Tan Sukhera 00:03
Hey guys, and welcome to Canadian regulatory fireside chats. Now, before the pandemic gr folks used to get together, especially on Fridays at lunch and network, and they would learn from their peers and troubleshoot different issues and brush up on tips. But unfortunately now it’s a bit of a thing of the past with the whole pandemic. And it’s really in this spirit that we started Canadian regulatory fireside chats. Now there’s been a massive lack of information out there, especially on our social media feeds about the fantastic work that people in the space are up to. So we’re really proud to be part of the solution. Now, the series is made to be a platform for champions of industry from government relations, policy regulatory teams, to be able to share their take on best practices and overcoming challenges and educating others. Now if you’re a fan of the chats, please feel free to like, share and join into the conversation. And now it’s time to take a look at some of the housekeeping rules. So as as always the 30 minute session, there’s a q&a in the chat. So if you want to take a moment to locate the q&a button in the zoom call there, you can use that to add in any questions that you have. The recording will be shared after the event and if you’re someone who likes to tweet, you can always use the hashtag hashtag fireside chats, and at no it G and o wi T. If you’re interested in becoming a speaker, you can always send us an email at Hello at nowhere calm, there’s always different topics and industries. And really the goal is to just share as much insights as possible. Now on that note, I’m your host Hansa Kara, I’m the VP of insights for no ink. And we’re always and still are improving and eager to learn and so we always welcome your feedback as well. Now this talk is powered by Noah Inc. And for those who don’t know, we’re a media regulatory and business intelligence company. We use AI and machine learning to actively search federal, provincial and municipal government sources of information online. This includes everything from the hand side of the Parliament, concerts, committees, debates, requests for consultations, regulatory bodies, government agencies, live video feeds, and more and you can visit www.att.com for more details on that. So now it’s time to you know, introduce our speaker for Episode 12. We’ve got it’s called cryptocurrency in Canada we’ve got torx Stein here. Now Torsten has recently joined a bit by as the head of regulatory affairs and Chief Compliance Officer. He’s going to be working with Canadian regulators to get bit to get bit by approved with Canadian securities administrators in Iraq as a dealer and marketplace so tour Stein has previously been the CEO and co CEO at instant Canada and instant Canada cross and prior to that tour, Stein was CTO at BMO capital markets. And he was also CEO and CTO at try act Canada marketplace and tour started recently was a member of the Ontario Securities Commission FinTech Advisory Committee, and is currently a member of Iraq’s crypto asset Working Group. Torsten has over three decades of experience in compliance, risk management and capital markets. So without any further ado, take it away, throw aside.
Torstein Braaten 03:02
Right Thank you 10. First, I’ll start off with a brief description of what bitbuy is, just in case you don’t know. We are crypto contracts dealer. So I’ll get into that a little later what that is, but we have nine crypto coins. We have a web and mobile platform. It’s an on ramp to buy crypto for Canadians in Canadian dollars, where you can deposit withdraw crypto from the platform, you can trade on the platform, it’s a marketplace, 24 hours, seven days a week continuous order book, we offer access to retail corporate clients from all provinces in Canada. And just to remind you that this is only for Canada, we have an over the counter desk, which helps clients by large, larger size orders. We act as agent on those trades. And we are one of the largest crypto platforms in Canada. So for my fireside chat, I thought I’d kind of go through a bit of a history of the regulation of crypto markets in Canada talk about the different regulators kind of walk you through how it was developed and where it’s going, hopefully in the future. There’s four basic frameworks for crypto regulation. There’s fintrac, which is the anti money laundering regulator, back in 2020, they required all the crypto firms to become money services businesses. So that is a registration with the fintrac organization into ensure just like many other financial services companies to file, suspicious transaction reports and other filings to assist law enforcement in the event of any money one. So that’s a little over a year ago. And so you can think about that as being fairly recent. But just like many of the other organizations, it’s been something that’s Important to the crypto industry for a long time. The second group would be the Canadian securities administrators. So that involves all the provincial Securities Commission. So I have here at screws Commission’s bc Securities Commission, those are across the country, and they’re involved with National Instruments, which you you hopefully are aware of that govern securities dealings. So all the securities practices across Canada, each province has its own commission, with the CSA as an umbrella, and they try to work together. And we often talk about passporting. So if you’re in one province, you can apply and get passported across the country. And Ontario is our lead jurisdiction, we’re in Toronto. So we will apply for any securities or related business with OSC and then hopefully get passed ported across the country through the CSA. Back in March 29 2021. The CSA as well as with iraq came out with a notice saying, all the crypto trading platforms had to get registered. So the idea was for them to come in and present their business case and plan to get registered. And then following that, there’ll be a process of registration. I’ll get into that a little later about some of the examples and our we are in that process, so bit by what have gone in and provided information. And we’ll be working with the regulators. And that’s the reason for my hire. The other framework, part of the framework is the Iraq investment industry, regulatory organization of Canada, that is part of the application process. If the CSA and various provincial securities commissions approve you, as what’s called the restricted dealer, you have two years to submit to Iraq as an investment dealer. And that would be a limited product offering of cryptocurrency. So there’s been a couple approvals out there, there’s an older one, and then just a couple of recent ones, the filings were made, and you can read through those on the OSC website or CSC website. And I’m not going to get into details of what our competitors have done.
Torstein Braaten 07:28
But the the idea is that it would be a limited product offering under the Iraq dealer registration. And that means that other iraq dealers could file as crypto trading firms by adding the product to their shelf. So if you can think of a current iraq dealer that trades principally equities and fixed income for their investment advisors, or institutional retail, they could add the product of crypto product, cryptocurrencies. So there’s two main themes in the the Iraq platform that would be the order execution only when you commonly think of your discount brokers. And then you have the suitability side where the advisor side where it’s a traditionally call that full service dealers. And I guess the third category would be institutional only. But the full service would be your traditional investment advisor that looks at your portfolio and provides recommendations about which products to buy and sell. The last part of this framework that is important is the marketplace regulation. As hopefully you realize, in Canada, we have a number of exchanges for equities. And we have a couple of alternative trading systems for equities. This will port over to the crypto space. So the term we’ll be using is crypto trading platform. But it will fall under the marketplace regulation. And it’ll be regulated by Iraq as well as the provincial securities commissions. And they will look at it very similar to what they’ve already set out as an alternative trading system or an exchange. There’s some question about if a crypto trading platform could be an exchange. Since it does not list securities, it simply in Canada would be trading crypto currencies or crypto assets that are created in the past on somewhere else, or maybe so but not created by the exchange as you think of a traditional Initial Public Offering IPO. So that’s, that’s a general framework you can think of for different categories. So now I’d like just to kind of quickly go through the evolution of crypto regulation which was the I think the point of my talk is to kind of walk through and say where we are, where we’re going and some of the highlights of what’s happening in crypto regulation. Thinking back, Bitcoin is not that old, but started in 2009. So you have a few years before it really got any attention. Back in 2012, one of the major developments was ripple that you can see there’s a lot of news about ripple in the US with the securities exchange commission, pursuing them. There’s a lot of talk about what is it UN Security was an illegal offering. But ripple was back in 2012. So we’re talking nine years ago. But that still is not that old when it comes to equity trading or investments in the industry. And then more recently, you have a major coin, Ethereum Ethereum network with ether launched in 2015. So this is a fairly new process of coins being developed. If you go on the web, you can probably search out and find 10s of 1000s of projects or coins or tokens. There’s so many items out there, I don’t think I’m going to get into the description of what each one is. But it’s important for you to realize that it’s an exponential growth of product. Very similar to thinking to the internet in the beginning, a few websites when they were first created. And as the product as the internet started to grow in popularity, websites started to explode the number of websites. And you can imagine there’s millions, if not billions of websites out there right now.
Torstein Braaten 11:52
Following the development of the crypto assets, we’ll call it, these coins being developed. We have the first view by the regulators in 2016. You have the Ontario Securities Commission Launchpad and the Canadian securities administer, airy, regulatory sandbox launched in 2016. So that would be just after a theory was started. Then in 2017, we got our first indication of what the regulators were going to do about reg regulation of tokens. There was something called the the token founder, application and belief. So that’s about four years ago, you start to realize that there’s some development, there’s some relief given, there’s some review of tokens being securities. Along that timeframe, we had a big focus on token offerings. And I think the focus back then was illegal token offerings. Since the view was if there was an offering of what was potentially defined as security, the crypto community call that a token or Ico Ico initial token offering, those were should have been filed with the regulator, and relief given if it was appropriate, and through the sandbox or Launchpad sort of process. So we finally got guidance on Icos back in 2018. So that would have been pronouncement from the Canadian securities administrators, they would have provided information with about their expectations. And it really comes back to applying very standardized securities offerings, perspectives offering approach. So if you don’t know what it is, put it into the sandbox and get an evaluation, applied its existing regulation, and see if you need relief. And if you need the relief, applied for the relief, get the relief and then go forward with your offering. If you don’t need relief, then probably need to file a prospectus. Now that the obvious challenges in this environment of a new innovative asset class, it doesn’t always fit in the concept of perspectives. You don’t have the same sort of idea as a company being developed with directors and products, physical products being sold, financial statements being developed for a token offering. So there was definitely some friction between the industry trying to offer the tokens versus the regulator’s trying to figure out how to regulate it. But they did provide guidance and they did vide how Use for companies or our projects, I’d like to call them to seek out relief. Following 2018, there were a few items that came out of the sandbox applications. So you can go on to the Canadian series administrator website, you can look at the applications, the projects, and what relief was received. But still, we were in a stage of putting everything that’s crypto related into the sandbox sort of concept, waiting for what the final regulation would be. So following that, in 2019, please, the regulator’s started to talk about what’s called crypto asset trading platforms. So that is identifying the firm’s that are offering access to customers to buy crypto assets. So in Canada at the time, you would have a number of companies that were providing technology, such a bit by would have been providing access through an application to buy maybe Bitcoin, maybe it ether, a couple of coins, a couple of coins available in Canada was the common position, you would be able to go on purchase and then hold with the platform, the coin and in some cases, be able to move it off the platform to your wallet or receive it from another marketplace or exchange abroad. So it would be more common at that time for the for a person to go out and buy bitcoin on an unregulated exchange somewhere. Think about the big ones called the buy Nance. And recently, we have the public company Coinbase, you could go on that platform buy bitcoin, you have to somehow Deliver us dollars to buy the Bitcoin and then you could take it and move it into Canada. Or if you wanted to buy in Canadian dollars, you would go to one of the local companies like bit buy, and it would be a crypto asset trading platform from the regulator’s point of view. But they still did not know exactly how they wanted those platforms to be regulated. This is still before fintrac announced that they wanted to be money services businesses. So we’re still working through the definitions. But one thing that became very obvious is that there are two types of platforms. There’s the platforms that held the coin on the platform, we call that custody. And there are other ones that we’re offering you access to by cryptocurrencies, but asked you to put it into your own wallet, so there is no custody. And that would mean that you’d set up a method for them to facilitate your transaction, instead of to be the opposite side, maybe trading its principal or what we often call an entry riskless principal. Because most of these platforms didn’t want to have too much capital tied up into providing to owning Bitcoin or ether and sell to their customers, they would have a liquidity provider or a marketplace or one of the like larger ones globally to be on the other side of those trades. So now we move into 2020, there was further guidance. So that was the custody versus immediate delivery. So that was the clarity of saying, if you could demonstrate that you provide an immediate delivery and you’re just more of a piece of technology, granting the customer the access to a platform that at this point would not have been regulated in and there’s very few jurisdictions that were having any form of true regulation outside of what we’d call the anti money laundering, terrorist financing restrictions or your your money services businesses. So in 2020, we’re thinking that’s just last year, we’re dealing with the understanding that there is going to be regulation coming, that custody is the key aspect that you have to focus on as the firm started to look into this and try to decide if they were going to change their business model suddenly came along 2021 when, in end of March of this year, the CSA and Iraq sent out the notice to say You must come in and register and they went out to me Every crypto platform they could identify, to try to contact to them to notify them that this was a relevant rule for that the if the marketing to Canadians, they were under the jurisdiction of the Canadian regulators, and that they should register if they want to continue to deal with Canadians. And when you think about Canadian Canadian person, it would be a company, an individual, an institution of any any sort, and then you’d have to figure out if, if it’s a person, you’d be highly regulated, if it was a large institution, there may be some exemptions available. So there’s other methods of offering to institutional investors such as exempt market dealer and other delivery mechanisms from that perspective. So that started in basically April, as all of these firms would have come in, and they would have contacted their local provincial regulator, and then started the discussions of what they were going to do. Some of the firms had already been in discussions with regulators since 2020, or even earlier, you will see references in some of the press releases that they’ve been in the process of figuring out registration for over a year. So it was not a quick process for a bit by we have gone going through the process of registering the dealer and the marketplace. So it takes time, we’ve seen references to 70 platforms have come in and submitted some form of paperwork. And we have two recent ones that were approved as restricted dealers. And as I mentioned earlier, they have the two year window to be registered with Iraq, but really a one year window to get their application in with Iraq. So this is a pretty well laid out path. And there’s a lot of I wouldn’t say precedent. But it there’s a lot of information available to these platforms, on how to get registered, that the information has been out there for many years. There’s a national registration. And I 31 103 is always a good handful to remember. But that’s the registration and definitions of what you need to do as a securities dealer or offering securities. And it covers a whole number of types of companies and businesses in the security side. derivatives, again, is a little different. But they would also those companies that are involved in derivatives would have an application process as well. So I’ve kind of gone through the history of con through what the major highlights, I wanted to kind of go back through a little bit of definitions of who’s being regulated, and a little bit about them. Because I think it’s also interesting, because if you’re watching this, you may say, Well, who do I deal with? Do I need to deal with anyone? Am I covered? Or Where would I go next? So the areas of regulation is focusing on crypto assets. And I think now’s the time to kind of step back and wonder what that really means. I would say anything that we have on the blockchain would be considered a crypto asset. The now that could be a token. It could be what we call a crypto currency. It could be a commodity, but whatever is on the blockchain, and that’s can be moved around as an asset or for value. Now, the other thing to think about the blockchain it’s it’s kind of one directional. It’s if you if two of us. So if Ted and I wanted to do a transaction, and I had a Bitcoin, I wanted to give him a Bitcoin. On the blockchain, I would have a record of my Bitcoin and I would transfer it to 10. But it would transfer free because there’s has to be something else involved. Why would I give him one coin. So there, there is no trade yet. I’ve gifted him a coin or I’ve donated a coin to him. But what we know is that I wouldn’t do that unless I was getting something return. And if I’m getting cash in return, that would look a lot like a traditional trade. I give one asset and I received cash, but you could, if I give him a car, and I receive cash, that’s not considered a trade in traditional sense, but if they give me security, and I received cash, that would be considered trade. So the Canadian regulators came up with a concept called crypto contracts. And that would be useful when you’re trading on a platform, since the platform is not actually moving coin around on the blockchain, not necessarily if they’re holding any custody, but they’re still doing what we call trades. movement of commitments, we’ll call it. So the crypto contract is a commitment to buy the platform to the customer of crypto crypto asset. So the platform allows me to sell one bitcoin to Tam and he, in his account, give me cash, and the platform processes that, but in essence, since the platform has all their crypto, hopefully in cold storage, or you can look that up if you want understand more about cold storage or hot wallets. But the idea is the platform facilitates the movements of these crypto contracts between clients. But it’s all in a closed system.
Torstein Braaten 26:06
And if you look at the possibility of bringing new assets into the platform, then that makes it feel more like an old open system. That means a liquidity provider delivers in the coin, so that I could buy this crypto contract that comes into the crypto trading platform. And then I have deposit my cash, and that cash may go off platform to the liquidity provider or to the seller of if it was within the platform. So this is the key to think about. What are you doing? And what are you trading? Are you trading crypto contracts, and who’s on the other side of that contract? This is contract representing a true crypto asset. Getting to the definitions, and it gets confusing when you start saying initial coin offering or initial token offering is a token or a coin, a crypto asset, I think we typically think it is. But then we also get the concern that if it was an illegal coin offering or token offering, then you wouldn’t want to be trading illegal securities. And that may be a concern for your customers if the coin offering or the token that they bought suddenly becomes illegal, and you’re not able to train anymore. So that’s kind of very important to keep in mind when you’re thinking about it, what is regulated. And what are these terms. It doesn’t really matter in the Canadian context. If it was if you’re going to call it a crypto asset, currency token coin, what we want to focus on crypto contracts. And that’s what the customers are actually buying. And behind the contract is the coins being held in custody. Now another group of P companies or persons that need to be regulated in some sense is the public issuers. So you see the mining companies, the technology companies that are offering that or maybe buying coins, and then offering access as a public issuer. So those are, they’re going to be regulated in a different sense. One thing for sure is that if they’re a public issuer, they are listed on an exchange as an equity, they’ll have a symbol, and they’ll be traded, and there’ll be public continuous disclosure requirements. And they will fall very similar to traditional equity security. But they’re going to have their own challenges because they’re holding crypto. And there’s still a lot of development in the, in the world about audit and reporting, taxation of those sorts of things. That leads to another category, which is very popular now exchange traded funds closed in funds, and brand new split shares. These are traditionally similar to what you would your old fashioned mutual fund, but traded on exchange. They trade all day long, from 930 to four in Canada. They each have their own purpose. So the you’d have to kind of investigate that to understand better, but again, they’re going to have the same requirements as a public issuer, but they’re going to have annual annual information forms, and they’ll have portfolio managers that are registered to manage the funds or the ETF. And that that whole area of regulation has been has been a lot of precedent to that since I think it was late 80s, early 90s when we had our first ETF come to Canada. So that that tips, I think we could call back into the day. And now the exci use, etc are more, more known today. Now, going back and thinking about the Canadian securities administrators I mentioned earlier, the National registration system back in, I might get the dates wrong but around 2008 we had registration form. So registration reform would have revamped what I called national instrument 31 1031. And it would have focused on how companies get registered if they need a Chief Compliance Officer.
Torstein Braaten 30:42
CEO would be the ultimate designated person, what would the finance requirements be disclosure requirements, all of these things apply to the crypto firms as they become registered with the screws Commission’s that national registration system was developed over time to launch a revamp client relationship model as back in 2013 2016. That range, then there was a client focus reforms from which are very recent, and that would be a bunch of changes, where they’re just updating the requirements to make sure that the proper disclosure of conflicts of interest is a key focus now, making sure all conflicts are reported to customers. So when that buyer is going through his process of registering, it has to look at all of these changes that happened since 2008. And comply with those just the same way as any other investment dealer would be building their business and building disclosure to their customers, fees, conflicts and everything like that. Now, the other side that I haven’t really focused on, but I want to just touch on is a marketplace. So we mentioned earlier that there’s several marketplaces in Canada, traditionally, you think of them as exchanges. So the Toronto Stock Exchange, there’s new Neo equitas, you have a NASDAQ, which is in Canada, those stock exchanges can list securities, some of them don’t. But they they’re well established businesses with a very well established rules and regulations around them with the crypto marketplace, they will have to look at if they’re offering a continuous market the same as the traditional Stock Exchange does, they will be offering this traditional market in a 24. Seven. So there’s no no time off. And the other interesting thing is, there’s a different sense of settlement. Sorry, I have my dog that just decided to speak up. And, okay, the marketplace that’s regulated, will have to do the same filings as an exchange and provide the same disclosures about fees, business, processes, policies and procedures. So that’s something that’s going to be developing over time. With the crypto area, we see the securities exchange commission in the US they are looking at that area, there are some firms that are filing or making submissions I’ve seen one recently. And this will become a global view as the this continues market these that have always operated within a crypto trading platform, but never operated like a traditional exchange. With all the obligations of filings and market data you can think about one of the key elements of an exchange is one thing fair access, so fair access to the exchange, but also fair access to the information. So the trade reporting and normalizing the trade reporting, so that regulators can do surveillance, customers can know what the fair value is, at any time they can, they can go on to, for example, a Bloomberg or Reuters terminal and say, Okay, I have confidence that bitcoins trading at this price, I can do a conversion for currency. So that sort of transparency is still to come right now. It’s there’s a fairly closed system by market by market, but there are services out there that try to provide transparency and those will be private websites that are not regulated. So they provide very good information. But again, if they’re not regulated, there is always some concern that the information may or may have conflicts. And that’s so you can look right across the web and take it as it is. And some point in the near future, I expect, the regulators start to push for more certainty that the information is true and correct. So the concern obviously isn’t for misleading. The other thing I wanted to kind of touch on is some of the things that are still uncertain about the where we’re think regulation needs more information.
Torstein Braaten 35:46
More, I guess, discussion by the regulators, one of them would be in the clearing and custody. do right now custody, we have a few new players in Canada, but most custody is happening in the large players established players in the US. That’s from a safety and security point of view. If you’re holding clients assets, you want to be very comfortable that the company doing the work has a proper controls has a proper technology, the cyber risk is a very important area. So that is a developing the custody side is developing in Canada, the rules around custody, the reg regulatory requirements around custody, and then on clearing. Right now every marketplace is fairly closed system. And if you need to have open clearing, traditionally clearing is what we know is t plus two in the securities world, it takes two days before the trade settles in the crypto world it should settle instantly. But on one leg, it settles. I would say instantly until it gets put into a block and the verified. But once it’s verified, it’s settled. But the other side of the trade the cash movement or the other coin that moves that that is where you would question it should be settled instantly. And therefore there’s no real need of a clearing agency. And there’s a companies are doing. I wouldn’t say clearing but they’re it’s incidental to what their businesses, they’re just ensuring that all the record keeping is done properly. And there’s no kind of a margin or credit or like the Canadian depository of securities, CDs, it is not in between all the brokers where the net settle, and the the CDs manages the money in the capital, that sort of thing doesn’t exist yet. It may exist, but it only the legitimacy of having a clearing agencies usually to manage over time and to deal with failed settlement. So those those questions are still open. Now the thing that’s kind of coming up every once in a while is tax reporting tax treatment, what we know that tax reporting will be self reporting right now. But what is the tax treatment was fraud, clarity? Is it income capital gains? What are the treatments by the CRA? And will they require these crypto trading platforms to file? And how will they address some of the common things that banks and trust companies are dealing with or so the FinTech world, obviously has to deal with that. And then, just quickly, some of the less less clarity or areas that need to be discussed maybe for a future fire chat. Something like lending loans on crypto. That is there is some models out there. But I think there’s still more to be discussed about loans with crypto and how that is managed in a regulatory sense. decentralized finance called define lend and lending of coins, staking of coins, yield harvesting, those are all interesting things. You can look on the internet and find lots of YouTube videos. Leverage, when should leverage be allowed margin we, we look at crypto and see that each coin has different volatility and maybe it’s legitimate to offer some leverage in some of the more
Torstein Braaten 39:46
larger coins or liquid coins and maybe not on others. So there’s some analysis that should be done there. Derivatives on crypto, that’s common globally, but not as much in cat not really Canada yet but us you have futures and the CME trades futures. But there’s things like swaps and forwards. And then there’s decentralized exchanges, you might have heard of things that exchange like uni swap and sushi swap, or pancake swap, these are where you swap coin for coin. And there’s kind of automated market making there’s methods to your fees, and there’s risk that the exchange could be a risk the the training could be a risk and how our profits made and are, is there arbitrage on these markets, and is it to the benefit of the investors or the benefit of the traders. And then last but not least, I think the most exciting one that’s in the spotlight right now stable coins, we have stable coins for maybe governments, but we have the stable coin, the traditional ones that are offered by private organizations, some of the more common one is tether, rhenish some issues. And then there’s usdc circle, which is the the company in the US that’s filed I think to go public, they offer usdc stable coin is basically supposed to be a coin backed by hard dollars. So it stays stable one coin for $1. But we know that they there’s possibilities that could be below $1 or above $1, based on trading based on the assets behind could be something different than $1. You have to be thoughtful about the whole process of buying and selling stable coins, because someone has to offer a platform and earn fees. So nothing is truly straight $1 for dollar, but it is definitely a very interesting area of growth and probably essential for development of the crypto markets. So as I kind of end, my quick discussion, I wanted to kind of highlight a bit about enforcement because everyone loves to know what’s gone wrong. In Canada, we’ve had four markets or crypto trading platforms that have been basically when I don’t know if I can say banned, but there’s been a statement of allegations against them, that they have been there unregistered, and they have not gone into the securities regulators to submit a plan of registration. So on there, you can find on the interior Securities Commission, these four companies that are being I guess you could technically say banned for Canadians to use. There’s no secret here that to coin by bit politics and Okay, x are the four. You can read the allegations. Not sure there. We can always say everyone’s innocent until proven guilty. But the the concern would be they would have marketed Centurion residents, crypto assets or crypto securities in an unregulated fashion, and have not demonstrated the interest in getting regulated. And the last one is the discussions about by Nance, how they’ve decided to tell a turtle residents that they can no longer deal with finance at the end of this year. So they put a note out themselves saying that they’ll close out all active positions by December 31 2021. That’s another approach where the company itself tells regulators that they’re getting out. So we’ll see how that pans out and and see what happens with the 70 others that apparently went in. So I’m going to hand this back to tend to open up the q&a. And if you want to reach out to me directly on LinkedIn, if you saw my my name in Pro, bio, but I’m also at bit bias towards dinette bit by.ca. And if you have any questions specific to me about some of the stuff I’ve talked about, you can reach out to me directly. Otherwise, let’s see what you have to say now.