[HN Gopher] Tether is under undisclosed SEC investigation, FOIA ...
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       Tether is under undisclosed SEC investigation, FOIA blocked
        
       Author : bhouston
       Score  : 118 points
       Date   : 2021-09-24 13:26 UTC (9 hours ago)
        
 (HTM) web link (twitter.com)
 (TXT) w3m dump (twitter.com)
        
       | bhouston wrote:
       | Another article on the topic:
       | https://www.coindesk.com/policy/2021/09/24/sec-hints-at-teth...
        
       | tomhunters wrote:
       | This has been quite the issue for a long time, and I can't think
       | why the authorities are delaying their actions against Tether.
        
         | lamontcg wrote:
         | Regulators don't take actions that risk popping entire markets
         | and creating many billions of dollars of losses on the balance
         | sheets of publicly traded companies like TSLA.
         | 
         | Madoff's Ponzi was pretty obviously a Ponzi and was reported
         | for years as a Ponzi to the SEC and nothing happened until it
         | was finally popped by the market retreating in 2008 and
         | redemptions causing the Ponzi to go completely cash insolvent.
         | 
         | Tether/crypto is going to pop when it pops, and regulators will
         | then step in aggressively afterwards.
        
       | ryanlol wrote:
       | Is this not a super standard FOIA response?
        
         | ceejayoz wrote:
         | Only if there's an active law enforcement investigation the
         | FOIA request touches.
        
           | dragonwriter wrote:
           | > Only if there's an active law enforcement investigation the
           | FOIA request touches.
           | 
           | Right, but that doesn't mean that the named entity is either
           | the target or even a subject of the investigation. Because
           | the FOIA request is for all documents relating to the entity,
           | if there is even one document related to any investigation of
           | anything that mentions the named entity in any capacity, it
           | is going to be withheld for that reason.
        
           | ryanlol wrote:
           | I don't think that your comment acknowledges the reality that
           | FOIA responses are decided by RNG unless you sue.
        
         | ajkdhcb2 wrote:
         | Yes. The tweet crops out a following paragraph that says it
         | should not be taken as evidence that an investigation is
         | underway. So this is fake news.
         | 
         | You can see the full letter here:
         | https://twitter.com/CryptoWhale/status/1429819156052983816
        
           | bhouston wrote:
           | Others are now reporting this such as coin desk:
           | https://www.coindesk.com/policy/2021/09/24/sec-hints-at-
           | teth...
        
             | ajkdhcb2 wrote:
             | The same form of letter was sent a month ago, so that just
             | reflects badly on them
        
           | ceejayoz wrote:
           | "We can't give you these records because it'd interfere with
           | law enforcement activities, which may not exist" seems like
           | it'd be a pretty big loophole in FOIA if you could use it
           | that way.
        
             | kube-system wrote:
             | That's not what it's saying. They didn't say law
             | enforcement activities didn't exist, they said a violation
             | of the law may not exist.
             | 
             | In the case of literally any law enforcement activity,
             | information is collected before law enforcement can come to
             | any conclusion whether or not a law was broken.
        
               | ceejayoz wrote:
               | > they said a violation of the law may not exist
               | 
               | The claim made is "under undisclosed SEC investigation",
               | not "has already been convicted".
               | 
               | A FOIA response of this nature indicates there's some
               | level of investigation occurring, or they couldn't use
               | that reason and would have to find another reason to deny
               | it.
        
               | ajkdhcb2 wrote:
               | >A FOIA response of this nature indicates there's some
               | level of investigation occurring
               | 
               | How is that possible when it says "the Commission does
               | not disclose the existence or non-existence of an
               | investigation"?
        
               | ceejayoz wrote:
               | If there were no investigation, they couldn't legally use
               | that FOIA rejection reason. They'd have to give a
               | different reason.
        
               | [deleted]
        
               | ajkdhcb2 wrote:
               | "the Commission does not disclose the existence or non-
               | existence of an investigation" seems to make it clear
               | that law enforcement activities may not exist either. In
               | order to comply with that, they would not be able to
               | answer something like 'we do not have any records because
               | there is no investigation', so you necessarily get a
               | vague letter like this that seems like it may be
               | suggesting there is an investigation.
        
             | ryanlol wrote:
             | This is exactly how FOIA works, it's rare that you get a
             | real response without appealing at least one of these
             | denials. Very often they will not comply unless you file a
             | lawsuit to show that you're serious.
        
       | gruez wrote:
       | "tether is a fraud/ponzi" claims aside, does SEC even have
       | jurisdiction here? The SEC isn't out to protect all investors,
       | only to protect them from _securities_ fraud. I 'm skeptical
       | whether a stablecoin could even count as a security. From
       | bloomberg:
       | 
       | >The rule in the U.S. is that an "investment contract," meaning
       | "the investment of money in a common enterprise with a reasonable
       | expectation of profits to be derived from the efforts of others,"
       | is a security
       | 
       | https://www.bloomberg.com/opinion/articles/2021-09-08/lendin...
       | 
       | Under that definition, are stablecoins even securities? You buy
       | it at $1 and the best you can hope for it is that the value
       | remains at $1. There's no expectation of profits.
        
         | silverlake wrote:
         | Tether is similar to a money market fund and could be regulated
         | as such.
        
         | josefx wrote:
         | Your link only says that a "investment contract" is a security,
         | not that all securities are "investment contracts".
        
           | gruez wrote:
           | >not that all securities are "investment contracts".
           | 
           | If you search around people do seem to think that "investment
           | contracts" are "security" (eg.
           | https://www.investopedia.com/terms/h/howey-test.asp) although
           | I can't find someone saying "investment contracts iff
           | security". If that's not the case, can you list what else
           | counts as securities, and why do you think stablecoins meets
           | those definitions?
        
             | josefx wrote:
             | I am far from an expert however following
             | https://www.investopedia.com/terms/s/seact1934.asp the SEC
             | can over see over the counter securieties
             | (https://www.investopedia.com/terms/o/otc.asp) that seems
             | to cover financial contracts that derive their value from
             | an underlying asset. As far as I understand Tether is
             | backing its value with dollars and has already been in
             | trouble over lending the money it officially used to back
             | its cryptocurrency away without disclosing that to its
             | users.
        
               | gruez wrote:
               | But that argument only applies if the underlying asset is
               | a security, right? Is cash a security?
        
           | abduhl wrote:
           | Securities are defined under 15 USC 77b(a)(1)
           | 
           | (1) The term "security" means any note, stock, treasury
           | stock, security future, security-based swap, bond, debenture,
           | evidence of indebtedness, certificate of interest or
           | participation in any profit-sharing agreement, collateral-
           | trust certificate, preorganization certificate or
           | subscription, transferable share, investment contract,
           | voting-trust certificate, certificate of deposit for a
           | security, fractional undivided interest in oil, gas, or other
           | mineral rights, any put, call, straddle, option, or privilege
           | on any security, certificate of deposit, or group or index of
           | securities (including any interest therein or based on the
           | value thereof), or any put, call, straddle, option, or
           | privilege entered into on a national securities exchange
           | relating to foreign currency, or, in general, any interest or
           | instrument commonly known as a "security", or any certificate
           | of interest or participation in, temporary or interim
           | certificate for, receipt for, guarantee of, or warrant or
           | right to subscribe to or purchase, any of the foregoing.
        
         | nivertech wrote:
         | 1. USDT is not a DAR (Digital Asset Receipt) like other so
         | called "stablecoins" (i.e. it's not backed 1:1 by physical
         | USD). Instead it's a pooled investment fund claiming to keep
         | NAV (Net Asset Value) around 1 USD.
         | 
         | 2. it behaves more like an MMF (Money Market Fund)
         | 
         | 3. market participants creating and redeeming large blocks of
         | USDT are getting discount to NAV and/or exchange price.
         | 
         | Each of the points above can be interpreted as "With the
         | expectation of profit" clause in the Howey test.
         | 
         | Additionally there are many regulations about MMFs, like
         | breaking the USD peg by more than 5c, i.e. when NAV goes below
         | 95c - the fund should be terminated.
        
         | coremoff wrote:
         | Gary Gensler thinks crypto is part of their remit:
         | 
         | > The SEC has a three-part mission -- to protect investors,
         | facilitate capital formation, and maintain fair, orderly, and
         | efficient markets in between them. We focus on financial
         | stability as well. But at our core, we're about investor
         | protection.
         | 
         | > If you want to invest in a digital, scarce, speculative store
         | of value, that's fine. Good-faith actors have been speculating
         | on the value of gold and silver for thousands of years.
         | 
         | > Right now, we just don't have enough investor protection in
         | crypto. Frankly, at this time, it's more like the Wild West.
         | 
         | >This asset class is rife with fraud, scams, and abuse in
         | certain applications. There's a great deal of hype and spin
         | about how crypto assets work. In many cases, investors aren't
         | able to get rigorous, balanced, and complete information.
         | 
         | >If we don't address these issues, I worry a lot of people will
         | be hurt.
         | 
         | (taken from one of Matt Levine's emails talking about the SEC
         | and Crypto)
        
         | BitwiseFool wrote:
         | >"does SEC even have jurisdiction here?"
         | 
         | In a Machiavellian way, I've come to realize that the Standard
         | Operating Procedure for government/bureaus is that when faced
         | with ambiguity about jurisdiction it's better to ask for
         | forgiveness than permission. In practical terms, who's stopping
         | them?
        
           | user-the-name wrote:
           | > In practical terms, who's stopping them?
           | 
           | Courts? Pretty basic principle of how democratic systems are
           | built.
        
             | Kranar wrote:
             | Not so, at least in the U.S. and Canada. As per "Chevron
             | deference" the courts are bound to defer to regulatory
             | agencies over how to interpret ambiguous areas of the law:
             | 
             | https://en.wikipedia.org/wiki/Chevron_U.S.A.,_Inc._v._Natur
             | a....
        
           | qeternity wrote:
           | > when faced with ambiguity about jurisdiction it's better to
           | ask for forgiveness than permission
           | 
           | Genuinely curious what has given you that impression.
           | Regulators have been insanely slow to act on crypto (and
           | there's no regulatory overreach here).
           | 
           | In general, it's a meme that regulators are slow to act and
           | often without any teeth.
        
         | mannykannot wrote:
         | > Under that definition, are stablecoins even securities? You
         | buy it at $1 and the best you can hope for it is that the value
         | remains at $1. There's no expectation of profits.
         | 
         | True, as far as I know, but this is not the case for Bitcoin.
         | If, as has been alleged, Tether has been used to fraudulently
         | manipulate Bitcoin prices, the question becomes one of whether
         | Bitcoin falls under the remit of the SEC.
        
           | trident5000 wrote:
           | This rumor has been debunked. We had a glance at tether
           | financials when the whole bitfinex IOU swap happened. Tether
           | is backed 1:1 but they have reserves in investments, claimed
           | to be mainly A2. Thats what people had a problem with.
           | 
           | If thats a problem ok, but insurance companies invest their
           | payout holdings in commercial paper as well and theres not
           | much of a public outcry.
        
             | user-the-name wrote:
             | Tether _claims_ to be backed 1:1, but _claims_ to have
             | reserves in investments, which are, yes, claimed to be
             | mainly A2.
             | 
             | We have zero evidence of any of these being true other than
             | the word of Tether executives, who have lied about their
             | backing before, as determined in court.
             | 
             | (Also, this is only the latest claim in a series of gradual
             | backtrackings on earlier, fraudulent claims about their
             | reserves.)
        
               | trident5000 wrote:
               | Their financials were shown to the new york attorney
               | generals office who then reached a conclusion and
               | settlement which you can read. What they did wrong was
               | issue an IOU to bitfinex which was hacked. Not run up a
               | 10:1 reserve market pumping scheme like tin foil hat
               | wearers claim. Theres lots to say about tether thats bad,
               | but thats not it.
        
               | user-the-name wrote:
               | ...and lied about it. That part is pretty important.
               | 
               | (And you are severely understating what they did, as
               | well.)
        
               | jcranmer wrote:
               | It is worth pointing out that the conclusion and the
               | settlement covers a time _before_ Tether did a massive
               | 10x growth in total circulating currency, and the
               | reserves accounting of the latter phases are not well-
               | established. By Tether 's own (very sparse, compared to
               | standards in the financial industry) reporting, ~75% of
               | its reserves are "commercial paper," without any further
               | identification of what commercial paper its holding. And
               | if true, this would make it one of the largest holders of
               | commercial paper, and yet no one has come forward to
               | corroborate transacting commercial paper with Tether.
               | 
               | Since there's no information on what it's holding, it has
               | fueled suspicion that a lot of the holdings are in things
               | like cryptocurrency scam-like companies, or as another
               | theory holds, invested in Evergrande property notes.
               | Tether hasn't released any information that would favor
               | or disfavor these hypotheses.
        
         | [deleted]
        
         | bohadi wrote:
         | You're absolutely right. Gensler has cited the Howey test
         | inconsistently. Well, under that definition, stablecoins are
         | not securities. There's no expectation of profits.
         | 
         | I expect future battlelines being drawn around decentralized
         | stablecoins. Tether is private and carries SPOF risk.
         | 
         | [1] https://www.investopedia.com/terms/h/howey-test.asp
        
           | qeternity wrote:
           | > You're absolutely right. Gensler has cited the Howey test
           | inconsistently. Well, under that definition, stablecoins are
           | not securities. There's no expectation of profits.
           | 
           | Uhh, the Howey test is not a magical test to determine what a
           | security is. For many things, Tether included, we have very
           | simple rules based tests.
           | 
           | The Howey test is to determine things that might not qualify
           | under letter-of-the-law but absolutely are investment
           | contracts in substance.
           | 
           | Crypto (stable coins included) runs afoul of both types of
           | definitions pretty much universally.
        
         | blitzar wrote:
         | Reminder: #Tether is registered and regulated under FinCEN as
         | all the centralised competitors. Strict KYC/AML is applied to
         | all Tether direct users, as the other main issuers are doing.
         | Less regulated is just FUD. Ask yourself who benefits from
         | spreading such misinformation?
         | 
         | -- Paolo Ardoino (@paoloardoino) December 30, 2020
         | 
         | Paolo Ardoino, Tether's chief technology officer.
         | 
         | It doesnt matter who is/isnt regulating you, once you are
         | claiming to be a regulated instrument publicly to people in the
         | US then the SEC have all the jursidiction they need.
        
           | FDSGSG wrote:
           | >It doesnt matter who is/isnt regulating you, once you are
           | claiming to be a regulated instrument publicly to people in
           | the US then the SEC have all the jursidiction they need.
           | 
           | The SEC does not have unlimited jurisdiction over things
           | which are publicly claiming to be regulated instruments to
           | people in the US.
           | 
           | The SEC regulates securities. According to the "Howey test"
           | provided to us by the US supreme court it appears that Tether
           | is not a security, therefore it does not fall under the
           | jurisdiction of the SEC.
        
         | ARandumGuy wrote:
         | My understanding is that, in the US at least, "securities" is a
         | broad category that applies to any financial asset or product
         | that isn't regulated under other rules. However, this is pretty
         | uncharted territory, and until there's some judicial precedent,
         | it's impossible to be completely sure.
        
           | ryanlol wrote:
           | > My understanding is that, in the US at least, "securities"
           | is a broad category that applies to any financial asset or
           | product that isn't regulated under other rules
           | 
           | This is incorrect. Many financial assets are not securities,
           | tether being a particularly good example.
        
         | mywittyname wrote:
         | Well, the other half of Securities & Exchange is exchange.
         | Tether is owned and controlled by Bitfinex, who does claim to
         | be a cryptocurrency exchange.
        
       | Havoc wrote:
       | Honestly I'd be more surprised if they weren't.
       | 
       | Wouldn't mind if the SEC takes tether down a notch...they're a
       | risk to the entire crypto ecosystem
        
       | trident5000 wrote:
       | If tether went belly up what would happen is everyone would sell
       | their tether for BTC and other cryptos (whatever they can get
       | into) and you would have the largest squeeze of all time. We
       | actually witnessed this during the tether freak out saga a couple
       | years ago where BTC on the bitfinex exchange was priced like 10
       | or 15% higher than the rest of the market. I wouldnt mind just
       | getting it over with. Then we could get that over with an just
       | have USD trading. But what most likely will happen is they will
       | just be forced to comply with certain rules.
        
         | postalrat wrote:
         | "If tether went belly up what would happen is everyone would
         | sell their tether for BTC"
         | 
         | What do you mean by "tether went belly up"? Even when it's
         | "belly up" it still has value to trade for BTC?
        
           | quickthrowman wrote:
           | Who would be buying the tether? Every trade on an exchange
           | has two sides, who is going to buy USDT that isn't worth
           | anything?
           | 
           | For example, the $449 strike SPY call expiring in 27 minutes
           | has a bid of 0.00 and an ask of 0.02, meaning nobody will buy
           | if you try to sell the call, but a market maker will sell you
           | one for 0.02. If tether was worthless, the same situation
           | would happen, people would be willing to buy for 0.00 and
           | sell for a bit more than 0.00
        
         | chollida1 wrote:
         | > If tether went belly up what would happen is everyone would
         | sell their tether for BTC and other cryptos (whatever they can
         | get into) and you would have the largest squeeze of all time
         | 
         | What squeeze could there possibly be? No one is forced to
         | deliver anything here so there is absolutely nothing to be
         | squeezed.
         | 
         | now you may get some people willing to buy tether at 10 cents
         | on the dollar but that would only continue to force down the
         | price of tether as you exhaust the very small amount of tether
         | buyers.
         | 
         | Who do you see being squeezed here?
        
         | quickthrowman wrote:
         | > If tether went belly up what would happen is everyone would
         | sell their tether for BTC and other cryptos (whatever they can
         | get into) and you would have the largest squeeze of all time.
         | 
         | I'd like to know who you think would be buying Tether if it was
         | collapsing, you can't sell if there's no bid!
        
         | rcohngru wrote:
         | The thought process here is that if you're stuck holding tether
         | if/when it collapses, you can just sell for a crypto that
         | hasn't collapsed. But who in their right minds would want to
         | trade something of value for something that has just been shown
         | to be worth $0?
        
           | trident5000 wrote:
           | For exchanges that use USDT, exchanging for crypto is your
           | only immediate option.
        
             | rcohngru wrote:
             | Right, but who would want to be on the other side of that
             | trade? You're telling me that if I have something worth $0
             | and you have something of value, you'd want to make that
             | trade with me?
        
               | trident5000 wrote:
               | Exactly, thats what causes a squeeze/absurd drive up in
               | price. Its why I dont hold tether.
        
         | kangnkodos wrote:
         | If Tether's USDT went belly up, there would be a loss of
         | confidence in the Coinbase exchange, a run on the market, and a
         | collapse in the price of Bitcoin.
         | 
         | Right now, everyone who has an account at Coinbase believes
         | that if they liquidated their Bitcoin tomorrow, they would
         | eventually get genuine US Dollars equal to the amount of money
         | in their account. Under normal operating conditions, this is
         | true. But if Tether's USDT goes down in price significantly,
         | all bets are off.
         | 
         | Under normal operating conditions, when a client sells Bitcoin
         | in their Coinbase account, Coinbase trades Bitcoin for Tether's
         | USDT, the USDT sits in the user's account for a while, and
         | eventually the user get US Dollars.
         | 
         | Where do the US Dollars come from?
         | 
         | Tether has a reserve of some US Dollars, and other non-crypto
         | assets that can be quickly traded for US Dollars. Let's just
         | consider this whole bucket as US Dollar reserves in order to
         | simplify this discussion. The important thing to remember is
         | that Tether's US Dollar reserves are only a small fraction of
         | all outstanding Tethers.
         | 
         | Also, Tether is constantly gathering more US Dollars. On an
         | average day, Tether receives more US Dollars than go out.
         | 
         | If for some reason, everyone decided at the same time that a
         | USDT was worth less that one US Dollar and the price continued
         | to drop over time, everything would change. In this dropping
         | USDT price scenario, anyone who held USDT would go to Tether at
         | the same time and ask for their US Dollars back.
         | 
         | Tether would have a few options at this point, but one option
         | they would not have is giving everyone their US Dollars back.
         | Remember that Tether has limited US Dollar reserves. Assuming
         | they kept trying to refund every request with a full US Dollar,
         | they would blow through their reserve and hang up a closed sign
         | on their window. Tether doesn't have any bankruptcy insurance,
         | and there isn't a government that is likely to bail Tether out.
         | They're not too big to fail.
         | 
         | Oh, Tether would try some tricks to slow down the process. But
         | they may not be able to stop the run on the bank/exchange.
         | 
         | So now, let's assume Tether is worth zero. What happens to
         | Coinbase and it's clients?
         | 
         | Buying Bitcoin would not be a huge problem. Coinbase might have
         | to change their procedures, but they could still find people
         | willing to accept US Dollars in return for Bitcoin.
         | 
         | The trouble would be selling Bitcoin. On a normal day, they
         | just trade Bitcoin for USDT, and if necessary, go to Tether and
         | trade the USDT for US Dollars. But if the normal system doesn't
         | work because a USDT is worth zero, Coinbase would have trouble
         | selling Bitcoin in a timely manner.
         | 
         | People would flood Twitter complaining that they can't get
         | their money out of Bitcoin through Coinbase, and this might
         | trigger a second run. All Coinbase customers might lose
         | confidence at the same time, and try to sell their Bitcoin in
         | their Coinbase accounts at the same time. The price of Bitcoin
         | would crash. Perhaps people would not trust exchanges such as
         | Coinbase for a long time after, and prices might stay low for a
         | long time.
         | 
         | This is all just a wild guess. What do I know?
        
         | randomopining wrote:
         | Wouldn't it cause holders to instantly have part of their
         | portfolio be worthless, which would cause them to have to sell
         | liquid BTC etc to cover their positions. Which would depress
         | the price of btc/eth a lot?
        
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       (page generated 2021-09-24 23:02 UTC)