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An Introduction to FINRA’s Crypto Asset Work and the Crypto Hub

August 08, 2023

In 2022, FINRA developed an enterprise-wide strategy to ensure it is prepared for an evolving crypto asset regulatory landscape and created the Crypto Hub, the Blockchain Lab and the Crypto Asset Investigations Team

On this episode, the first in a three-part series, we sit down with Omer Meisel, Senior Vice President of the Complex Investigations and Intelligence Group, Jason Foye, Senior Director and Head of FINRA's Crypto Hub, and Reema Abdelhamid, a Director with FINRA Enforcement to learn more about the strategy and the role of the Hub and FINRA’s work to advance its mission of investor protection and market integrity.

Resources mentioned in this episode:

FINRA Blog: An Inside Look into FINRA’s Crypto Asset Work

SEC’s SPBD December 2020 Statement

SEC’s September 25, 2020 No-Action Letter, “ATS Role in the Settlement of Digital Asset Security Trades”

Crypto Asset Communications Exam Letter – November 2022

FINRA and NFA Joint Press Release

Reg Notice 20-23: Activities Related to Digital Assets

Reg Notice 21-25: Continued Engagement in Activities Related to Digital Assets

Episode 112: FINRA's Complex Investigations and Intelligence Team & Cyber and Analytics Unit

Episode 113: Regulatory Operations: Stronger Regulation Through Integrated Oversight

Episode 117: Membership Application Program

Episode 134: Gen Z Investor Attitudes

FINRA Foundation Report: Gen Z and Investing

Investor Insights: What Is a Blockchain, and Why Should I Care?

Listen and subscribe to our podcast on Apple PodcastsGoogle PodcastsSpotify or wherever you listen to your podcasts. Below is a transcript of the episode. Transcripts are generated using a combination of speech recognition software and human editors and may contain errors. Please check the corresponding audio before quoting in print. 


00:00 - 00:23

Kaitlyn Kiernan: In 2022, FINRA developed its enterprise-wide strategy to ensure it is prepared for an evolving crypto asset regulatory landscape with the creation of the Crypto Hub, the Blockchain Lab and the Crypto Asset Investigations Team. On this episode, the first in a three-part series, we sit down with three members of the Crypto Hub to learn more about the strategy and the role of the Hub.

00:23 – 00:33

Intro Music

00:33 - 01:12

Kaitlyn Kiernan: Welcome to FINRA Unscripted. I'm your host, Kaitlyn Kiernan. I'm excited to welcome three guests to today's show to kick off a three-part series introducing you to FINRA's ongoing work to ensure it's prepared to address the evolving crypto asset regulatory landscape as we work to continue to advance our mission of investor protection and market integrity. Joining us today are Omer Meisel, Senior Vice President of the Complex Investigations and Intelligence Group, Jason Foye, Senior Director and Head of FINRA's Crypto Hub, and Reema Abdelhamid, a Director with FINRA Enforcement. What they all have in common is that they're all members of FINRA's Crypto Hub. Omer, Jason and Reema, welcome to the show.

01:12 - 01:14

Omer Meisel: Hi Kaitlyn. It's great to be back on the podcast.

01:15 - 01:16

Jason Foye: Thanks, Kaitlyn. Thanks for having us.

01:16 - 01:17

Reema Abdelhamid: Thanks, echoing that.

01:18 - 01:27

Kaitlyn Kiernan: So, to kick us off, can you each introduce yourselves and tell us about your current roles at FINRA and maybe a little background about how you got here? Omer, can we start with you?

01:28 - 02:26

Omer Meisel: I'm the Senior Vice President who leads the Complex Investigation and Intelligence section within Member Supervision's National Cause and Financial Crimes department. We refer to it as the CII. And the section includes four units: the Cyber Analytics Unit, which has three groups, the Crypto Asset Investigation Group, the Cyber Security Group, and the Cyber-Enabled Fraud Group. We also have the Financial Intelligence Unit within CII, the High-Risk Registered Representative and Vulnerable Adults and Seniors Investigative Unit and the Special Investigation Unit, which has three groups: two Anti-Money Laundering groups and one Anti-Fraud Investigation group. And the last position in CII is our Treasury and U.S. Law Enforcement Engagement position. Now, in addition to leading CII, I'm also charged with leading and executing FINRA's enterprise-wide crypto asset strategy to include the Crypto Hub.

02:27 - 02:38

Kaitlyn Kiernan: Great. Thanks, Omer. And the Crypto Asset Investigations team, as a teaser will be our next episode in the series, so stay tuned for that. Now, Jason, how about you?

02:38 - 03:05

Jason Foye: Well, the audience may remember me from some previous podcasts in my role as the Head of FINRA's Special Investigations Unit that's part of the CII section that Omer just covered. Over the past eight months, I've also had the privilege of serving as the Chief of FINRA's Crypto Hub, and I know we'll get into a lot of the ins and outs of what that role looks like and what the Hub's been up to over the past eight months as part of the conversation.

03:06 - 03:08

Kaitlyn Kiernan: Thanks, Jason. And Reema, how about you?

03:09 - 04:05

Reema Abdelhamid: Hi, I'm Reema Abdelhamid and I'm incredibly excited to be part of FINRA Unscripted for the first time. As Kaitlyn said, I'm a Director in FINRA Enforcement in the Office of Counsel to the Head of Enforcement, also known as OCHE for short. And in this role, I manage a group of attorneys who work on novel and complex enforcement issues. Before my current role with OCHE, I was an enforcement attorney doing sales practice cases at FINRA for several years. And I'm a member of the Crypto Hub, and in that role, I monitor and coordinate various Enforcement teams on crypto matters and work with these teams on effective ways to investigate and appropriately resolve crypto matters. I've also worked with other members of the Hub to carry out its mission, such as providing advice on crypto matters to other departments and also working on crypto-related training.

04:06 - 04:20

Kaitlyn Kiernan: Great. Thank you. Before we dig into FINRA's work in the crypto asset space, Jason, can you provide an update on how FINRA defines crypto assets and where the crypto market is currently?

04:21 - 06:03

Jason Foye: First, FINRA defines the term crypto asset to mean any asset that is either issued or transferred using distributed ledger or blockchain technology. Overall, the crypto market has grown rapidly over the last decade and currently has a total capitalization just north of one trillion. While the overall size and capitalization is down from its high of approximately around three trillion in 2021, the market size is still significant, and in recent years we've seen increases in product offerings, increases in the types and volumes of crypto asset-related activities being conducted by FINRA member firms and associated persons, and an increase in retail investor demand and participation, especially among younger investors, as a recent report by the FINRA Foundation detailed.

And as these markets have grown and investor interest in crypto assets has increased, we've also seen instances where bad actors have exploited these markets to steal from investors through phishing scams, fraudulent offerings or other schemes. And as this audience knows, FINRA's core mission is to protect investors and promote market integrity. And this is really at the heart of everything that we do. So, as we look at the crypto asset space and think about the overall size of the market, investor participation in it and recent events such as the collapse of FTX, it really underscores for us the importance of FINRA's ongoing regulatory work related to crypto asset activities of FINRA member firms and associated persons.

06:04 - 06:22

Kaitlyn Kiernan: One of our most recent episodes was on that Gen Z FINRA Foundation study that showed how crypto is really an entry point for the youngest investors. Omer, can you share some background on why FINRA has decided to create an enterprise-wide strategy for crypto assets?

06:23 - 09:54

Omer Meisel: Absolutely. So, Jason really outlined, right, our core mission. And with that in mind, in 2022, our CEO Robert Cook, FINRA's Executive Leadership team and FINRA's Board recognized that although there were limited number of member firms approved to engage in crypto asset activity, we should take a proactive approach to be prepared to perform our regulatory mission regardless of what crypto asset regulatory regime is ultimately adopted. So, starting in the summer of 2022, FINRA's Executive Vice President of Member Supervision Greg Ruppert and myself were tasked with developing and implementing an enterprise-wide crypto asset strategy for FINRA. And as we developed this strategy, we started with a goal state, which is to establish organizational regulatory capabilities for crypto assets regardless of which regulatory regime is ultimately adopted, and leverage innovation and technology to meet our regulatory responsibilities, protect investors and safeguard market integrity.

So, to execute this strategy, we focused on three core objectives. The first objective is to enforce the current regulations. FINRA has been regulating crypto asset activities of our member firms for quite some time now. And currently, there are 26 member firms approved solely to engage in crypto asset securities business. Now the crypto asset market is seeing explosive growth and product expansion despite the recent downturn. And FINRA is committed to continue adapting our regulatory programs to protect investors in this highly dynamic environment. So, as an example, in the past year we established a dedicated group, the Crypto Asset Investigation Group, or CAI, composed of crypto asset subject matter experts to conduct risk-based examinations on crypto assets, conduct investigations related to crypto asset fraud, and serve as crypto asset subject matter experts who provide advice and consultation to other FINRA departments who encounter crypto asset issues. And as you said earlier, Kaitlyn, this will be the subject, I think, of a future podcast.

The second objective is to build for the future by establishing the Crypto Hub, which is a "one FINRA" approach that serves as a cross-department nerve center to program manage the enterprise's crypto asset activities, including developing strategy to build for potential future regulatory states, help build crypto asset market surveillance strategies, and develop staffing models and training needs to name a few initiatives.

And the third objective is to engage in blockchain innovation to support and enhance FINRA's regulatory capabilities across all product types, including crypto assets, as well as exploring the utilization of blockchain solutions in financial applications. And so, to accomplish this objective, FINRA established the Blockchain Lab within the Office of Financial Innovation, whose mission is to work in partnership with Reg Ops, which, I believe, Kaitlyn, has been a subject of a previous podcast, and refers to our operational departments, which are Member Supervision, Enforcement and Market Regulation. And the Blockchain Lab will also partner with our technology department and the Crypto Hub to develop blockchain-related regulatory initiatives, identify new technology opportunities and build blockchain expertise.

09:55 - 10:16

Kaitlyn Kiernan: We will also be talking more about the Blockchain Lab on a future episode, and we can link to our episode on the Regulatory Ops group for anyone who missed that. So, Omer just referred to the Crypto Hub as a nerve center for FINRA's activity here. How is the Hub structured and who is participating within FINRA?

10:17 - 12:15

Omer Meisel: So, let me start with the strategic vision of creating the Hub. It's not necessarily a new concept to those who have worked in our U.S. government's national security apparatus. I've utilized this methodology in various leadership roles when I was at the FBI in my work with the intelligence community to solve complex emerging issues and threats which impact an entire agency or agencies. And we've adapted the hub concept to fit FINRA structure, regulatory authority and mission. The Hub is now composed of 28 different departments from across FINRA to not only include departments from Reg Ops, but also the Office of General Counsel, Corporate Communications, People Solutions, which is sometimes called Human Resources in other organizations, Training, Office of Government Affairs and Technology, to name a few.

So, as you can see, this is truly an enterprise-wide effort. And each of these departments has at least one subject matter expert represented on the Hub. Now, when I say the Crypto Hub's role is to program manage FINRA's crypto asset work, what that means in practice is that the Crypto Hub is an organizational function that oversees a group of individual projects and initiatives linked together through shared organizational goals and objectives, thus providing synergy, consistent management and greater visibility to FINRA's executive leadership team than individually managed projects, which are much more tactical. And, as Jason said, he's the Chief of the Hub and he's like the conductor of an orchestra, who works with the various department program managers represented on the Hub to orchestrate strategy, communication, coordination and cross-enterprise crypto asset projects comprising the overall program that, together, realize our strategic goals and objectives.

12:15 - 12:49

Kaitlyn Kiernan: Thanks, Omer. I'm not sure how many of our listeners have had the chance to work in our national security apparatus, but it does remind me that we go in depth on your very interesting background prior to joining FINRA on our first episode together. So, I'll link to that, too, for any listeners who want to go back and listen. Jason, Omer had mentioned that there were 26 firms that were approved just for crypto business, but I think there's some other business lines also approved. Can you give us an overview of the types of crypto asset activities that FINRA member firms and associated persons are currently involved in?

12:51 - 16:37

Jason Foye: Sure. Kaitlyn. As Omer mentioned earlier, there are 26 firms approved solely to engage in crypto asset securities business. This includes nine firms approved to engage in the private placement of crypto asset securities, nine firms approved to operate in alternative trading system, or ATS, for crypto asset securities, seven firms that are approved to both engage in private placements involving crypto asset securities and operate in ATS for crypto asset securities and one firm that has been approved to be a special purpose broker-dealer or SPBD, under the SEC's December 2020 statement regarding the custody of digital asset securities by special purpose broker-dealers.

It's important to note for the audience that FINRA requires approval by our Member Application Program for firms engaging in material crypto asset securities business. Firms seeking approval for such a business line must provide specific information to FINRA, demonstrating that the firms meet applicable requirements under the securities laws and FINRA's Rules. And FINRA follows the SEC's guidance in assessing these proposed businesses involving crypto asset securities under applicable rules, such as the SEC's financial responsibility rules and customer protection rule.

So, for example, consistent with the requirements that have been set out by the SEC in that December 2020 statement regarding the custody of digital asset securities by SPBDs, an SPBD must operate in accordance with several SEC requirements that limit the scope of its operations and the assets for which it can provide custody service, namely to crypto asset security, specifically. In another example, again consistent with the SEC staff’s, in this case, ATS No-Action letter, an ATS seeking to facilitate secondary market transactions in crypto asset securities pursuant to the "three-step model" must meet heightened requirements, including certain net capital requirements compared to firms that are seeking to facilitate secondary market transactions in crypto asset securities pursuant to the "four-step model" as laid out in that ATS No-Action letter. We can definitely provide links to some of the relevant guidance documents in the show notes, and the audience can also check out that recent FINRA Unscripted episode that you all did with the MAP program that really digs into the process for reviewing and approving firms with material crypto asset securities business lines.

In addition to these firms, it's also important to note that FINRA has previously issued Regulatory Notices, namely Regulatory Notice 20-23 and 21-25 to ask our member firms to notify us if they or their affiliate engage in or plan to engage in crypto asset-related activities, including activities related to crypto assets that are not securities. To date, FINRA has identified approximately 200 member firms as having some direct or indirect touchpoint to crypto asset activities. This includes proprietary trading businesses and distributed ledger technology initiatives. And in certain other business models, we're seeing member firms that have established relationships with either affiliates or unaffiliated third parties to grant their customers access to crypto asset activities. Lastly, just beyond the scope of what our member firms are doing in the crypto asset space, FINRA has also identified numerous associated persons who are engaging in a range of crypto asset-related activities through either an outside business activity or private securities transaction.

16:39 - 16:51

Kaitlyn Kiernan: So, when thinking about ensuring compliance with existing rules and regulations, how do FINRA Rules apply to the crypto asset activities and conduct of the member firms and associated persons that Jason was just telling us about?

16:51 - 18:11

Reema Abdelhamid: So, this is an important question because much of the audience has no doubt heard much of the discussion out there coming from media regulators and others about whether crypto assets are securities. And the resolution of those questions is going to depend on many factors, lots of analysis to come and may not be known for some time. Certainly, there's some FINRA Rules that by their language, only apply if a crypto asset is a security. That being said, there are a number of FINRA Rules that apply regardless of whether the crypto activity in question is deemed to be a securities activity. And I just want to highlight a few of those here for the audience. One of them, FINRA Rule 3270, which concerns outside business activities, is applicable to a wide range of activities beyond securities. Also, FINRA Rule 2210, FINRA's advertising regulation rule concerning communications with the public. That, too, applies to communications regarding non-securities products. And perhaps most importantly, FINRA Rule 2010, which concerns commercial honor and just and equitable principles of trade, that rule applies in both the securities and non-securities contexts.

18:12 - 18:21

Kaitlyn Kiernan: Great. Thanks for that overview. And where is FINRA seeing potential violations of its rules when it comes to crypto asset activities?

18:21 - 21:15

Reema Abdelhamid: So, there are actually quite a few areas in which FINRA has seen potential misconduct. And to begin with, FINRA has already charged violations of FINRA Rule 3270, which is, as I said, the outside business activity rule and FINRA Rule 3280, private securities transactions, in the crypto space. And that's again for failures related to outside businesses and private securities transactions. That's unsurprising, perhaps, given the level of activity Jason flagged in these areas. We continue to see these rules coming up quite frequently in our ongoing crypto investigations.

Also coming up with some frequency is the supervision rule, which is FINRA Rule 3110. And this is for failures to conduct due diligence on crypto asset private placements. And this is an area where we're very much focused, given also, the risk of fraudulent offerings. The AML rule has also come into play in a lot of our investigations. That's FINRA Rule 3310. When firms fail to establish reasonable AML programs, when the crypto asset activities are occurring by, at, or through the member firm.

And now I want to shift gears a bit and discuss what we're seeing in the context of a more targeted advertising regulation investigation. And specifically, our Ad Reg department has focused on the crypto asset-related communications by the broker-dealer or an affiliate of 17 member firms for an approximately three-month period. And for those who are interested, you can find the November 2022 Crypto Asset Communications Exam letter on the FINRA website. This examination looked at different aspects of the advertising materials to evaluate disclosures in these materials, and the preliminary results have shown certain patterns.

We're just going to give a couple of examples here. One is a failure to balance communications with respect to the risks associated with crypto asset securities. And another is that broker-dealers, in some instances, are being falsely identified as the entity offering the crypto asset product. And of course, this is problematic because customers reading those materials may not understand the degree to which they're leaving a regulated space, the member firm space, and entering into an unregulated one, that of an affiliate of a third-party intermediary.

And just one more thought. In the crypto space, generally, we've also barred associated persons for violations of FINRA Rule 8210 for failing to produce records or give testimony related to crypto asset activities.

21:17 - 21:24

Kaitlyn Kiernan: Thanks, Reema. That's a really interesting overview. Are there any other efforts FINRA's taking in this area that we want to highlight right now?

21:25 - 22:12

Reema Abdelhamid: So, we have been doing quite a bit of market surveillance and investigating pump and dump schemes in the crypto space. Also, investigating market abuse involving crypto asset securities traded on alternative trading systems that Jason referred to earlier. And also, perhaps, another area we haven't touched upon yet is that of referrals. FINRA has made and continues to make referrals to other regulators and agencies on fact patterns related to crypto that for one reason or another, may be outside of our jurisdiction. And these referrals are critical, frankly, to make sure that all misconduct is pursued by the entity in the best position to pursue it.

22:13 - 22:28

Kaitlyn Kiernan: Good to know. So, Omer mentioned that one of the key parts of the enterprise-wide crypto strategy is building for the future. Jason, what does the Hub's work in this area focusing on the future look like?

22:28 - 25:35

Jason Foye: When we kicked off the Hub, we initiated a few parallel paths to help us build for the future. The first was working with our partners in Risk Monitoring, Firm Examination, National Cause and Enforcement, just to name a few, to gain a granular understanding of the types of crypto asset activities that our member firms and associated persons were engaging in, in order to set a solid foundation on which we could anchor our efforts to enhance our capabilities. At the same time, we kicked off assessments of our regulatory processes to look at how we factor crypto asset-related activities into these functions. This included considering the potential risks each of the different crypto asset business lines may present to investors and markets, what data and intelligence was available that could help FINRA make risk-based decisions with respect to its regulatory work in this area, and as Omer previously mentioned earlier, assessing our staffing and expertise needs in this space and, where needed, bringing crypto asset expertise in-house to FINRA.

We've also looked at our technology needs and are actively assessing and developing new investigative tools specific to crypto asset activities in order to enhance our capabilities in that area. The Blockchain Lab that Omer mentioned earlier is one of the leading groups within FINRA on that front, and I don't want to spoil the future podcast on that one, so I'll just encourage the audience to tune in to that future episode to hear more about the ongoing work that they're helping to lead internally here at FINRA. We've also engaged in a broad effort with our partners in market regulation and transparency services to assess and, where needed, enhance FINRA's market surveillance capabilities with respect to crypto assets.

We recently formed a dedicated crypto asset surveillance team that's going to be leading our efforts on this front in coordination with different groups across the organization and with the Hub. There's so much going on right now at FINRA with respect to crypto assets, I certainly can't cover all the incredible work that's being done across the organization in such a short amount of time. But if I can maybe squeeze in one more item into the discussion, it would be the development of a new enterprise-wide training program, which has already produced new, self-paced training pathways within FINRA, held an internal training conference where FINRA subject matter experts provided targeted in-person training to FINRA staff from across the organization and in the near future will include advanced training for examiners, investigators and other FINRA staff that's focused on the development of a advanced proficiency with respect to a range of different crypto asset investigative tools that are currently being deployed or built within the organization.

This training program, more so than a lot of the other projects that are ongoing, is one that we expect to continue to pay dividends for FINRA as we think about building up our capacities and enhancing our abilities to fulfill our regulatory mission with respect to crypto assets.

25:36 - 25:45

Kaitlyn Kiernan: Just as FINRA staff might be expected to know about stocks, bonds, private placements, they're going to be expected to know about crypto as well.

25:45 - 25:46

Jason Foye: Exactly.

25:46 - 25:56

Kaitlyn Kiernan: So, Reema mentioned making referrals when information is outside FINRA's jurisdiction, but how else is FINRA engaging with other regulators and agencies in this space?

25:57 - 27:32

Jason Foye: Since the Hub was created, we've worked with our partners in FINRA's Office of Government Affairs, Office of International Affairs, Office of Regulatory Liaison and Office of Financial Innovation to engage with other state, federal and international regulators and agencies to discuss crypto asset regulatory efforts and developments. We've also spent a lot of time meeting with member firms and other industry participants to understand the types of activities that they're currently engaging in, the activities they plan to engage in, and other crypto asset-related issues that may be occurring.

I think one example of FINRA's regulatory coordination efforts in this space was the FINRA NFA Crypto Summit, which we hosted in our San Francisco office. At the summit, crypto asset and blockchain experts from both FINRA and the National Futures Association, or NFA, met to share regulatory intelligence related to crypto assets, discuss potential risks and supervisory obligations associated with crypto asset-related activities and the importance of investor protection in the space. As a result of the summit, FINRA and NFA agreed to expand our existing Memorandum of Understanding to address information sharing and collaboration regarding crypto assets, blockchain technology developments and crypto asset regulatory risks, which we believe will help both organizations fulfill our respective regulatory missions. And FINRA and the NFA issued a joint press release if the audience is interested in reading a little bit more about that summit.

27:33 - 27:53

Kaitlyn Kiernan: Great, and we can link to that in the show notes. As we've mentioned, we're going to have a couple more episodes in this series, so don't want to spoil what's to come in those. But just to wrap up on this first intro episode, Omer, how do you plan to share information and learnings from the Crypto Hub with firms in the future?

27:53 - 28:50

Omer Meisel: It's one of the things that we're very focused on and we are looking at every possible way of sharing that information. And so, we have a bunch of different ways in which we do that. FINRA Unscripted podcast is one avenue, but we're also, at FINRA conferences, are going to highlight the work we're doing within the crypto asset space, we'll be involved in industry conferences, we'll be involved with member firm committee meetings, issuing Reg Notices and alerts and other communications tailored to this asset class. And we're also partnering with Investor Education, who also has a representative on the Crypto Hub to provide investors critical information about the risks associated with investing in crypto assets. All those different formats will be tailored to get more and more information out there.

28:51 - 29:00

Kaitlyn Kiernan: So, our listeners can stay tuned. And if they see any of your names on a conference agenda, don't sleep on the opportunity to register.

29:01 - 29:01

Omer Meisel: Exactly.

29:02 - 29:06

Kaitlyn Kiernan: How do you see the role of the Crypto Hub evolving from here?

29:07 - 30:22

Omer Meisel: Kaitlyn, there are so many different, exciting and important initiatives and projects that are either currently ongoing or being developed. And so, we look forward to providing more information about those initiatives in the future. And Jason highlighted one of those initiatives, which is the establishment of a dedicated crypto asset surveillance team and market regulation. So, just another example of how we continue to lean forward and be proactive in our work here. The future of crypto assets and crypto asset regulation is still in flux and FINRA does not play a role in determining the final state of crypto asset regulation itself.

However, FINRA is committed to this work and ensuring that whatever the future holds, we are prepared to fulfill our regulatory mandate and advance our core mission to protect investors and safeguard market integrity. And as the blockchain technology creates new potential financial solutions, we will be prepared to grow and adapt to any of those potential changes. And finally, I'd be remiss if I didn't point out how incredible it is to watch the organization embrace the strategy I outlined today and see firsthand how dedicated, collaborative and innovative our employees are in this space.

30:23 - 30:59

Kaitlyn Kiernan: Awesome. Thanks, Omer. Well, that's it for today's episode of FINRA Unscripted. Omer, Jason and Reema, thank you so much for joining me to introduce us to FINRA's enterprise-wise crypto asset strategy and the Crypto Hub. Listeners, if you don't already, you definitely need to subscribe to FINRA wherever you listen to podcasts so you can stay up to date when the next episodes in this series post. We'll be taking a break at the end of August, but we'll be back with the next episode right after Labor Day. Today's episode was produced by me, Kaitlyn Kiernan, engineered by John Williams and coordinated by Hannah Krobock. Until next time.

30:50 – 31:05

Outro Music

31:05 - 31:32

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