Crypto’s Speculation Problem, Regulation Without CLARITY & The Gambling Economy
Pioneers
Santiago Roel Santos
Summary
- Yanowitz argues the market has bottomed, and his evidence isn’t price — it’s pipeline: Blockworks logged more sales calls this week than any week in six months, with inbound leads rising six straight weeks, led by fintechs and brokerages rolling out crypto. His read is that commercial demand from traditional finance (“even Vanguard is pushing in”) is a leading indicator of sentiment, even as spot markets churn sideways and Saylor’s selling is met with only a ~2% weekly drawdown.
- With CLARITY at roughly a 20% chance on Polymarket, Yanowitz’s catalyst thesis is that the SEC and CFTC stop waiting on Congress and push through rules they’ve been sitting on — innovation exemptions, fundraising exemptions, and safe harbors. Rob agrees the agencies will move, but flags the cost: without legislation, token value-accrual design stays “murky” and the largest banks and asset managers — who need long-term planning certainty — invest less. “It is certainly net worse than if we don’t get the CLARITY Act.”
- The sharpest disagreement: Santiago declares “tokens are kind of dead at this point,” citing retail scar tissue from low-float/high-FDV launches and telegraphed vesting unlocks; Rob fires back that “tokens are definitely not dead — that’s a crazy thing to say.” Both concede adoption (stablecoins, Coinbase launching its chain) can boom while your token drops 60–90% — correlation breaking is maturation, but it means enterprise wins don’t pump your alt.
- On Fomo versus Pump.fun, the numbers are hot — Fomo hit a $1.88M weekly net-revenue all-time high with 50K daily active traders, and routed $139M into Pump.fun’s pre-graduation bonding curve August 1–7 — but Rob warns the headline data flatters a shrinking market. DeFi’s rising volume share reflects CEX volume falling sharply, not necessarily on-chain growth (“the numerator is getting bigger, the denominator is getting smaller”), and if this is another meme cycle, history says it crashes in two to three months and “spells worse things for the rest of crypto.”
- Santiago’s most tradeable confession: he’s allocating “less and less crypto, to be honest” in his own venture book, frustrated that most on-chain activity remains “24/7, 365-day speculation” while SpaceX- and Cerebras-style deals feel like curing cancer. Rob’s counter is that financialization “has just seeped into every piece of our lives” — Betterment data shows 26% of Gen Z call sports betting part of their financial strategy and 52% diverted would-be investments into it — so the job is building transparent products, not moralizing.
- Rob’s breakdown of Erebor’s $1.5B raise at an $8B valuation: “the fastest-growing bank ever, essentially,” with over $4B in deposits, using crypto and stablecoin-related capital to lend into capital-starved defense. Banks trade on a tight price-to-book versus ROE relationship; its ROE is deliberately low to signal conservatism to regulators, the raise covers capital ratios, and crucially “they’re growing deposits much more quickly than they’re growing loans, which is a good thing.”
- Collector Crypt crossing $1B in gross revenue — with Pokémon cards as “the single best-performing asset of the last couple of months” — gets dissected as gambling in collector’s clothing: disclosed negative-EV packs, instant buybacks at a 15% discount, and about 99.5% of users selling straight back. Rob’s verdict: “essentially a slot machine where you always make some amount of money, it’s just EV-negative” — and liking this while disdaining memecoin trading “feels very disingenuous.”
- Odds and ends with teeth: Jason reported Paolo’s claim that Tether underwent its first full KPMG audit with an unqualified clean opinion — “the largest inaugural audit in the history of finance,” though Jason said he wasn’t sure how that was measured — and Santiago is holding memory stocks (Micron, SK Hynix, SanDisk; memory was up 15% on the day). If Micron fell 40%: “I’d load up the truck” — his thesis rests on 3–5-year locked-in business contracts and the Benchmark-podcast mantra that “you’re just not bullish enough on AI.”
Deep dive
1. The bottom call rests on B2B pipeline, not price
- Yanowitz’s proposed fear-and-greed index: Blockworks had more sales calls on the calendar this week than any week in the past six months, and inbound leads — historically a leading indicator, since optimistic customers come to you — have increased six weeks in a row. The buyers are fintechs, brokerages, and financial institutions rolling out crypto: they need APIs, the asset-monitoring platform Blockworks acquired from Messari, and front-end signals including fundamentals, social sentiment, and AI chat (“How is Aave different from Morpho?” on a Schwab-style listing page).
- A third bucket is telling: teams “told by their CEO that they need to do something in crypto” who can’t track anything — no user counts, no behavior data — because “all of their traditional data breaks down.” Brokerages see what Binance, OKX, Bybit, Coinbase, and Kraken are making; “even Vanguard is pushing in.”
- Santiago’s pushback: adoption inbound doesn’t equal flows on-chain. “What market and what bottom?” The market always needs a catalyst, Galaxy and every Bitcoin miner are pivoting to AI infrastructure, and retail Koreans are longing SanDisk, Micron, and SK Hynix — “where’s the bid going to come from?” On the 2023 Solana bottom, he admits his thinking wasn’t sophisticated beyond feeling it was totally oversold; he now weights flows and the M2 correlation far more.
2. CLARITY stalls, rulemaking becomes the catalyst — and the token-death fight
- Yanowitz’s thesis: with CLARITY at roughly a 20% chance on Polymarket and Saylor selling while the market is down only about 2% on the week, the SEC and CFTC will stop deferring to Congress and push forward rules they’ve been sitting on since Atkins’ DAS keynote in March and Project Crypto’s rollout sometime in 2025. “They’re not doing these to move prices… they’re doing these to spur innovation” — and innovation spurs prices, the way GENIUS catalyzed stablecoin adoption.
- Rob’s more granular map: an innovation exemption “relatively soon,” a startup fundraising exemption with caps, and safe-harbor rules for teams onshoring in good faith. But the legislation-dependent work — disclosure schedules that could permit direct value accrual to a token or to its holders — “becomes a little bit murkier,” and the largest banks and asset managers doing long-term planning will invest less without statute. “It’s not all lost, but it is certainly net worse.”
- Santiago’s provocation, worth quoting in full: “tokens are kind of dead at this point. Doesn’t mean they’re not alive.” Retail has built “scar tissue” against anything with a telegraphed vesting schedule and low-float/high-FDV structure; certain pockets (stablecoin issuers and projects, Coinbase launching its chain and “printing money over there”) thrive while tokens fall 60–90%. Rob’s flat rejection: “tokens are definitely not dead. That’s a crazy thing to say” — they’re a good mechanism for operating networks, though “that does not mean whatever random token you name is going to go up.”
3. Fomo versus Pump.fun: synergy on the surface, a shrinking denominator underneath
- The headline stats: Fomo hit a weekly net-revenue all-time high of $1.88M with 50K daily active traders; Pump.fun overtook Hyperliquid on some metrics as buybacks may be starting to work. Rob rejects the trendy Polymarket/Kalshi analogy — “they’re not the same thing whatsoever” — and notes they’re partly synergistic: Blockworks data shows Fomo routed $139M into Pump.fun’s pre-graduation bonding curve from August 1–7.
- Rob’s structural worry: institutions are calling Blockworks, “but then literally the only thing happening on-chain right now is memes… and perps.” Past meme cycles ran two to three months before crashing and wiping everyone out — “if we’re having a meme cycle again, that actually spells worse things for the rest of crypto in the near term.”
- His data-literacy caveat is the keeper: charts showing DeFi’s rising share of total volume, or RWA share on Uniswap, mislead because CEX volume from normie users is falling sharply while on-chain-native interest is staying the same or rising — Hyperliquid’s volume is “basically the same.” “If you look underneath the data, it’s not actually great in my mind.” Rob disclosed a small personal angel check into Fomo; he also clarified that Dragonfly is not an investor.
4. Every company gets a reckoning — invest in whether founders survive it
- Yanowitz’s framework: Pump has already passed through its first reckoning — from “could do no wrong” to a difficult past year. He speculates that it may have involved turnover, internal moves, process changes, and figuring out its next products, while acknowledging he doesn’t know what happened internally. Fomo hasn’t had one yet. “I don’t really personally care about breakout virality… I care about how do you get through the reckoning.” Fomo’s founders seem fantastic, but the reckoning is coming; how they handle it is the real diligence.
- Santiago cites Benchmark’s Eric Vishria: if an early-stage investment fails, it fails for exactly the reasons raised at investment committee — and if it works, those reasons wouldn’t have mattered. He retells Vishria’s Cerebras story: a 2019–2020 board meeting where “the chips were melting” and they feared the $50 million already invested might be lost. Santiago also notes that both Kalshi and Polymarket endured years of “really, really tough times” before their seemingly sudden rise over the past 1.5–2 years.
- Rob’s founder filter: some founders “fly close to the sun” and need more support, while he looks for people who are tenacious and will “drive through a wall” to make it work. Pretty much every builder he’s backed or talked to says the same thing: “it just never gets easier, ever.”
5. Santiago’s crisis of conviction — and the industry’s PR problem
- The episode’s most candid moment: Santiago grappling with “where is the puck going?” Underwriting Polymarket’s seed as the future of media was one thing, but “most of the activity today has just been 24/7, 365-day speculation,” and he’s now deploying “less and less crypto, to be honest” — pulled toward SpaceX/Cerebras-style deals that feel like “quite literally curing cancer,” while conceding he has no edge in biotech (“Atlas and a handful of firms” do) and accesses it through funds instead.
- Yanowitz’s reframe: there’s no clean good/bad company anymore — Facebook democratized communication and fueled a youth mental-health crisis; Google organizes the world’s information and monopolizes your digital life; Amazon revolutionized delivery with grueling warehouse conditions. He thinks crypto’s narrative will flip positive in two years, while AI’s will turn negative around the midterms. A source described as well connected in D.C. gave Santiago the top three election issues as “affordability, jobs, and data centers and AI,” with sentiment on data centers and AI already “incredibly negative.”
- Yanowitz says AI has also been poor at explaining itself, quoting an unnamed industry leader whose message is effectively: “I’m going to replace all of your jobs,” while promising unexplained abundance and leaving the winners looking like already-rich San Franciscans. He says crypto has a similar PR problem. The signal hire: Coinbase’s chief legal officer Paul leaving for Cognition, which is raising at a $40B valuation — Yanowitz reads it as Cognition gearing up for a big fight in D.C. as sentiment turns on AI.
6. Inside Erebor’s $8B bank raise: how to value the fastest-growing bank ever
- Rob’s valuation mechanics on Erebor’s $1.5B raise at an $8B valuation: regress price-to-book against ROE and “basically every bank trades on that line” — high multiples price in high future ROE plus growing equity. Erebor is “the fastest-growing bank ever, essentially,” with over $4B in deposits, using crypto and stablecoin-related capital — which has a lot to lend because it is often fully collateralized — to serve capital-starved defense. Its ROE is deliberately low to signal conservatism to regulators; the raise exists because hitting capital ratios requires common equity — “the only way a bank can grow.”
- Santiago’s SVB-shaped challenge: is a balance sheet growing that fast filling a genuine gap, or loosening underwriting to lend into the Palmer and Anduril defense network that JPMorgan and other banks would likely serve, including a $60B company going public? Rob’s honest non-answer: “I’m not there for the underwriting… filling a hole in the market would imply they’re willing to take on certain risks other people aren’t,” and he doesn’t know how to think about “lending to a cash-flow-negative drone company.” The mitigant: deposits are growing much faster than loans.
- Context on crypto credit: since Genesis, there has been a “dearth of credit in the crypto ecosystem.” Rob says Ro is lending to crypto companies and running the crypto side of the desk, while someone else handles defense. The largest lenders today are primarily stablecoin companies, plus some activity from Alameda, FalconX, and others.
7. The gambling economy: gacha packs, Gen Z portfolios, and the transparency defense
- Collector Crypt crossed $1B in gross revenue, and Santiago says Pokémon cards were “the single best-performing asset of the last couple of months — outperformed AI, outperformed any crypto token.” He distinguishes gross from net revenue: net revenue subtracts gacha buyback repurchases. Santiago thinks Collector Crypt is “operating better than nearly any company in crypto today,” while noting that all marketplace businesses require scrutiny of revenue recognition.
- Rob strips the mechanics bare: you buy a $100 pack with disclosed EV of roughly $98–102, the platform offers instant buyback at a 15% discount to its stated valuation, and about 99.5% of users sell straight back without ever holding the card. “It’s essentially a slot machine where you always make some amount of money, it’s just EV-negative.” Claiming to like this while disliking memecoin trading “feels very disingenuous to me.”
- Santiago accepts the parallel and names the distortion: “Wall Street’s okay, but Vegas is not… Robinhood’s okay, but Fomo and Pump less so.” His constructive angle: crypto genuinely fixes collector markets — provenance, settlement, and collectors who never take delivery. BlockBar is doing this in liquor; Santiago says 80% of collectors don’t actually want to drink the bottle. NFTs could reduce the large take rates charged by marketplaces such as StockX, but verification against counterfeits is where much of the real cost lives.
- Rob’s Betterment data lands the macro point: 12% of all respondents but 26% of Gen Z say sports betting is part of their financial strategy, and 52% of Gen Z moved money they’d otherwise have invested into betting. “Financialization has just seeped into every piece of our lives… humans can get used to anything” — Robinhood was once the moral panic. Santiago’s synthesis: “if it’s going to happen, at least make it in a more transparent venue” — hence his push for the Token Transparency Act, disclosures, and market integrity, because “we’re going to have 100 times more tokens in the next 5 years” and 10-K-style integrity is what gives market participants confidence to put more money to work on-chain.
8. Closing positions: memory conviction, “everything works,” and content
- Santiago on his memory-stock book (Micron, SK Hynix, SanDisk; memory ripped 15% on the day): a five-year hold framed as the next Nvidia arc — “super boom-busty” turning secular on the AI capex wave, with H100 useful life extending beyond anyone’s prediction and 3–5-year locked-in business contracts dampening the downside. If Micron dropped 40%? “I’d load up the truck… Volatility does not concern me.” He also points to a very strong earnings season explaining all-time highs; the hiring softness is not showing up as labor shortages or cost reductions, and companies are hiring less because they hired too many people after COVID.
- Both flag the Benchmark/Vishria podcast: the internal partner debate is where AI value accrues, and his answer — “I just think everything works,” every layer of the stack makes money — plus the discipline of 18 investments in 12 years. Yanowitz wants to hear what the other Benchmark GPs think, since that cannot be the consensus view across the firm.
- Content corner: Yanowitz recommends Tony, the Bourdain prequel film (“not completely historically accurate, but that’s not the point”); Santiago got lost in Om Malik’s 30-year blog archive (om.co — “Symbolic Capitalism,” “Velocity Is the New Authority,” and other posts) after seeing people post that Malik had passed away. Also flagged: Jason reported Paolo’s claim that Tether’s first full KPMG audit of Tether International returned an unqualified clean opinion — “the largest inaugural audit in the history of finance,” though Jason said he was unsure how that was measured — and the Forbes 30 Under 30 creator was fired after allegedly taking $6M from a founder of a firm doing business with the magazine. The Hayden Adams episode and Uniswap dashboard were also flagged for Monday.