The combination of a hyper-complicated regulatory system, a remarkably expansive and aggressive rulemaking agenda and a penalty system that rejects proportionality ultimately serves as a tax on society, on businesses, on their owners and on consumers.

The issue of proportionality as to penalties is serious. In one case (see ), large fines were levied for using new messaging technology for which there were no developed recordkeeping methodologies. Without any tie between those…

While digital asset legislation and regulation is overdue, is this the right moment? Financial legislation adopted in the wake of failure tends to be reactive, as no one wants the blame for the failure.

With digital assets having already lost two-thirds of their value without a whimper from the larger financial system, it is hard to make the case that - after a crash that did not make much of a broader bang - they pose an unreasonable risk to financial stability.

As to climate risk, the FRB would be more accurate if it simply said it has no clue, and is trying to develop some basis for climate risk-related predictions. Nothing in the report suggests that the FRB has any "material"…

One disadvantage of the current administration's generally hostile approach to the use of digital assets is that it may result in moving away from highly regulated financial institutions (where it could be reasonably monitored) to less-regulated firms.