Brooks’ calendar of appointments, obtained by CoinDesk through a Freedom of Information Act (FOIA) request, sheds new light on his seven-and-a-half month tenure leading the Office of the Comptroller of the Currency (OCC), the regulator for national banks. (The calendar was partially redacted under exemptions related to internal personnel rules, agency practices, trade secrets, commercial or financial information and personal information.) Those meetings involved a wide range of participants in the crypto market, from executives of Fortune 500 companies to founders of decentralized finance (DeFi) protocols.
During this time, the former Coinbase executive pursued an aggressively crypto-friendly agenda, releasing interpretive letters that gave traditional financial institutions the green light to get involved in digital asset custody, staking and stablecoins. The Trump appointee came under criticism from congressional Democrats for spending so much time on crypto during the coronavirus pandemic.
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After leaving the OCC in mid-January, he rejoined the industry as CEO of Binance.US, the global crypto exchange’s stateside affiliate.
“At the time Mr. Brooks was appointed to the OCC, the U.S. government on an interagency basis had been working on digital assets for years,” an external spokeswoman for Brooks and Binance.US said in an email. “The Federal Reserve’s work on a ‘digital dollar,’ the [Commodity Futures Trading Commission’s] work on bitcoin futures, the [Securities and Exchange Commission’s] work on securities regulation, and banks’ increasing interest and participation in stable coin projects and other digital assets predated Mr. Brooks’s arrival at the OCC and will undoubtedly continue.”
Stablecoins on agenda
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His first crypto-related meeting as acting comptroller, with blockchain lending startup Figure, came on June 12, 2020, 15 days after he was appointed by then-President Donald Trump. That was followed that day by a meeting titled “Innovation/Crypto Currency Discussion,” which was then immediately followed by a call to Sen. Mike Crapo (R-Idaho), who heads the Senate Banking Committee. It is not clear if that call was about digital assets, but Rep. Tom Emmer (R-Minn.) did discuss “crypto issues” with Brooks on Nov. 16.
It’s also in this calendar that we get a glimpse of some of the first interagency work on stablecoins, as Brooks had a meeting about stablecoins with the President’s Working Group on Financial Markets. Six months after his departure from government, stablecoins are now a flashpoint of controversy, with several major U.S. financial regulators publicly calling for the pegged digital assets to be regulated.
Brooks also met with license applicants including Paxos and Anchorage, which were both granted a national trust charter, and First Blockchain Bank and Trust (a subsidiary of Metal Pay) and Figure, which both have applied for a full national bank charter.
He also met with some fintech heavyweights, including PayPal CEO Dan Schulman, Facebook executive David Marcus and officials from peer-to-peer lending platform SoFi and U.K. digital bank Revolut. It was not clear whether crypto was discussed in any of those meetings. But Marcus is Facebook’s blockchain lead and PayPal started a digital asset service in 2020. SoFi has a digital assets trading unit. Revolut has offered crypto trading services since 2017. Brooks also had a meeting with the Treasury Department to discuss Facebook’s controversial stablecoin project Libra, now called Diem.
The former acting comptroller also made sure he got input from the budding decentralized finance (DeFi) market, and one of his last meetings at the OCC was a “staking discussion” on Jan. 10. In August 2020, Brooks’s “prep for 8/21 OCC management conference” included a call to Compound founder Robert Leshner. About two months later he held a meeting titled “MakerDAO call.”
Compound is one of the leading decentralized lending protocols on the Ethereum platform. Loans on Compound are extended in a permissionless way, with borrowers only needing to post the right amount of crypto collateral. MakerDAO is a protocol that takes ether, USDC or BAT holdings as collateral for a dollar-pegged stablecoin called dai that’s minted specifically for MakerDAO loans.
Following is a full list of the former acting comptroller’s meetings that either include stakeholders in the crypto industry or companies that have a digital assets unit:
Again, these meetings foreshadowed policy debates to come, as Sen. Elizabeth Warren (D-Mass.) has recently asked President Biden’s Securities and Exchange Commission (SEC) chairman, Gary Gensler, how Congress can empower regulators to rein in DeFi.
Interview with Cointelegraph’s Kollen Post on June 4, 2020.Interview with CoinDesk’s Nik De on June 5.An appearance on The Block’s “The Scoop” on June 10.Outside of press interviews, Brooks’ first crypto-related meeting was on June 12 with blockchain lending startup FigureThe first agency meeting about cryptocurrency (“Innovation/Crypto Currency [sic] Discussion”) occurred later on June 12.Brooks traveled to Figure’s offices on July 7 and met with CEO Mike Cagney.An early morning call with David Marcus, blockchain lead at Facebook, on July 31 followed by a “Crypto meeting” with OCC officials. Also a call with Marcus on the evening of Nov. 16.Another “Crypto Meeting” with OCC officials on August 11A Robert Leshner call on August 12 that’s supposed to be “prep for 8/21 OCC management conference.” A call with Chris Giancarlo, the former CFTC chairman and digital dollar advocate on Aug. 17 is also part of this prep.An appearance on Circle CEO Jeremy Allaire’s podcast “The Money Movement” on Aug. 13.He participated in a “Cryptocurrency Industry Meeting” on Aug. 25 led by Xapo’s Wences Casares.Meeting with Revolut on Sept 2.“Treasury Libra Meeting” held on Sept 14.“Stable Coins Follow-Up” on Sept. 15 with OCC officials.Industry lobbyists Coin Center on Oct. 2 and Oct. 8Paxos on Oct. 6Polychain Capital on Oct. 7Bitpay on Oct. 7 and also on Dec. 15Maker DAO call with OCC officials on Oct. 8Anchorage on Oct. 23Investor Mike Novogratz on Nov. 5Regulatory panel for Credit Suisse’s Blockchain and Digital Assets Symposium on Nov. 11“Future Interpretive Letters on Crypto” with OCC officials Nov. 11Interagency virtual meeting on stablecoins on Nov. 12A call with Rep. Tom Emmer (R-Minn.) on “crypto issues” on Nov. 16.“PWG StableCoin” on Dec. 9.Jeremy Liew, partner with Lightspeed Venture Partners, on Dec. 11.“Trust Bank Applications” call on Dec. 14“Novel Charter Set-up” with OCC officials on Dec. 16 and Dec. 29PayPal CEO Dan Schulman on Dec. 18Wyoming blockchain advocate and Avanti Bank founder Caitlin Long on Dec. 18Teddy Fusaro from Bitwise on Dec. 18“First Blockchain Bank” on Jan 6“Figure and OCC” on Jan. 7.“staking discussion” on Jan. 10.Valor Roundtable: Digital & Cryptocurrencies” on Jan. 11.Elliptic webinar on Jan. 13
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