Coinbase has departed from its conservative roots and begun adding many more coins. Dan Romero, vice president of Coinbase, explains how its listing process works, how it tries to prevent insider trading, and why it’s listed coins that had ICOs, even though the SEC has indicated all coins that were offered in ICOs at least started off as securities. He also talks about Coinbase’s international expansion, how regulations around crypto differ in Japan vs. the U.S., and the importance of banking relationships for crypto companies. Plus, we dive into how Coinbase plans to weather competition on multiple fronts — from Robinhood, Square and Binance on its consumer side, and from Fidelity and Bakkt on the institutional side — how its decentralized projects could affect its current revenues and how it is staffing now for any future hype cycles that could increase crypto adoption by an order of magnitude.
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Episode links:
Coinbase: https://www.coinbase.com/
Coinbase Listing: https://listing.coinbase.com
Digital Asset Framework: https://listing.coinbase.com
Coinbase’s new listing process: https://blog.coinbase.com/new-asset-listing-process-a83ef296a0f3
Announcement that they were exploring adding Cardano, Basica Attention Token, Stellar Lumens, Zcash and 0x: https://blog.coinbase.com/coinbase-is-exploring-cardano-basic-attention-token-stellar-zcash-and-0x-9e44f0eb823f
News announced after we recorded: Coinbase considering offering 31 new assets: https://blog.coinbase.com/coinbase-continues-to-explore-support-for-new-digital-assets-92ba4ab7f465
Interview with Will Warren of decentralized exchange 0x: http://unchainedpodcast.co/will-warren-of-0x-on-why-decentralized-exchanges-are-the-future
Coinbase investigates insider trading of Bitcoin Cash: http://fortune.com/2017/12/20/coinbase-bitcoin-insider-trading/
Coinbase finds no insider trading of Bitcoin Cash: http://fortune.com/2018/07/24/coinbase-insider-trading/
Unchained episode on Coinbase/IRS case: http://unchainedpodcast.co/is-the-irs-justified-in-demanding-information-on-millions-of-bitcoin-users
Link to Alistair Milne’s tracking of total Coinbase customer base: https://docs.google.com/spreadsheets/d/1NgvD2kFT69mSXuJPzPDu-Qv9SS1ck2iPt6Kw9a55z0k/edit#gid=0
Coinbase adding USDC: https://blog.coinbase.com/coinbase-and-circle-announce-the-launch-of-usdc-a-digital-dollar-2cd6548d237
Unchained episode with Circle: http://unchainedpodcast.co/circles-jeremy-allaire-and-sean-neville-on-why-crypto-will-be-bigger-than-the-web-ep71
Unchained episode with Rune Christensen of MakerDAO: http://unchainedpodcast.co/why-its-so-hard-to-keep-stablecoins-stable
Unconfirmed episode with Rune: http://unconfirmed.libsyn.com/rune-christensen-of-makerdao-on-its-15-million-from-andreessen-horowitz-ep039
Transcript:
Laura Shin:
Hi, everyone. Laura here. A quick note before we dive into today’s show. The one-hundredth episode of Unchained is coming up. I know, hard to believe. Side note for those of you keeping score at home, included in the count were special recordings from conferences. For the one-hundredth episode, I want to hear from you. Send me a voicemail or an audio recording telling us your name, where you’re from, and anything else you’d like to say related to the show, whether it’s what you’ve learned from Unchained, your favorite moment or guest, how you listen, or whatever else you’d like to say.
Then, finish it off with a prediction about what will happen in the crypto space in 2019. You can easily record a message on the Voice Memos app of your Smartphone or using an app on your computer. If you do that, email your file to [email protected], with the subject line “100.” Again, that email address is [email protected], and use the subject line “100.” Or you can call and leave me a voice message at 917-675-4882. That’s a US number, so my international fans should use country code 1. Again, that number is 917-675-4882.
As a reminder, tell us your name, where you’re from, and whatever you’d like to say about the show, and then round it out with a crypto prediction for 2019. The deadline for these submissions is Thursday, December 20. I look forward to having you guys take over the show.
Hi, everyone, welcome to Unchained, your no-hype resource for all things crypto. I’m your host, Laura Shin. If you’ve been enjoying Unchained, pop onto iTunes to give us a top rating or review. That helps other listeners find the show.
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Laura Shin:
My guest today is Dan Romero, vice president at Coinbase. Welcome, Dan.
Dan Romero:
Thanks for having me, Laura.
Laura Shin:
You’ve been at Coinbase almost since the beginning. What was your background, and what have you done at Coinbase over the years?
Dan Romero:
So, I started my career in management consulting. I was in Boston, and then moved out to the Bay Area five years ago, spent about a year at a SaaS startup, but I ultimately fell down the Bitcoin rabbit hole, just being here in San Francisco, and made the move over to Coinbase in 2014. I started on the business development team, and had a bunch of different roles here, especially on the ops side of the house, and more recently have been working on the consumer product and business unit, Coinbase.com and the mobile apps, and then the international side of our business.
Laura Shin:
You’ve talked about how you started off in business development. What exactly were you doing, and if you just talk a little bit over how your duties changed over time, and reflect on how that, I guess, comported with the different priorities of Coinbase over its history?
Dan Romero:
Yeah, so, when I started at the company, one of the first projects I worked on was launching Coinbase in Europe, and spent the summer of 2014 hopping around to a bunch of different countries, meeting with dozens of different banks, and ultimately found a banking partner that we still work with today based in Estonia. And that was an eye-opening experience for me, because naturally you’d go into these meetings with banks, and the question would be, “What is Bitcoin?” Some people hadn’t heard of Bitcoin to begin with, or, you know, “What is the blockchain, how does it work?”
I think there were a lot of preconceived notions, this is a technology only used for money laundering and kind of nefarious activities, and coming off the kind of Silk Road and Mt. Gox news in 2014, it was definitely like pushing a snowball uphill. I think things have changed a bit over the last four or five years, and we’re getting to a place now where, you know, people realize the power of Bitcoin and cryptocurrency. And I think banks and folks in the traditional financial world are far more informed than they were when I first started out.
But I still think that there are some really challenging problems that the cryptocurrency industry as a whole needs to solve. So, one, fundamentally, going back to the point about access, in order to have easy on-ramps into crypto, you still have to have strong partnerships with traditional financial institutions, and they are under, as you can imagine, post-financial crisis, a bunch of different new regulations and a lot of kind of pressure to kind of be very selective with types of customers they onboard. So, I think that’s made it especially challenging for cryptocurrency, which in some regard is there as a kind of decentralization of the existing financial system.
But the irony here is that in order to make that happen, you need to have kind of bridges between Finance 1.0 and Finance 2.0. And so, I think Coinbase is committed to kind of working closely with regulators and the traditional financial institutions because we realize from a practical standpoint that that’s how you actually get more people with access to cryptocurrency.
Laura Shin:
And so, why is it that crypto startups have such a hard time maintaining their banking relationships? What are the actual problems or kind of, yeah, what are the difficulties, I guess, that banks have with servicing crypto startups?
Dan Romero:
I think there are two main reasons cryptocurrency companies run into banking challenges. So, the first is a little bit more structural and systemic within the banking world. There’s a kind of initiative in the US in 2013, Operation Choke Point. You can kind of look it up on Wikipedia, but there was a lot of pressure to kind of de-bank money service businesses, and under current regulations, cryptocurrency companies are money service businesses, at least here in the US. And so, a lot of kind of, anything that fell in that category, banks decided that they weren’t going to just be banking those customers anymore.
I think that’s since changed, which is, I think, a good thing, generally, for the industry. But I think the second thing, and this is far more on the cryptocurrency companies and the industry as a whole, is I don’t think there have been a ton of reputable actors to date. I think that that number has increased, especially in the last year, but if you think of some of the early names in crypto, generally kind of associated with the kind of Silk Road/Mt. Gox type stuff, I think that that reputation was set pretty early, and it’s taken us almost four or five years to unwind that.
I think Coinbase has been pretty committed. There are other companies here in the US, and especially some companies that have recently entered this space, I think, that help add credibility to it. But I think banking generally is very driven by reputation, and so, it takes a very long time to build a good reputation, and it’s very easy to kind of quickly flip that to having a bad reputation.
Laura Shin:
And so, talk a little bit more about that latest role. You are, I guess, helping Coinbase expand internationally. How does that fit within the company’s overall strategy for this next phase of its development?
Dan Romero:
Yeah, so, we think that access to cryptocurrency globally is still largely an unsolved problem. If you’re talking about customers or users in the US or in Europe, there are pretty good on-ramps. Coinbase is one of those, but when you start to think about, you know, people in emerging markets, it’s actually still quite difficult to get their first Bitcoin or cryptocurrency. And so, I think for us, we’re really focused on expanding the number of people and countries that have easy on-ramps into crypto, specifically with local currency.
So, I think there are great options globally to trade crypto once you already have it, but trying to get into crypto to start, that’s a really challenging problem.
Laura Shin:
I know that, I think Japan is one of the first areas where you’re going to focus, and I think Japan probably is one of the prime examples of how, I guess, governmental, and also banking attitudes toward the crypto space have changed, because obviously Bitcoin is a national currency there. What would you say are the differences in launching or running a crypto startup in Japan versus the US?
Dan Romero:
Well, we’re not up and running yet, so I can’t speak entirely from experience, but having spent the last year engaging with regulators there, and we now kind of have a small office and a team, I think Japan is an interesting market, because it’s one of the first, I actually think it is the first country that has a federal or kind of national-level license. And so, in the US, we’re far more of a state-regulated business today.
So, for example, we have the New York State BitLicense, but that specifically applies to the customers in the state of New York, whereas in Japan, the Japanese FSA has a similar-type license, but it applies to everyone in Japan. So, that’s kind of an interesting new dynamic that we’re navigating. I think that the other thing to think about Japan is that they’ve had Bitcoin exchanges there for quite a long time. Mt. Gox was located there, and I think today there are several large ones, but security has actually been a challenging thing.
And I don’t think it has anything to do specifically with Japanese companies, but it just so happens that there have been a few high-profile hacks. So, I think when you look at some of the guidance that’s come out from the FSA, they’re very focused on security. I think fortunately for Coinbase, that’s in our sweet spot. “Most trusted and easy to use” has always been our kind of guiding light, and core component to being most trusted is having great security.
Laura Shin:
Yeah, I could imagine. I know this whole money-transmitter thing has been, I’m just going to say it, I think it’s been an albatross a lot, for a lot of these crypto startups. And I know that even you guys, you know, who are extremely well-capitalized, don’t have licenses yet in all 50 states. So, I think there could be something that the US could glean from the differences with Japan. But I actually want to switch to talking about the listing of coins on Coinbase, which was sort of, actually the main impetus behind this interview.
Previously, Coinbase took a pretty conservative approach to adding new coins. For a while, it was only Bitcoin, then you actually added Ethereum and Litecoin, and then eventually you offered the forks of those coins, you know, Bitcoin Cash and Ethereum Classic. But recently, it appears that Coinbase is loosening that conservative approach to add coins that are either more experimental or less proven than the previous ones. Why is that?
Dan Romero:
Yeah, so, I wouldn’t say “loosening.” I think what we’re doing is revising kind of our approach, based on customer feedback and kind of new developments that we think have happened within the regulatory space. We’ve taken a posture, from day one, that, you know, the Howey Test applies to kind of any financial asset. And so, when we’ve been thinking about adding new cryptocurrencies, we’ve always taken that under consideration. And I think our recent shift in strategy is really driven by customers.
And so, when we asked customers the number-one thing that they want from us is adding new cryptocurrencies to the platform. And so, I think our plans are now to list as many cryptocurrencies as possible within kind of compliant and legal constraints, and then also having information and quality signals easily available for customers, so that they can kind of determine if a cryptocurrency makes sense for them. And I think that this is pretty similar, if you think about a traditional stock brokerage or exchange.
They list everything above a certain quality bar, and ultimately, investors and kind of individuals make decisions on what to invest. They’re less curated and editorialized. And so, for us, I think creating a platform where everything has that certain level of quality, and obviously follows the compliance and legal regulations per jurisdiction is a core component to our strategy.
Laura Shin:
And what is the process for listing new coins? You have that application page where a token issuer can apply. So, once they do that, what happens inside Coinbase?
Dan Romero:
Yeah. So, a few years ago, we published a kind of a digital asset framework, and that was our first kind of attempt at codifying how we think about adding new cryptocurrencies to the platform. Listing.Coinbase.com is a kind of a revision and update of that, and I think for us, we realize that there’s been a proliferation of cryptocurrencies, many of which have kind of active development teams and folks who are keen to kind of get on the Coinbase platform.
So, that was an attempt to make it easier for those teams and kind of projects to be able to reach out to us directly and provide us with all the information that we use under consideration when we’re thinking about adding to the platform. Internally, our process kind of has a series of checks and balances. So, we have the listing team, which kind of collects that information, puts it together in kind of an internal document format. Then they are able to share that with the relevant parties on our legal team, on our compliance team, and on our security team.
And if kind of any team is going to veto an asset, then that kind of would stop it there. Assuming everything is cleared at that level, that kind of moves up to a senior group of folks who then kind of approve to make sure that the process was followed to our standard, and then we go ahead and list it. And so, I think we’ve built a set of kind of processes internally so that we can ensure that we can keep that quality bar, and then of course the legal and compliance regulations per jurisdiction.
Laura Shin:
And when you said that that initial check goes to the regulation, compliance, and security teams, what are they looking for?
Dan Romero:
Each team’s going to have a different lens by which they approach. Legal obviously has the legal components, and you know, the frameworks each country has relative to whether something might be a security or not. I think compliance, looking to kind of see, okay, is the purpose of a given cryptocurrency maybe not something that we’d be okay with from a compliance standpoint on the platform, and we have a lot of considerations to think about there. And then security, I think that generally is where I start.
That’s the most important, in that we’ve built a brand around being trusted and easy to use, and as I said before, the part of trust is keeping customer cryptocurrency safe. And so, adding an asset that potentially has security issues would be very problematic. So, I think we take it pretty seriously in terms of, you know, to do the auditing from a security standpoint.
Laura Shin:
So, then, ultimately, who decides? So, I understand there’s input from all these different teams, but then, how large is this committee of who decides, and then who knows before an announcement is made which new coins will be listed, and how many people is that?
Dan Romero:
Yeah. So, it’s a limited number of people who have access to this whole process, and they’re all vetted and under a set of kind of trading guidelines internally. I think the number of people, I don’t know if we’ve ever publicly disclosed that, but I’ll say it’s more than one and less than 50, how about that, in terms of the final deciding number of people. But I think…
Laura Shin:
Forty-eight different options there.
Dan Romero:
Exactly, but we’re keen on making sure that we have representation from each part of the business, and the mix of people who can fundamentally do the auditing of a smart contract, for example, and then, obviously people who can kind of think about risk and regulatory at a more holistic level. So, really trying to kind of do the kind of best job we can in diligencing anything we add to our platform.
Laura Shin:
So, as you I’m sure know where this is going, Coinbase has previously come under criticism that employees have engaged in insider trading, most famously around the Bitcoin Cash launch in Coinbase. So, what are your insider trading policies, and how do you enforce them, because if, just thinking, you know, about how somebody could do this, I just feel like there’s so many ways in which an employee could trade a coin without Coinbase knowing, especially since, like, before launching it on Coinbase, they would literally have to obtain those coins on a platform that’s not Coinbase, right? So, how would you even know?
Dan Romero:
I think it’s a challenging problem, but no different than any publicly-traded company or any other industry. First and foremost, you fundamentally have to hire good people that you can operate from a principle of trust with, right? I don’t think it’s productive to hire people that would, if you set a set of policies that say “You can’t trade X,” or “You can’t do Y,” they would go around that policy and do that on the back side. Obviously, if we ever found any wrong-doing, we would take immediate action, and then to the degree that there was potential for criminal, then that’s a separate process.
But I think that first principle of, this problem exists universally, in any kind of industry, there’s always kind of proprietary or confidential information that could potentially be misused, and you know, no one talks about public companies in terms of the average person, this is an issue, because it’s existed for a while. There are a set of norms, and if people violate those norms, there are repercussions. And so, for us, I think we’ve taken a pretty aggressive approach internally, in terms of what controls we have, and I don’t think we’ve publicly disclosed every aspect of that, but I think it’s something that we feel confident is trust-building, especially with our partners on the regulatory side, and our bank partners.
And ultimately, I think it comes down to how customers view us, right? So, ultimately, if customers don’t trust us, then that’s probably not going to be effective. I think we’ve done a pretty good job. We could probably continue to do better, especially on the communication side to customers, but it’s something we take really seriously.
Laura Shin:
And just to go back to how you do enforce or investigate this type of behavior, how would you do that?
Dan Romero:
I don’t know if I can get into the specifics there, other than we’d take, you know, investigation of a potential claim around something that would violate our employee trading policies incredibly seriously, and to the degree that there were kind of any findings from that, we would take whatever appropriate action necessary.
Laura Shin:
And so, as for the Bitcoin Cash listing, there are various charts on the internet that make it look like, certainly, the volumes in the Bitcoin Cash price actually did go up in the hours before the announcement, you know, beyond kind of where it had been trading before. And yet, I know that two independent law firms concluded that no insider trading had actually taken place. So, what did they find? Like, what was the explanation for that correlation?
Dan Romero:
Yeah, it’s something that I can’t get into the specifics, other than what we’ve publicly posted. I can say, though, that we take this stuff really, really seriously, and we view it as kind of a critical component to our brand that our customers trust us. And so, that was one of the reasons, I think, we put out the public post to begin with, but yeah, I think…that’s all I can talk about on that specific issue.
Laura Shin:
Okay. So, to go back to the listings, the listing web site asks the token issuer, the person or team applying to have their token listed if the token has passed legal and security review. However, you also note that a factor in determining whether or not you’ll list a coin is whether or not it would be considered a security coin, according to Coinbase’s security’s law framework. So, how much of that review do you leave up to the issuer, and then how much does Coinbase put into its own legal review?
Dan Romero:
Ultimately, that’s our assessment, and we welcome and often solicit the input of external parties on that, both outside counsel and then to the degree that there’s available legal opinions from the project itself. But I think it depends, it’s a case-by-case basis, and I think, you know, kind of legal opinions can always get a little intense in terms of their specifics. And you know, you talk to a lawyer, and they always say, “Facts and circumstances.” So, for us, we have a process, we have a team that kind of works on that, and it’s hard to generalize.
Laura Shin:
And so, recently at Consensus: Invest, SEC Chairman Jay Clayton said, “If you finance a venture with a token offering, you should start with the assumption that it is a security.” Both Zero-X and Basic Attention Token were sold in ICOs. Are you guys worried about having listed what could potentially be considered unregistered securities?
Dan Romero:
I think we’re pretty confident in the process that we have, in terms of evaluating each asset we add to the platform. If we have new information, whether that’s through kind of an SEC-type action on a given asset, or a new policy or framework that they put out, new legislation, we’re going to take appropriate actions. But in terms of where we are today, I think we have pretty good confidence in our process and the kind of sets of checks and balances we apply to each asset we list.
Laura Shin:
And so, you know, just through, I think you might have said in this interview, or at least I have the impression that Coinbase has been in communication with regulators about these matters, and I’m sure you’re not just listing new tokens without feeling some level of reassurance that you’re not listing unregistered securities. And everyone’s always talking about how it is the Howey Test that determines whether a token is considered a security.
However, there is this new idea that you could potentially have a token that starts off as a security, but that at some point in time later morphs in a commodity. So, what factors do you look at to determine whether or not, even if a coin was sold in an ICO, whether it would no longer be considered a security?
Dan Romero:
I think, again, it depends on the asset, case-by-case basis. But my sense is, the SEC has been very public about their kind of pragmatic optimism around the innovation that’s coming from cryptocurrencies, and I think that they kind of have also said, hey, look, we’re going to enforce the laws that exist. And so, I think I’m keen to just continue to watch the developments. I think, you know, the kind of senior leaders and their comments publicly there have been positive for the industry, and I think, in terms of, if you kind of think about stepping back where we were in 2017, we saw a massive increase in the amount of mainstream interest in cryptocurrencies.
And with that interest, you had a bunch of bad actors also come in, and I think having the government on the regulatory side come in and issue clear guidance, and take action on the clear bad actors, I think is a net positive in the long term, especially for companies and projects and people in the industry who are trying to do legitimately innovative things. And so, from my standpoint, each kind of new piece of guidance or shift in terms of thinking around cryptocurrencies is a positive thing for the industry.
Laura Shin:
So, at least with Ether, I think one of the factors that led them to recently say, and it wasn’t, like, an official SEC statement, but one of the directors made remarks saying that Ether was now sort of, basically sufficiently decentralized. So, how are you guys kind of looking at coins that you might potentially list when it comes to that? How are you thinking about decentralization and whether or not that would, you know, kind of push something over to that area of no longer being a security?
Dan Romero:
Yeah, I don’t think it’s as black or white, and again, I keep going back to this idea of facts and circumstances, case-by-case basis. But generally, decentralization is something that we look at in assets, and I think generally, most of these projects, they start off with a small number of people who are interested in them, and generally over time, they get more people who are interested in them, right? So, even something like Bitcoin started with a small group of people who found it interesting, and then over time, more and more people got exposed to it, and now probably the best-known cryptocurrency.
So, my sense is, there’s a spectrum with all of these projects, and we’re such early days for this industry. So, I can only imagine where we’ll be two, three years from now, and many of these projects that kind of only have a few people interested in them today will have potentially millions of people using it, whether they know it or not, as a technology platform.
Laura Shin:
We’re going to keep discussing Coinbase’s listing process, but first, I’d like to take a quick break for our fabulous sponsors.
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Laura Shin:
I’m speaking with Dan Romero of Coinbase. So, to go back to your listing checklist, it also notes that consumer demand is one of the factors guiding the decision. As we’ve seen in the crypto space, there are various pump-and-dump groups, or, as I can see from my Twitter notifications, sometimes a prominent fan of a coin will tag, you know, somebody that they perceive as an influencer or whatever and get hundreds of people to, like, re-Tweet it, so it will spam that person’s notifications.
So, from all these different behaviors, we know that people are financially motivated to harass exchanges like Coinbase to get their coin listed, and that’s sort of, like, regardless of whether it has any real fundamentals. So, in more gray areas, where the coin maybe isn’t, you know, kind of, like, obviously one of the top coins, how much would consumer demand play a role in determining whether or not to list a coin?
Dan Romero:
So, customer demand is a core component to anything that we do at Coinbase, listing assets or building new products. But I think, something I had mentioned before, one of the things that we plan to do as we list more cryptocurrencies to the platform, provide customers with information and quality signals that can help them make good decisions related to cryptocurrency. And I think Coinbase.com/Learn is an initiative we recently launched, that we had really never done any education, and it’s kind of our first foray there.
It’s a bit more high-level and focused on Bitcoin, but with that and our recent addition of asset pages on the consumer platform, we have a kind of new place where we can add information and quality signals on a per-asset basis for customers to make their own decisions. If you think about in the kind of traditional financial asset world, if you were to go to kind of a traditional brokerage account, and you were to look up a ticker symbol, there’s a plethora of information, both technical information as well as analyst third-party information. Obviously, in a kind of public equities world, there are quarterly filings.
I think the Masari Project is a great example of a third-party project that’s trying to kind of create some of that in crypto, and I think we’re keen on exposing our customers to the highest-quality sources of information, so that for any given cryptocurrency, they can make a determination whether it makes sense for them to buy it or use it. And I think you have to also think of, there are cases where, especially as we move towards a utility phase for cryptocurrency, where consumers, especially, may earn some cryptocurrency, that they would prefer to actually change into a different cryptocurrency.
So, you can imagine, I’m using a kind of cryptocurrency-powered social network, and I might earn some cryptocurrency for posting a funny piece of content, and I get some up-votes there. I might not actually want to own that cryptocurrency long-term, and so, what I do is I take that cryptocurrency, I bring it to a platform that I trust like Coinbase, and I might trade it for Bitcoin, which might be my preference to own long-term. And so, I think for us, we have to balance that the kind of ability to switch between cryptocurrencies is a core piece of functionality in the ecosystem.
And today, for customers who use Coinbase, when we only have seven assets on the platform, and there are other exchanges out there that might have, you know, 200-plus, it ultimately has customers going to other places, where they’ve told us, hey, I don’t trust the security there as much, but ultimately, I want to do something with a different cryptocurrency. So, I think we’re committed to listing as many crypto assets as we legally can possibly do, in as many places as we can from a jurisdiction standpoint, but I think it’s, part and parcel is to also have that high-quality information and signals about each asset, so that consumers are really well-informed.
Laura Shin:
Yeah, I find that really interesting, and smart, frankly, to give people more information, because I feel like what’s happening in this space a lot is that consumers just hear about something, they don’t really understand it, but somebody has told them it’s the next, fill in the blank, like, Bitcoin or PayPal or whatever it might be. And so, yeah, I imagine that education is a huge component, but by the same token, do you worry that Coinbase maybe has this sort of, like, outsized influence in what people will purchase?
Dan Romero:
I don’t worry too much about that, because, first of all, if you look at it from kind of a global trading volume standpoint, we’re not kind of the runaway market share leader. It’s actually, there are far bigger exchanges, and customers, whether they’re here in the US or overseas, they use other platforms. And so, I think of us as providing kind of those two things I always go back to, as most trusted and easy to use. And “most trusted” generally comes with kind of playing within the regulatory frameworks for the markets where we operate, and having really good security, and then, I think “ease of use” is offering customers, in whatever kind of local currency they have, an easy on-ramp into the ecosystem.
And then, to the degree that they want to cash back into fiat, we allow that too. And so, I think those are our core principles, and adding more cryptocurrencies to the platform, like I said before, is something that customers are asking us to do, and when we think about how we can do that and still remain trusted and easy to use, our mind immediately goes to, how can we provide consumers with kind of one-click access to the best sources of information about any given crypto asset.
Laura Shin:
Coinbase Custody, which is your product for institutions, lists more assets than Coinbase itself does. How does the approval process for those, for the assets on Coinbase Custody differ, and why does it differ?
Dan Romero:
So, Custody’s slightly different, in that you’re not trading cryptocurrency in Custody, you’re simply storing it, and if you think about it, when you’re storing cryptocurrency, you’re simply holding a private key on behalf of another person or organization. So, I think it has a slightly different set of legal considerations. We have a trust license in New York, and so, very focused on making sure that we fall within the kind of regulatory framework for that license, but I think generally you’ll see Custody probably have more assets, or cryptocurrencies, that we support than maybe what’s available on Pro, which, then a sub-set might even be smaller on Consumer.
So, I think we think about it based on the customer type, as well as the kind of intended purpose of a given product.
Laura Shin:
And is that more based on demand from the institutions, then?
Dan Romero:
Yeah. I think institutions, a lot of these early-stage projects that are even, in some cases, pre-launch, they still have to solve the Custody challenge. And I think Coinbase Custody provides kind of a clean, well-lit, regulated place for institutions to do that, and that’s kind of the focus of that product.
Laura Shin:
So, I was also looking, again, at these criteria for the Coinbase listing page, and it also was saying that when it comes to airdropped or hard-forked coins, at least with regard to consumer demand, that there’s a separate set of criteria. So, what is that criteria? Like, how do you determine whether or not to add an airdropped or hard-forked coin?
Dan Romero:
The airdropped or hard-forked coins, I think those fall in a separate bucket, but largely the same set of criteria. I think there might be some minor nuances, but nothing that comes to top of mind that probably is worth discussing.
Laura Shin:
Okay. So, so far, Coinbase has cultivated this reputation as a regulatory-compliant crypto exchange, and yet at the same time, you recently listed the Zero-X token, and you also acquired the decentralized exchange relayer Paradex. Meanwhile, the SEC announced that it had settled charges with Zachary Coburn, the founder of the supposedly decentralized exchange EtherDelta, which the SEC had determined, who the SEC determined had operated as an unregistered national securities exchange.
So, I see Paradex is currently not available in the US. What is Coinbase’s thinking around decentralized exchanges and how they can be regulatorily compliant?
Dan Romero:
Yeah, so, if we step back, I think one of the things that we’re always asking ourselves at Coinbase is what’s next, and when we were looking at that earlier this year, we felt like decentralized exchange technology is something that we should be investing in, given that our core business today is exchange of cryptocurrency. So, we, in the same way you might think of Apple with the iPod, and then getting first to the Smartphone game with the iPhone before someone else invented that, I think for us, we want to make sure that we’re thinking about what’s next.
And Ron and team had built a great product with Paradex, and so, kind of started some conversations with them, and ultimately they kind of decided to come onboard. I think from a country-by-country approach, like I said before, we’re going to take that really seriously, and so, where Paradex is available today or not available today is largely driven by where we believe that the kind of current model by which it’s operating where we can effectively do that. I think the long-term view of decentralized exchanges, it actually is a significant improvement for the security model of the industry overall, in that you can do exchange without having to trust someone else with the custody of your keys.
Now, there are going to be definitely situations where people still want that, and I think Coinbase has provided a great brand and platform for people who want someone to store their private keys securely. We do that both on our Consumer platform and on the institutional Custody platform, but there’s always going to be a segment of folks, and I would imagine over time, as people get more comfortable with cryptocurrency, it will be a growing segment that fundamentally want to hold and secure their own private keys, but in doing so, they’re limiting some of the functionality that you might get from the kind of centralized platforms today, mainly being able to exchange between different cryptos.
And so, I think decentralized exchange technology that Paradex kind of has built, and there are others out there, using the Zero-X protocol is a really powerful force, but we are still really in the early days there. So, I think for us it’s a kind of early-stage product that we hope to see grow over time, and hopefully is a complement to the kind of centralized order books and exchanges that we have today.
Laura Shin:
Yeah, I actually want to talk about this a little bit more, because I feel like the way the crypto space is developing, there’s two business models that we’re seeing in the space. One is the traditional centralized business model, which is what Coinbase has so far pursued, and then there’s this decentralized business model, which, you know, there’s actually many variations on this, but you know, Paradex would be, I guess, an example. But generally, I guess you could say that they’re sort of characterized by not having this traditional top-down, hierarchical business structure.
So, what does that look like for a centralized company, to work with and integrate this decentralized service?
Dan Romero:
It definitely has its set of challenges, and I think one of the things that we are learning here at Coinbase is how to have an effective distributed workforce. We traditionally had been here in San Francisco, and then we had some remote folks on the ops side, but we’re now at a point where we have multiple offices. We’re very much a global company, right? You know, Japan, UK, multiple offices here in the US, and then kind of distributed engineers and other folks around the world.
I think if you step back even more and look at crypto, I think crypto companies are probably some of the most decentralized and remote-first companies that exist in technology, period. And so, Paradex is a great example of a team that, they were largely remote when we kind of acquired them, and now, I think we’re building that culture at Coinbase to effectively be able to handle both. And I think the power of crypto, to the point about decentralization is, as long as you have an internet connection and a computer, you can start contributing right away, wherever you are.
And hopefully, in a world where there’s easier access into cryptocurrency with any local currency, it’s easier to get some of your first crypto. But even if you don’t, I think platforms that we have like Earn allow another vector for people to get their first cryptocurrency, it’s to earn it, right, to do a task, get some crypto, and then, you know, be able to be on your merry way. But even, I think, you know, mining is another example, and maybe you can’t mine Bitcoin because it’s all ASICs at this point, but there are other cryptocurrencies that maybe just having a laptop, or even a Smartphone, you could get some of your first cryptocurrency.
Laura Shin:
And for a company like Coinbase where compliance has been such a big focus, obviously when you have something like a DEX, where maybe there isn’t necessarily an account where there’s KYC and AML being done, how would you navigate that priority of wanting to be compliant against kind of this more decentralized model that maybe doesn’t have that compliance layer on it?
Dan Romero:
The way we think about compliance as it relates to crypto is when you’re hosting someone’s keys, and you have a centralized platform, and you’re touching fiat money, that’s your very standard financial service, right? So, immediately have all the obligations that you would if you were any other money-transmitter or kind of financial institution. The interesting thing happens when you start to talk about non-custodial, right, user control is another term for that, and that looks a lot more like software, right? So, I have Google Chrome.
When I download Google Chrome, you know, that’s a piece of software that sits on my computer, whereas when I use Gmail, that’s a service that Google is providing, and you know, to the degree that Google has regulatory obligations, subpoenas, et cetera, they’re going to comply with that on their hosted service. But as it relates to Google Chrome, that’s on my computer, right? And I think that’s the same for Coinbase, as we think about our sets of products. We have our set of hosted products that kind of fall under all these very specific and very clear, in my mind, regulations.
And then, I think on the kind of software-only side, Coinbase Wallet, you know, Paradex, in terms of the fact that you’re not controlling the keys there, and the settlement layer is actually happening on the Ethereum blockchain. I think we think of those as far more software-oriented products. That said, I think we tend to make to make sure that we’re engaging with regulators on everything that we’re doing, and so, to the degree that we feel like something might even be software, but a regulator is kind of, has a different point of view, I think we’re going to kind of make sure we’re proactively engaging there, and kind of make a risk-adjust decision on kind of what we’re offering where.
Laura Shin:
And earlier, we talked about the business models, but just to kind of point out, like, obviously right now, a huge part of Coinbase’s revenues comes from exchange fees. But with something like Paradex, it probably really isn’t possible to charge those kinds of fees. So, as you kind of look to disrupt yourselves, or look around the corner at what’s coming next, how would this kind of acquisition or adopting this new model, how could that affect the way Coinbase makes money?
Dan Romero:
Yeah, I mean, if I had a crystal ball to be able to tell you, then, you know, A, we might already be doing it, but I think if you look at a couple of analogs in the tech space, obviously Netflix started out as mailing DVDs, and then moved to streaming, and then that was a transition that they kind of had to thread the needle on. I would imagine we’re going to have our own version of that at some point, and I think we can kind of see where the world is headed. In terms of decentralized exchanges, you have less of a chance to charge the kind of standard exchange fee that we have today.
But that said, I think there kind of can be business model innovation, right? CD companies, or music companies used to sell records, then they sold CDs, and then Napster came along, and everyone said, my goodness, you can’t make money on music anymore, and then we moved to things like streaming, and then live concerts, right? So, I think we’re going to continue to adapt, based on fundamentally what customers want, and if we can provide value to customers, whether that’s in a centralized fashion or a decentralized fashion, I think we’ll probably be able to figure out a way to get compensated for that.
Laura Shin:
You mentioned Chrome as a comparison. So, Google gives away Chrome for free, but then it benefits from the data that it collects on users. So, is that where you were going, like, would Coinbase do something similar with stacks users?
Dan Romero:
Probably not. I can’t comment on the future, but I think, knowing how we operate here today, and kind of what our business model is, and frankly, the ethos of the cryptocurrency space, I think privacy is a huge component of that. I think you could see in the IRS situation last year, where we fought back for customer privacy as a commitment, right, that was something that we made a decision, that customer privacy is worth going to bat for. And my view is, selling customer data, it’s kind of a race to the bottom, so, something that, I would rather figure out other ways to provide value to customers.
And the beauty of crypto is that you have value embedded in the networks. So, to the degree that I’m providing someone value for cryptocurrency, it’s pretty easy to take a little bit of a fee, for example, if, assuming that the customer opts into that, in a pretty seamless way, right? I think one of the challenges with the traditional internet, and kind of, maybe you call it the original sin of Web 1.0 and Web 2.0 was that 402 error didn’t ever get filled out, and native payments were not made part of things. And so, naturally, you had to move to ad-based models or models that assumed adding a payment method was really hard.
So, I think for us, we’re going to continue to start with a customer, what do they want, and try to figure out ways to provide value in a way that customers think we’re most trusted and easiest to use. So, to the degree that ad-supported business models, I don’t know if that’s going to fall in that framework.
Laura Shin:
Yeah, and for listeners who aren’t familiar with what happened with the IRS, they asked Coinbase to provide all of their customer data on people who transacted within, like, a, it was over a three-year period, I think. And Coinbase successfully got that down to customers whose transactions exceeded, I think it was 20,000 dollars in a year, was that correct?
Dan Romero:
It was a significantly smaller number of customers, and I think for us, we’re always happy to kind of work within the law in the places that we operate, but we also really care about customer privacy.
Laura Shin:
Yeah, I did do an episode on that, but that was before the whole thing got resolved, but I’ll still, I’ll link to it in the show notes in case anybody’s interested. So, another question that I wanted to ask was about how the industry, or at least a lot of these networks, are moving over to a proof-of-stake model, and we’re seeing these staking-as-a-service companies and things like that coming up. Obviously, Coinbase is holding onto a lot of coins for users. Would Coinbase ever consider staking for users?
Dan Romero:
I think it starts with what do customers want, and so, if customers are saying to us, “We want the rewards from staking,” assuming we support assets that kind of use staking, then I think that’s something that we’re going to strongly consider. I think today, the assets we have on the platform, none of them have a clear timeline for staking. I don’t think that’s going to happen in Bitcoin any time soon. I think with Ether, there are kind of talks of it and plans, but that’s still a ways away.
I think there are certain other assets that are actively using staking technology, different types of it, and in some cases, people are earning some amount of interest, if you want to think of it like that. So, it’s something that we’re paying attention to, and if customers are kind of telling us this is what they want, I think we’re going to try to deliver that.
Laura Shin:
Yeah, something that was a little bit interesting, that somebody mentioned to me, was if that happens, then we could end up in these situations where these exchanges have a large amount of power over some of these networks, right? What do you think of that?
Dan Romero:
Potentially. The other thing that’s beautiful about cryptocurrency is if people don’t like that, they can fork the network and potentially redo the staking algorithm or consensus mechanism in a way that might limit any one party from having a large pool of the crypto tokens in that given network. So, I don’t worry too, too much about it. It’s a bit of a hypothetical at this point, but the power of crypto and the open financial system is that if you don’t like something about it, you have the ability to kind of fork or clone or build your own, and if people fundamentally believe in that governance model and kind of the way the technology works, you’re probably going to find fans.
And people spend a lot of time looking at new technologies in this space, so, I think you kind of saw it with Bitcoin. When I started at Coinbase, it’s kind of, the only game in town was Bitcoin, and I think you saw this with the rise of Ethereum, right? And I think Ethereum provided a set of things that didn’t exist in the marketplace, and so, people use Ethereum for certain things, and they use Bitcoin for other things, and I can imagine that at some point, there will probably be another kind of blockchain that comes along with a set of rules and technologies that people are pretty interested in.
And to the degree that centralized, or too-centralized staking is a problem, that’s something that either the network that has that problem can fix, or someone else can come along and offer a better alternative.
Laura Shin:
So, there was a period where Coinbase grew exponentially in a short period of time, and also what happened during that short period of time is that customer service complaints skyrocketed. But just, there’s somebody who tracks the growth in customers at Coinbase, and when you look at the graph of that chart, it literally, it just looks like one of those classic hockey sticks. So, what was it like trying to scale the company at that time?
Dan Romero:
It was definitely a challenging year. I think the metaphor people sometimes use is building an airplane while flying it. That felt apt for how 2017 was, and frankly, it was challenging in that customers were disappointed when we can’t get back to them in a timely manner, or, you know, the site goes down. And so, that’s incredibly frustrating, when you’re putting your kind of heart and soul into the company every day, and you’re not kind of meeting those expectations.
But fortunately for us, I think, we’re doubling down on crypto this year, when others may be pulling back, and we kind of committed to improving last year, and have kind of chugged away, largely silently on that, and I give Tina Bhatnagar, the executive we hired, who had previously been at some other prominent tech companies, she solved the support problem, from my view. I think we’re at this point where 90 percent of cases are resolved within 48 hours. I think last year we were measuring time to first response as our kind of primary metric.
So, it’s a marked year-over-year change. Granted, volumes are a bit lower this year, but I think we’re going to continue to invest in the quality and service levels of our platform. So, we’re constantly working right now on how do we scale for the next hundred X, because there have been a few of us who’ve been here for, you know, four, five-plus years, and we know crypto goes through cycles, and we may be in a period kind of where there’s less activity in the market for another year, maybe two, and then things are going to pick back up, and there are going to be a bunch of companies that came in kind of where prices were really high, and activity levels were high, that had kind of pulled back.
But I think it’s safe to say Coinbase is going to be around, and we’re probably going to have, hopefully, a better service kind of level for customers, both on the technology side as well as the support side.
Laura Shin:
Yeah, that actually was my next question for you, because, you know, as you mentioned, there are just, in crypto there are these cycles where there’s these periods of exponential growth. So, how do you make sure that you’re not caught flat-footed again in the future, and yet, also not kind of, like, unnecessarily spend on staff right now during this, what people are calling a crypto winter?
Dan Romero:
I think it’s a couple different things. First, foremost, starts with Brian, he’s incredibly mission-driven. Despite what people on Twitter say, I think Brian is really committed to growing cryptocurrency as a whole, and I think that starts with Bitcoin. But the kind of strategy I think we’re taking is, let’s be really smart about who we’re hiring right now, given where kind of the market is. But at the same time, we’re making the right hires to ensure that we can continue to build out a quality platform, again, both on the technology side and on the support side.
I think we are fortunate in that I think we have a pretty healthy financial state of the company, and we recently just raised some additional money, thinking through, okay, how do we ensure that we can offer a great proposition and continue to invest in innovation, if, you call it the crypto winter, potentially lasts for a year or two. And so, I think ensuring that we can be around, focused on cryptocurrency, and not have to kind of make any compromises, going back to idea of business model, I think we can really focus on delivering great value for customers with a straightforward business model, and do that in a way that, as we move into the next phase of crypto, we’ll be here, and hopefully customers will continue to choose us.
I think one framework we use is when I joined the company in 2014, I think we had kind of crossed the million-person threshold, so, orders of magnitude here. So, a million in the kind of 2014 cycle. I think last year we’re kind of in the tens of millions, and then I think what we think of is in the kind of next general up-market for crypto, you’ll probably see that threshold globally cross a hundred million people using crypto. So, I think that that’s what we’re focused on now, is how do we serve that next hundred million that comes into crypto, and doing that both on a technology and support side.
Laura Shin:
So far, Coinbase has had a very healthy business giving consumers an easy way to buy and sell crypto, but it’s facing, and has already weathered, competition in various ways. And we sort of have touched on some of this so far in the episode, where, you know, like, Binance, you didn’t use that word, but they are an example of an exchange that has listed many, many more coins than Coinbase. So, they, I know, are attracting consumers that want more choice.
Meanwhile, Square and Robinhood are also now competing with Coinbase on its core offering, which is an easy way to buy and sell Bitcoin with no fees, and that could potentially cut into your revenues from that business. And then, on the exchange side, there are institutional players who may prefer to deal with brands such as Fidelity or ICE, which is launching Bakkt, rather than dealing with a startup like Coinbase. So, how does Coinbase plan to weather the competition on all these various fronts?
Dan Romero:
I think that’s all valid, and frankly, I think a lot of those companies that you mentioned have great service offerings, and it really pushes us internally, I find it incredibly motivating. First, from a principle standpoint, I think free markets fundamentally benefit consumers, right? In a world where you only have one or two offerings, it’s easy to kind of rest on your laurels or not think about improving, but in a world where we live, people kind of want to compete for our customers every single day. And one of the beauties of crypto is if you’re not happy with Coinbase, it’s one click away to switch to a different provider.
So, I think that’s a pretty big bar, in terms of offering a level of service and kind of satisfaction for customers, and I think we take it seriously. We track it, we survey customers daily to kind of see the sentiment and set of features that they’re looking for, in order to us, you know, to continue to have that relationship. I think one of the reasons we’re adding more cryptos is when we ask customers kind of what would make you use Coinbase more, or kind of what would increase your satisfaction with Coinbase, it’s hey, you don’t have as many cryptocurrencies on your platform.
So, I think that’s a great example of where we’re responding to customer demand, but I don’t think we’re ever going to just magically have competitors go away. So, I think we generally have to kind of respect competitors, and think about what are they offering to consumers that we’re not, and then kind of take that internally, and try to offer great value proposition to our own customers.
Laura Shin:
Coinbase recently added a stablecoin, USDC, which was launched by Circle, and for listeners who haven’t heard it yet, you should check out my episode with Jeremy Allaire and Sean Neville of Circle. I’ll link to it in the show notes. So, there are various stablecoin approaches. The one that USDC follows is one where the stablecoin is fully backed with reserves. There are other models where, for instance, they maybe will over-collateralize the stablecoin with another crypto asset or other crypto assets. MakerDAO is probably the best example of that.
I also did an episode with MakerDAO, so, actually two, so I will link to those, and then there’s the seigniorage shares model, where they use incentives to keep the price of the coin stable. So, why did Coinbase decide to go with this dollar-backed model?
Dan Romero:
I might sound like a broken record, but generally starts with customers. In kind of talking to our most active customers, one thing that they had kind of cited as hey, look, when we’re trading cryptos, whether it’s on Coinbase or other exchanges, having a kind of cryptocurrency that doesn’t have the exposure to as much volatility is something that’s quite useful, especially as a kind of trading pair. So, I think that’s kind of an initial kernel of an idea, and then kind of looking at the ecosystem when we apply kind of our strategy towards being most trusted and easy to use, we really didn’t see any other kind of alternatives out there other than what Circle had announced.
And so, I think we approached them and said, hey, looks like you’re creating a consortium. We think that you’re taking kind of the same approach around building a really well-trusted stablecoin, which I think is an opportunity in the market. They have the very similar set of licenses that we do. I think we have very similar postures around kind of how to build trust, and so, felt like a really good partner for us to work with. And so, I think the kind of focus of USDC is be that most trusted, and kind of have that US regulatory kind of oversight, as well as, you know, high-quality banking partners here, based here in the US.
And then, I think on the easy-to-use, it’s kind of, you’re one click in and out of a stablecoin, which, I think, if you think of some of the other stablecoins in the ecosystem, sometimes it can be a little challenging to get in and out of the stablecoin. It’s easy if you already have some crypto, and you trade it on a different exchange, but in terms of the ability to kind of redeem that stablecoin, I think we’re in a unique position to kind of offer really high-quality on and off-ramp for it.
Laura Shin:
Here we are, it’s pretty soon going to be 2019, and Coinbase has this mission of building an open financial system for the world, and so far, what we’ve seen in this space is that there’s, I mean, at least in the US in particular, which is I think, you know, the bulk of your business, it’s mostly been speculation. And at the same time all this is going on, I’ve done a little series on my podcast with projects that are building what they call the world of decentralized finance. And earlier, you also referenced how you feel like, you know, at some point soon it’ll be moving into kind of, like, the usability or utility phase of crypto.
So, I’m trying to bring a bunch of strands together into one question, but where do you think the space is going, and where do you see Coinbase fitting into that?
Dan Romero:
So, I reflect over the last four, five years, the biggest difference now compared to where we might have been end of 2014, 2015, which, the kind of environment in some ways felt similar, is the amount of interest from software engineers, entrepreneurs, you know, kind of general tech folks in building, and the amount of innovation that’s actually happening. A lot of kind of under the radar, not necessarily covered by the mainstream press, which loves to talk about whatever the price of Bitcoin is on a given day, is at what I think is an all-time high.
And if you talk to someone like Chris Dixon at a16z, or, you know, Olaf at Polychain, they’re still seeing really, really high-quality teams coming into crypto, trying to solve problems with the technology, and I think that’s the best leading indicator for 2019, and kind of beyond. So, I think, you know, you have Bitcoin and Ethereum, which I think are a little bit more established at this point, but if you kind of look to the next generation of, whether it’s actual blockchains or kind of applications built on top of blockchains, whether that’s on Ethereum with, I think you kind of mentioned decentralized finance.
I think there are a bunch of projects that are pretty exciting there, but it bodes well for the actual utility of the space, right, and to the point about open financial system, our view is you have to have the investment phase happen first, before you have the utility phase, because you’re fundamentally booting up kind of money, and value. And so, to do that, you need to actually bring some value into the system first before you can kind of start to do things like payments, and kind of all the other wild things that no one’s totally invented yet, right?
Balaji Srinivasan, our CTO, mentions on a pretty regular basis that everyone says there’s no one doing anything with crypto except moving billions of dollars per day in a trustless, peer-to-peer manner. And so, I kind of chuckle every time I think about that, because it is kind of true to think about ten years ago, this didn’t exist. And so, just kind of to imagine where we are ten years from now, you know, your mind can kind of run wild.
Laura Shin:
Yeah. Yeah, I actually, I totally agree with you, or, I guess, what you were saying with Olaf and Chris, what they’re seeing, in the sense that, because, like, so, I started covering this space in 2015, and what I really liked about it was that I felt like I was learning about some really interesting technology, and just kind of having my mind blown all the time, right? And then, in 2017, I was like, man, my job is super-different now, and it’s not as much fun, because it’s just about shady people doing shady things.
And so, I feel like it’s kind of just a bit more refreshing this year to, again, feel like I’m engaging more with people who are serious and are actually trying to solve real problems. So, anyway, well, this has been a great discussion. Where can people learn more about you and Coinbase?
Dan Romero:
You can learn more about Coinbase at Coinbase.com, and more about me on Twitter. My handle is DWR.
Laura Shin:
Great. Well, thanks for coming on Unchained.
Dan Romero:
Thanks for having me.
Laura Shin:
Thanks so much for joining us today. To learn more about Dan, check out the show notes inside your podcast player. New episodes of Unchained come out every Tuesday. If you haven’t already, rate, review, and subscribe on Apple Podcasts. If you liked this episode, share it with your friends on Facebook, Twitter, or LinkedIn. And if you’re not yet subscribed to my other podcast, Unconfirmed, I highly recommend you check it out and subscribe now. Unchained is produced by me, Laura Shin, with help from Rayleen Galipali, Fractal Recording, Jennie Josephson, Corin Haith, and Daniel Nuss. Thanks for listening.
