't pay your bills, and you know the government is supposed to, you know, be much more just than, you know, bringing actions based on false claims. And you know, the SEC tried to get the judge to say, oh, you know, we will train our employees. No, the judge said, you know, we're going to fine them. But that doesn't undo the harm that was done. You know, it's very difficult to put people back into place where they would have been had these actions not been taken. So it was, you know, I think the last four years were incredibly difficult. 

Gabe Benincasa  

Another thing and not, not the SEC I think the last four years have seen a somewhat a weaponization of the use of reputational risk to basically cause de banking, right, tobacco is out of favor, right. Examiners come in and say, you know, your tobacco lending to tobacco companies could cause reputational risk because, you know, you have a Wall Street Journal article saying about all the lending that you may lose customers as a result of that, should you be doing that business? Or if you're a crypto firm, and they come in and say, you know, you got, you got approval during the previous administration. Now they come in and say, you know, your business is too risky to really continue, and they used reputational risk as a sword to really prevent what they didn't like. What's very interesting is the OCC has now taken reputational risk out of its examination rule book and handbooks, you cannot use reputational risk. Congress, both the Senate and the House are looking to pass a bill called the firm bill, which will take reputational risk out by legislation from being used for examination and for causing basically de banking, right? It's a powerful tool because it's incredibly subjective. Right, I come into your business and say, you know, Ryan, you've got a mustache, that mustache is going to cause you to lose customers you shouldn't be doing. You know, it's, it's subjective, and it's an easy tool to use to basically get your regulated entities from not doing business that they would maybe want to do, right? You look at coal industry, tobacco, I mean, pick your industry, you know, and I could use reputational risk. Now, it doesn't mean the government seems to be trying to take reputational risk out. It doesn't mean that the registrants or the broker dealers or banks cannot, on their own, examine, you know, have certain businesses, but you don't have the government, saying you can't do this because of reputational risk, right? And that, I think that was used too much and I do agree with the regulators, the OCC and others, taking their own steps to remove that as part of the examination process. And I agree with Congress basically saying, let's codify this so we, if you have a change in administration, it's not used again, because, listen, it could be, you know, we have a change of administration. Republicans could just return the favor and basically go after industry that Democrats may be more in favor of, right? You could use reputational risk for anything, so I agree with some of the actions that are being taken.

Ryan Miller  

Yeah, because it sounds like that was a bit of a choke point in that and you know, hindsight is 20/20, and I'm sure there are many, many very talented people, and you were one of them that did and still do work at the SEC. And I never worked for a regulator, but I can just imagine that is not an easy job to do, right? And I say this jokingly, we say on this side of the fence that, you know, being a regulator is really hard, and typically they'll just tap the brakes until something flies through the windshield, is kind of the expression we use. But, you know, in all fairness, when there's a new technology or a new type of security, doesn't happen very often, and it did, and they're trying to, you know, wrap their arms around us to say, yeah, healthy regulation is good, but where's the line? And the answer is, we're we were kind of figuring that out. And so now, I think, from your perspective, and that was the question is, as now on the outside, what are you seeing? And you're saying, I'm seeing a lot of the reputation risk, and these subjective rules start to fade away, if not completely get wiped away. And that brings me to my next question now, now that the change is underway and the SEC seems to be taking more of an ally position over an adversarial one, at least in this case, where do you see this new stance showing up in the US economy?

Gabe Benincasa  

Well, let me just go over some things that actions that have taken, besides the change in reputational risk, trying to take that out from weaponization these you know, and I know more about the Securities and Exchange Commission than other regulators, and I follow them more closely, just because I have a lot of friends who work there, including the new commission. You know, the the SEC, I think, has actually worked even more quickly than I was predicting. For instance, Staff Accounting Bulletin 121, was reversed in January 2025 there's the rule requiring two broker dealers. They should frequently ask questions, which basically said, you can go to you can do the business in one broker dealer. They have a crypto task force being led by Commissioner Hester Peirce, looking at all the regulations. They said they basically suspended the cases against binance and CZ the SEC case, because, remember, there was a DOJ settlement, and I believe they settled the case also with Coinbase. So they settled a lot of cases, or actually just terminated going, you know, those cases. And so they're acting in a very, very fast pace to undo what was done. And I think this is kind of a great time for the crypto markets, I mean, you have really the regulators aligning. You have Congress, which the Senate just passed the Genius Act, which is a act for stable coins. There's a similar act in in the house, you know. So you have this environment that went almost overnight from being anti crypto to pro crypto. And you know, I was just at a crypto conference last week, and I speak to a lot of people at these conferences, and you know, it's the innovation, right, that they're coming up with. I mean, let's, let's, I mean, when I got into the industry, all right, right, security settlement, where it's called T plus five, took five days to settle. And before I got into the industry, was T7, seven days, it went from five to three, most recently, to one. You know, people don't. There's risk in that, you know, when you have five day settlement, you have five day settle, then you have three, then two, now one, but that's still settlement. You know, blockchain technology can get you to instantaneous settlement removes a lot of risk from the system, right? You don't have to wait for people to pay you. 

Gabe Benincasa  

And really, I think that the role of government is to not get in the way, but to have thoughtful regulation as to, you know, you want to prevent the fraudsters, right? There's, you know, anytime you have anything that makes money, you're going to have potential fraudsters, and that, I think that's where you have to go back to, you know, one of the three main parts of the SEC and all the regulators is really to protect the individuals, protect, you know, the investors. And you know, I think that's the purpose of regulation, but to weaponize and to try and, you know, stop businesses that you may not like, that's that's not the purpose. We're supposed to be kind of, give the playing field, give it, give a even playing field, try and prevent fraud, but, you know, not suspend the innovation and, I mean, the the innovation that's happening. And, you know, if you trade crypto, right, it's the only market that trades 24/7, I mean, you could trade it at any point in time. It's, you know, they say New York City doesn't sleep. Well, the crypto market doesn't sleep. And it's really, you have to look at as two parts, right, there's the crypto asset, right? The Bitcoin, the ease, the salon is, right, it's, you have all of, all of that, and then you have the blockchain technology, right? The blockchain technology will probably get, you know, the securities markets, instantaneous settlement at some point. And then the regulators have to worry about, you know, regulation. Regulators usually go, you know, regulate through the middle, the middleman, right? The banks, the brokers, the funds, the fund managers. And when there's a disaster, they tend to go after the middleman. If you go to pure, peer to peer settlement, you won't have that middle man to regulate, and you won't have that middle man to ultimately pay in case there's some fraud that's committed. So I think that's kind of where the market is going to have to start looking at, well, if you go to a pure peer to peer, what is the potential risk to investors and what is potential harm? You know, someone creates a fraud that and there's no one to potentially rely on, you know, we in the US, rely on the middleman to do all the KYC, AML, DSA, right? We want to make sure that the people we're dealing with are not, you know, financing terrorism, that you know they're not coming from countries on the SARS list. You know, we do those regulations by regulating the middleman or middle person. But you know, it's what do you do when you have you're now creating a technology which has the ability to take the middle person out of the that equation. So I think those are things that you know, regulators will have to look at. And again, they also, they don't want to stifle innovation, but at the same time they also want to protect the market and investors.

Ryan Miller  

Yeah, spot on back to that original mission and thank you for that. I mean that that is a brilliant insight, both from inside and the outside, on both sides of the fence and and you know now that you're in the prime of your career and you have a clear path in front of you, what difference would you say you're making in the capital markets, just to carry that original mission forward from the SEC?

Gabe Benincasa  

So you know, we've we're creating a unique bank. It took us almost two years to get OCC approval. And the reason being is we hold your money, Ryan Miller's money in trust. So a typical bank, Ryan Miller gives us $100 and I can leverage that up 10 to one, make loans to myself and others and invest that money so I could your, your 10, $100 I'm creating $1000 of value. But if you and everyone else, if you want that money, that money's not sitting in my vault. And so, you know, it's called the classic run on the bank. Well, at FundBank, we hold your money in trust. So if Ryan I Ryan Miller gives me $100 I actually have it in either a correspondent account or a treasury money market fund. The Treasury money market fund has never broken the buck and remember, in the old story the Jimmy Stewart, It's a Wonderful Life. People had to take less money. Well, if everyone in the wonderful life story wanted their money, we can get it back by the next day, because we don't use your money. So we were created with the thought of having a safer banking way of doing banking for the alternative fund industry. And the reason being is because of regulations you know years ago, capital charges for banks were simple. You had to set aside 2%, 5% now you have stress tests, liquidity coverage ratios, which basically looks and says, what is the risk, right? And the risk of holding deposits for alternative funds is riskier than holding deposits for Ryan Miller and other individuals. So because of that, the government requires a higher capital charge, right, so more money has to be set aside. So the same for the bigger banks. Basically look and say, well, since I have to set aside so much capital, I have to make X money from Ryan Miller or his firm for me to bank him, so that through throws a lot of your mid tier alternative funds to community savings banks and other smaller the regional banks, right? If you look at the regional bank failures, Silicon Valley, Silvergate, Republic, First Republic, right, they, was a classic run in the bank, and they couldn't return money. But you know, investors would have lost significant amounts of money had the government not stepped in and said, we'll guarantee you all deposits. Our bank was set up with if there's a run, we can return everything in one day and really we are set up to only, and we can only our approval from the OCC is to only handle private equity, venture capital and hedge funds, the alternative fund industry, which results in higher capital charges for the banks. So since we don't hold money in deposit, we don't have a capital charge I don't we don't have stress testing. So it's just a safer way for the alternative fund industry to maintain their operating account, or any you know, cash that they are that they need for their business use.

Ryan Miller  

So then the FundBank, banking style, if we can even call it that, but the banking style really sounds like it just helps to mitigate a lot of those higher liquidity coverage ratios that exist for fund managers, alternative asset managers, even deal syndicators, I'm assuming, just anybody where, traditionally, it made you a little uncomfortable, regardless of what that is, you have a specific I think those three sectors that you cover, and you limit it to that.

Gabe Benincasa  

Yes, we limit ourselves to those clients, as our charter says, So, you know. And it was really, like I said, we had the idea before the regional banking crisis, but then the regional banking crisis proved our theory that there's a need for an alternative way of doing banking which protects, you know, the funds of these asset managers. Because, you know, people would want to go to the safer, larger banks. But let's say, you know, Ryan Miller is just starting a brand new fund, right and he has 25-30 million that he's raised. Well, you know, you're not going to be able, you don't have your pick of any bank to use, because you're not going to throw off enough income revenue to them. So you maybe have to go to one of the smaller, you know, regional banks and so and that added risk you know to you. So you know you're being paid to invest money on people's behalf. They don't want to lose money because of who, who your service providers are, right? They don't want to lose money because you've deposited it in a bank, and now that bank has had a run on it, and you can't you know you haven't done anything, and yet, you know you haven't invested it, right? Because you think it's time to be liquid in cash. Now your money is subject to risk because you're you've put it into a deposit taking institution, which how they've managed your money, like, if you look at Silicon Valley, right? They went into 30 year treasuries, mainly at a point in time that you know interest rates were 0% or close to zero, and so when they had a run, they couldn't pay their depositors. But if Ryan was starting his new Pentium fund and had money there, he would have lost it, unless Now, luckily for the depositors, the government stepped in. But we had this theory of, why don't we create a safer alternative and our best clients are really going to be more than mid tier in the alternative fund space, but are also going to have our clients could be some of the larger like I have, you know, one client is $20 billion fund, and that reason why they'll be a client, they have their choice to go to any bank, but because they manage 20 billion but they're looking at it, saying, The way you're holding our funds, it's even safer than any, any firm that passes these stress tests, because you don't take any, you know, you don't leverage the money we entrust or, you know, put into your bank. So it's an interesting model, so we're hoping it works.

Ryan Miller  

Yeah, I love it, and it looks great, man. I'm excited for that, I'd love to pop the hood maybe a little bit down the road here after we're done recording. I'd love to sit down with you and really lock in on that. It sounds fascinating, man. And I'm so relieved, like you've opened my eyes to many things that have existed, are existing. And I'd love to, just as we round through base, maybe look about what are, what's your opinion on, where you see the markets going in the future, just as a part of the regulator team, and now you're on the financing side of things, where do you see the markets going in the future?

Gabe Benincasa  

You know, looking at, you know, the tail winds of what's going on in the regulatory world, right? Especially for crypto. You know, these are heady days for crypto. I was just at this conference last week. I mean, you look at the value of Bitcoin, ETH and others, you look at the use cases for stablecoin. I mean, this is, you know, I just think, and then just the whole the use of blockchain technology. I mean, I just think, we're it's kind of going back to when the internet was first taken off and the government didn't step in and stifle it, right? We're at a point in time where I think the government is taking a proactive approach, and I think, you know, it's not stifling the industry. So I think we're in kind of a great time period for the crypto market, I think we could be also in for a great time period for other markets, just because, you know, I've been, I was only a regulator for three years, but I've always been on the other side, and that is, I've had to live with the implementation of regulation. I'm not saying these regulations are not necessary, but it is very, very expensive to, like when we implemented Sarbanes-Oxley 404, very expensive, and having to implement, you know, compliance and risk regimes to cover reputational risk, you know, as mandated by the government, as opposed to your own requirements. Or ESG rules, which would have, you know, there's an ESG rule passed by the SEC which the new administration hasn't really put a pause on, which would have really required the amount of data that would have had to be collected and the reporting requirements, what you would have had to put an entire, you know, program just to capture data on cap on carbon emissions and report the data. You know these things, any businessman, they have a certain amount of capital to use to grow the business, and if you have to use a significant portion of your capital to really comply with onerous regulations, it ultimately stifles how much you can grow. I think the entire now, I don't think that, I'm not proposing that we get rid of all regulations, right? I think you need some, but just passing regulations which stifle the industry, especially when you do it through enforcement, you know, that really put a grip in the entire market. And I think based on the fact that we're looking at, you know, the all of the agencies, or all the regulators are looking at the over regulation that occurred and cutting back on it, I think it could unleash a really good time period. I'm not a stock predictor, but, you know, if you look at what's been happening in the crypto world, and and then you look at some of the, you know, all of a sudden you don't have to spend millions of dollars on capturing data for carbon emissions. You know, they can use that for other purposes. So I think we're in a time period where the regulatory environment is going to be very conducive for business. Now you've got to hope that there is no wars and other extraneous, you know, things that could occur outside of the markets. You know, because you never know what the impact of that. But if you look at the kind of you have, the government is really putting together an environment which is going to be conducive to growth. 

Ryan Miller  

Brilliant, so, and you're spot on. That was the first thing that I thought of as well Gabe was because I remember when I was an undergrad, and we would study stocks, and from a very neutral position in the phenomenon of how other people would go to different the FTSE or TSX or whatever, and they would list in other markets, because compliance cost is starting to be a real line item. And instead of investing it in now in compliance and legal defense and all these other things, which to some degree you know that that is a factor, you're never going to do away with it, but now you can reinvest it in growth or handing out dividends. And a lot of the times, and sometimes people in the government say, sure, we may take out a loan, but it gets paid for out of growth. And so at every level, from the private to the public markets growth matters, and if you over regulate, and whether this was over or not, over regulation or not, but just from a principles standpoint. When there's too much regulation, typically, as you said, it's very expensive for everybody, and those extra expenses need to be justified and if they're not, you're just sucking out potential growth. You're you're, you could be scaring away foreign direct investment and other things. Is just to say, nah, like, I'm not putting my money in that, that is crazy. They'll light us on fire, and light my money on fire too. So that doesn't sound like a very good investment and so when we move to step back into the position of saying, hey, we're not taking an adversarial one, and maybe they didn't even mean to in the first place. So regardless about when we're saying, hey, we want you to know we are your ally. You know we have a mission to do. We want you to grow, but we got to do it in a way that's honest, upfront, protects investors, sure we get that. I don't think anybody would disagree with that, unless you're a scumbag criminal, and you probably not listen to a show like this. But for us to say regulation is great, and neither of us are saying it's not, but we're saying hey, like it's felt around the world, especially in the US. And so with that, listening to a show called Making Billions for people who are listening to it, what perspective can you offer to those people, just to help them level up in their pursuit of Making Billions?

Gabe Benincasa  

So kind of a couple of thoughts. One is, don't be like me, that when you go to a presentation and you hear something novel, and say, I don't understand it. And, you know, and probably not pay attention to it. I mean, you know, like I said, it was early days, and I just didn't understand it, I'll be quite honest, and I just didn't think about it and, you know, it's just, it was, I went to this presentation this company was talking about Bitcoin, and I was like, what in the world is that, right? So I would say, especially if you're kind of approaching my age, be a little more open minded, especially when you're hearing like I said, I was at this conference, and I've been to a number of crypto conference. I mean, there are people creating games around, you know, crypto. I mean, it's, there's just so many things out there, and it's just, you know, so I'd say, be open minded. And then I guess the second thing is, you have to work hard. There's no, there's no shortcut, unless you inherit it. There's no shortcut, you have to work hard. I remember my grandfather, I started working at an early age, and I was. Bus boying at a restaurant, and my grandfather came in, and he saw that I was a bit embarrassing because I was cleaning the floors and everything. He took me aside, and he says, you know, never be embarrassed about getting paid for working hard, and you always want to do the best you can, no matter what your job is. And that always stuck with me, it's, it's, you know, work hard. There's no substitute. And you know, and also be interested in things like, you know, I went from accounting to law to risk, you know, you can, you can learn many different things and be interested. And so I would give that advice, expand your horizon and try and meet Ryan Miller at Cayman Islands. 

Ryan Miller  

It's always a good time, you never know where I'm going to pop up man. So, so before we wrap things up, any any ways people can reach out to you or learn more? You mentioned FundBank, is there any, any closing closing thoughts?

Gabe Benincasa  

Reach out to me through LinkedIn. LinkedIn are also the bank itself, our website but I'm very easily reach through LinkedIn. There are not many Benincasas out there, just so, you know, I've traced almost every Benincasas from a small town in Italy where I was I was born. And so, you know, I will respond on LinkedIn. They can reach me through my the bank, FundBank, which is based in Austin, but we Austin and New York. 

Ryan Miller  

All right, brilliant man. So just to, just to wrap things up and summarize everything we talked about, embrace the SEC ally position. Another one was just look for banking partners that actually helped to reduce risk. Who knew there was a style of banking that you could subscribe to? Next one was, just watch for the rise of material value in crypto, and match it with the moves of SEC and, dare I say, even institutions as well. And finally, work hard be curious, and you too will be well on your way in your pursuit of Making Billions.

Ryan Miller  

Wow, what a show, I hope you enjoyed this episode as much as I did. Now, if you haven't done so already, be sure to leave a comment and review on new ideas and guests you want me to bring on for future episodes. Plus, why don't you head over to YouTube and see extra takes while you get to know our guests even better, and make sure to come back for our next episode, where we dive even deeper into the people, the process and the perspectives of both investors and founders. Until then, my friends, stay hungry, focus on your goals and keep grinding towards your dream of Making Billions.