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Thanks for your note. As fellow counsel, I'm sure you get why the post had to be general. I earnestly believe that none of the clients I had did anything I th
by kemitchell 4y ago
Thanks for your note.
As fellow counsel, I'm sure you get why the post had to be general. I earnestly believe that none of the clients I had did anything I thought illegal when I represented them. But I can't ethically blog details of their compliance postures, or of their private negotiations. I can't name names, of clients or of counterparties.
I did not then and do not now perceive any great regulatory "vacuum" as concerns securities regulation. Having learned the 33 Act from law school and in practice, rather than Coin Center and blogs, I didn't see uncertainty demanding regulator clarification. I saw Coin Center and friends trying to manufacture a perception of such uncertainty. Even so, the SEC Report on Investigation on the DAO came right out and said "security", under both '33 and '34 acts, five years ago. And hammered the point that existing analysis fully applied.