Accounting for Crypto

The period leading up to June 30 saw the usual raft of end of financial year updates, special offers and reminders from equipment suppliers, business service providers, accountants, tax specialists and even the ATO itself.

Crypto is certainly getting a lot of attention in Australia at the moment.

First, there is a Senate Select Committee on Australia as a Technology and Financial Centre, including “opportunities and risks in the digital asset and cryptocurrency sector”. The Select Committee is also looking at ways to define and/or potentially regulate crypto assets.

Second, ASIC has launched a public consultation process on crypto ETFs. This follows a desire from the regulator for more policy guidance from the Federal Government on the “regulatory perimeter” for crypto assets.

Third, the CPA published an op ed on the need for more clarity in crypto asset accounting. Not just in Australia, but across the world of International Financial Reporting Standards.

None of this should be surprising, as governments, regulators, tax authorities, professional bodies and institutional investors are still struggling to comprehend this new asset class, and the technology that underpins it.

Do crypto and digital assets represent currency, commodity, real estate, software license, network membership, utility access, payment mechanism, store of value, financial security, or unique property rights? Depending on the design, use case and origination of a token and its economic properties, the answer could be “yes” in each case – albeit not all at the same time.

In my consulting work with Brave New Coin, I get to speak to clients on a daily basis about their own crypto activities – be they exchanges, asset managers, accountants, tax authorities, regulators or investors. A lot of the discussion involves education – helping them to make sense of the technology and its potential. Some of the time they are simply asking our advice about how to address a particular issue, or they need a recommendation for a custodian or broker. A few share the regulatory challenges they face, and seek our perspective in how to navigate them. Others need more technical help, in building software solutions, or with on-chain analysis and wallet tracking (even though “free” block explorers already do a pretty good job in that regard). While many simply need a source of market data and indices for price discovery and NAV calculations, or a process to capture and track the crypto equivalents of corporate actions.

If anyone wonders how we are doing to make the reporting of crypto holdings as simple as equities or fixed income assets, my own experiences suggest we have a way to go. Legacy accounting and portfolio tools struggle with crypto: for example, can they calculate to 8 decimal places? how do they deal with an air drop? and how do they distinguish between Ether and Ethan Minerals (both use ETH as their ticker symbols), or Cardano and Adacel Technologies (both use ADA). And if I am an accountant, auditor, financial planner or adviser, how can I make sure I understand my clients’ portfolio of crypto investments, if I don’t have the appropriate tools?

Next week: Goya – allegories and reportage for the modern age

Notes from Blockchain Week

Blockchain Australia, the national industry body, recently organised the first National Australian Blockchain Week – a mix of on-line and in-person events, hosted in Sydney and Melbourne. Overall, it was an impressive line up of speakers and topics, featuring key local figures and presenting some intriguing announcements from politicians, regulators and practitioners alike.

The recurring themes were: Regulation, Tax and Innovation.

Despite past pronouncements about adopting a light-touch regulatory regime when it comes to Blockchain technology, the absence of definite regulation risks stifling innovation and/or driving projects overseas to more receptive jurisdictions. (Irony of the week #1: contrast this with the early and positive regulatory engagement with Digital Currency Exchanges (DCE) and other market participants in Australia, not to mention previous progress in removing the absurd GST treatment on the purchase and sale of cryptocurrencies).

Now, the industry is (once again) asking policy makers: to clarify the law as it relates to decentralised protocols, digital assets and utility tokens; to streamline the confusing and over-complex tax system as it applies to DeFi: and to define a specific regulatory boundary (rather like the UK’s FCA perimeter) within which crypto assets need to be regulated. Sadly, the latter is extremely hard to acheive thanks to the very broad definition of “financial product” within the Australian Corporations Act.

Throughout the four days, there were several highlights: Senator Bragg’s keynote speech on driving the policy agenda to bring clarity to regulators and markets alike; a progress report on the National Blockchain Roadmap; tax and legal updates from Joni Pirovich and Michael Bacina; a showcase of local Blockchain start-up projects (more on that next week); and a couple of enterprise presentations on the ASX’s DLT replacement for CHESS and the Blockchain-based insurance project between the R3 consortium and Grow Super. But apart from a couple of other Blockchain-in-business sessions, there was a noticeable absence of corporates, major banks, traditional financial services and institutional investors.

There was a lot of commentary around the fact that many Blockchain businesses and crypto projects still find it challenging to access regular banking facilities in Australia (Irony of the week #2: Westpac’s windfall from the recent Coinbase IPO). There was also a lot of discussion about the need for investor education before crypto and digital assets can go “mainstream” – which I find surprising when plenty of people seem to be finding their way without any help from traditional financial advisors, and yet no-one is required to educate themselves before their money is put into compulsory superannuation or real estate assets. Even where crypto assets are being included in retail investor products, the allocation is very modest and is being transacted offshore (see Raiz’s 5% allocation via the US-based Gemini Trust). Why not use one of the several established and well-run exchanges, crypto funds and OTC providers here in Australia?

Regarding the potential offshore brain drain, much was made of the work that Singapore is doing to attract Blockchain and crypto businesses. But I think the focus on Singapore risks overstating the situation there, and overlooks what is actually happening (and could happen) in Australia. For example, while Singapore may have more favourable tax arrangements for new Blockchain projects, I understand that ordinary retail investors don’t have access to crypto funds (not even ETPs). The Singaporean issuance of digital assets via tokenisation has to be done via an SPV structure. And while many ICOs have been issued from Singapore, they could not be marketed to local investors. At least Australia has a robust DCE sector, e.g. Independent Reserve, BTC Markets, and Bit Trade (now part of Kraken); early on we saw some very successful retail products such as CoinJar; and the local industry continues to nurture innovative decentralisation projects – we just need to sort out those “policy settings”, and give more encouragement to local entrpreneuers and innovation. (Irony of the week #3 – when former ALP politician and self-styled crypto OG, Sam Dastyari, was asked if the private equity fund he works for was investing in Blockchain or crypto, there was a deafening silence…)

Finally, one of the main benefits of Blockchain Week has been to entice people out of hibernation, and to attend in-person events after months of lock-downs and restricted movement. It felt good to be back.

Next week: Blockchain Start-up Showcase

FinTech Australia Road Show

This week I had hoped to blog about the latest FinTech Australia Road Show in Melbourne – unfortunately, COVID-19 intervened, and the event has been postponed.

So instead, here is my personal quick take on recent developments in the local FinTech scene:

A tale of 2 neobanks

Maybe Australia isn’t ready for challenger banks, despite the early interest and apparent market demand. Xinja* has decided to give back its banking license, having spent a ton of money on obtaining it in the first place. It couldn’t sustain savings and deposit accounts (even in a low-interest rate environment) without sufficient regulatory capital, the funding for which has failed to materialise; and without deposits, Xinja couldn’t offer loans. There is talk of launching a US share-trading app instead (à la Robinhood) but given the recent shenanigans with Wall Street Bets, Reddit, hedge funds and GameStop day traders I don’t suppose the regulatory path to market will be that easy. Xinja looks like it’s done.

Meanwhile, NAB has just announced that it is acquiring the shares in 86 400 that it does not already own, in order to merge it with NAB’s digital brand, Ubank. Which further suggests neobanks can’t survive on their own in the Australian market, with the dominant and regulatory protected cartel of the Big 4. (My good friend Alan Tsen has described this latest transaction as a turducken….)

Other challenger brands in Australia are having to take different approaches: Up is piggybacking off Bendigo and Adelaide Bank’s ADI license; Volt describes itself as a BaaS provider (“banking as a service”); Judo is focused on business banking; and the UK’s Revolut is bringing a mix of credit cards, payment solutions and forex services (including crypto), rather than transaction banking. Meanwhile, another BaaS from the UK, Railsbank is currently recruiting locally for a GM to leads its Australian roll-out.

Finally, despite some concerns about the BNPL sector (“buy now, pay later”), Afterpay is partnering with Westpac‘s BaaS platform to offer banking services to its customers.

Whither the Big 4?

Speaking of which, what are the Big 4 doing in the broader sphere of FinTech?

Despite (or because of?) buying a neobank, NAB has apparently closed down the Labs part of NAB Ventures, the often-mentioned, but largely silent startup incubator. CBA has created X15, a similar FinTech ventures platform with the ambitious goal of launching 25 businesses in 5 years (I seem to recall NAB Ventures once had a similar mandate?). Westpac‘s own FinTech fund, Reinventure is expected to do well out of the forthcoming Coinbase IPO; so much so that Reinventure is planning to decouple from Westpac, and launch a new fund focused on DeFi opportunities. ANZ has been putting out some commentary on its ANZi platform for FinTech innovation and partnerships – but its remit is limited to trade finance, home ownership and open data, and it is being very coy as to what specific bets they are making. Ho hum.

Did somebody mention crypto?

In case you hadn’t realised, we are experiencing something of a bull market in crypto.

Coinspot just announced they have 1,000,000 customers. Raiz Invest has launched its retail savings portfolio product with a 5% allocation to Bitcoin. Other funds like Every Capital are planning similar retail offerings. Luno is advertising on Melbourne’s tram shelters. And the Australian division of eToro is talking up DeFi. Game on!

Next week: Transition – post-pandemic career moves

* Declaration of interest – the author participated in the Xinja equity crowd-sale a few years ago

The Limits of Technology

As part of my home entertainment during lock-down, I have been enjoying a series of Web TV programmes called This Is Imminent hosted by Simon Waller, and whose broad theme asks “how are we learning to live with new technology?” – in short, the good, the bad and the ugly of AI, robotics, computers, productivity tools etc.

Niska robots are designed to serve ice cream…. image sourced from Weekend Notes

Despite the challenges of Zoom overload, choked internet capacity, and constant screen-time, the lock-down has shown how reliant we are upon tech for communications, e-commerce, streaming services and working from home. Without them, many of us would not have been able to cope with the restrictions imposed by the pandemic.

The value of Simon’s interactive webinars is two-fold – as the audience, we get to hear from experts in their respective fields, and gain exposure to new ideas; and we have the opportunity to explore ways in which technology impacts our own lives and experience – and in a totally non-judgmental way. What’s particularly interesting is the non-binary nature of the discussion. It’s not “this tech good, that tech bad”, nor is it about taking absolute positions – it thrives in the margins and in the grey areas, where we are uncertain, unsure, or just undecided.

In parallel with these programmes, I have been reading a number of novels that discuss different aspects of AI. These books seem to be both enamoured with, and in awe of, the potential of AI – William Gibson’s “Agency”, Ian McEwan’s “Machines Like Me”, and Jeanette Winterson’s “Frankissstein” – although they take quite different approaches to the pros and cons of the subject and the technology itself. (When added to my recent reading list of Jonathan Coe’s “Middle England” and John Lanchester’s “The Wall”, you can see what fun and games I’m having during lock-down….)

What this viewing and reading suggests to me is that we quickly run into the limitations of any new technology. Either it never delivers what it promises, or we become bored with it. We over-invest and place too much hope in it, then take it for granted (or worse, come to resent it). What the above novelists identify is our inability to trust ourselves when confronted with the opportunity for human advancement. Largely because the same leaps in technology also induce existential angst or challenge our very existence itself – not least because they are highly disruptive as well as innovative.

On the other hand, despite a general shift towards open source protocols and platforms, we still see age-old format wars whenever any new tech comes along. For example, this means most apps lack interoperability, tying us into rigid and vertically integrated ecosystems. The plethora of apps launched for mobile devices can mean premature obsolescence (built-in or otherwise), as developers can’t be bothered to maintain and upgrade them (or the app stores focus on the more popular products, and gradually weed out anything that doesn’t fit their distribution model or operating system). Worse, newer apps are not retrofitted to run on older platforms, or older software programs and content suffer digital decay and degradation. (Developers will also tell you about tech debt – the eventual higher costs of upgrading products that were built using “quick and cheap” short-term solutions, rather than taking a longer-term perspective.)

Consequently, new technology tends to over-engineer a solution, or create niche, hard-coded products (robots serving ice cream?). In the former, it can make existing tasks even harder; in the latter, it can create tech dead ends and generate waste. Rather than aiming for giant leaps forward within narrow applications, perhaps we need more modular and accretive solutions that are adaptable, interchangeable, easier to maintain, and cheaper to upgrade.

Next week: Distractions during Lock-down