重写规则：SEC与CFTC论加密货币、IPO及美国市场未来

好了，各位。

Alright, everybody.

欢迎来到全方位访谈节目。

Welcome to the all in interview program.

今天，我们非常荣幸地邀请到两位在未来几年内塑造资本市场的重要人物。

Today, we are delighted to have two of the most important individuals shaping capital markets over the next couple of years.

美国证券交易委员会主席保罗·阿特金斯和商品期货交易委员会主席迈克尔·塞利格与我们同在。

SEC chair Paul Atkins is with us as well as CFTC chair Michael Selig.

欢迎来到全方位访谈节目，两位先生。

Welcome to the All In interview show, gentlemen.

很高兴能来这里。

Glad to be here.

非常高兴。

Very much.

很高兴能在这里。

Great to be here.

是的

Yep.

同时在我身边的是我的好友查马斯·帕利哈皮蒂亚，他以参与资本市场而闻名。

Also with me, my bestie, Chamath Palihapitiya, who is known to participate in capital markets.

我认为我们这里有一个很好的结构来进行讨论。

I think there's a great structure here for us to talk.

在这个充满活力的时代，有许多机会，同时也有一些我们需要关注的监管框架和问题。

Many opportunities and then guardrails and things that we should be concerned about in such a dynamic time.

阿特金斯主席，这是您自九十年代以来第三次担任这一职务。

Chairman Atkins, this is your third tour of duty since the nineties.

情况已经发生了巨大变化。

Things have changed dramatically.

所以，也许我们先从这里开始，我知道查马斯准备了很多精彩的问题。

So maybe just to start us off here, and I know Chamath's got a lot of great questions ready to go.

我只是好奇，在您过去的四十年左右时间里，您观察到资本市场发生了哪些变化？

I'm just curious, in your time, let's say the last forty years or so, what has what have you noted here about capital markets and how they've changed?

那么，对我们未来而言，什么是重要的？

And what's important for us looking forward?

谢谢。

Well, thanks.

很高兴今天能在这里见到你们两位。

It's great to be here and see both of you all today.

我最初在八十年代中期作为一名年轻律师在纽约从事公司金融工作，比如新股发行之类的业务。

Well, so I started out as a young lawyer in New York City doing corporation finance work, you know, new offerings and that sort of thing in the mid eighties.

那时候，如果你想创办一家初创公司，开发产品、进行研发，就必须上市，像苹果、微软、超威半导体这些公司，最初都是通过IPO起步的。

And and it's and there, you know, to to be a startup company and to to build your products and do r and d and all that, you had to go public in order to so Apple and Microsoft, advanced micro devices, all of those companies started off as as, you know, IPOs.

安德里森·霍罗维茨有一张非常棒的柱状图，对比了八十年代早期到中后期的公司与今天的公司，它清楚地展示了早期公司内部人士与公众股东在投资回报率上的差异——当时几乎没有私募股权或风险投资。

And so Andreessen Horowitz has a really, I think, a really good bar chart where they compare the companies of the early and mid to late eighties to, today where I mean, it just basically demonstrates through the ROI that, insiders versus the buyers of, the public stock, you know, enjoyed from those early companies, the insiders, meaning, you know, there's not much private equity, or venture capital back then.

但所谓的内部人士，也就是高管、董事等人，他们所占的股份比例相对较小。

But the insiders, meaning the the officers, directors, whatnot, they had a relatively thin slice of the entire pie.

我的意思是，当然，每个人都能赚到钱。

I mean, everyone made out well, obviously.

但公众投资者在IPO中购买股票，多年来获得了非常丰厚的回报，占据了绝大部分收益。

But the public, purchasers of in the IPO, you know, made out very well over the years and then had the lion's share of that.

看看今天的情况，我们如今拥有强劲的私人资本市场，而上市公司数量仅为三十年前的一半，情况完全颠倒了。

You look at today, the current situation where, you know, we have robust private capital markets and, we have fully today half the number of public companies as we had thirty years ago, and it's completely reversed.

投资回报主要流向了内部人士、私募股权、风险资本以及公司高管和员工，而非公众投资者，因为这些公司上市时已经相当成熟了。

The return on investment is, you know, mainly to the insiders, private equity, venture capital, and the corporate officers and employees versus the the public because they're they're mature companies when they actually go public.

这是一个巨大的变化。

So that's a huge change.

私人市场非常强劲和活跃，但无论如何，我认为美国的资本市场依然非常健康。

The private markets are very robust and and strong, but but, anyway, but the American capital markets are are very healthy, I think.

当你回望过去，那时每个人都必须投入大量工作，因为正如你所说，这些公司还非常年轻。

When you look at that back then, there was a real requirement for everybody to do an enormous amount of work because to your point, these companies were quite young.

那时你可能是一家只有四五年的公司，上市并不是为了套现。

You'd be a four or five year old company, and you'd go public because the going public was not about monetizing anything.

上市实际上是一次融资机会。

It was actually a fundraising moment.

这就像一轮C轮或D轮融资。

It was like a series c or or a series d.

我想答案是，发生变化的原因可能是，正如你所说，这些回报太多了。

I guess the answer is the reason it changed was probably because, to your point, there's all these returns.

因此，投资者说，好吧，让我们在私募市场中为 ourselves 和我们的有限合伙人捕获这些回报。

And so investors said, well, let's go capture these in the private markets for us and our LPs.

但这也改变了这些市场行为的性质。

But what it also does is then change the nature of how these markets behave.

你能评论一下公司保持私有状态的时间越来越长、IPO数量减少的现象吗？因为如今IPO更多是流动性节点，而不仅仅是融资节点。你认为这种情况是否应该改变？如果应该，你希望如何改变？为什么？

Can you just comment on the amount of time companies are staying private, the dearth of the IPO because it has become a liquidity defining moment and is much more so than the financing moment, and whether things should change and if so, how do you wanna change that and why?

是的。

Yeah.

这毕竟是一个自由市场，显然，投资者应该让市场按其自身规律发展，但你说得完全对。

Well, it's a free market, obviously, so, you know, investors, we should allow the market to develop as it will, but, you're exactly right.

所以现在它更多地成为内部人士的流动性事件。

So now it's more of a liquidity event, for insiders.

所以我们现在看到，在私募市场中，有大量的资本愿意投入到早期阶段的公司，并持续持有。

And and so what we are seeing now is, in the private markets, you know, there's a lot of capital that's, where people are willing to deploy it to companies at early stages and then to to stay on.

但与此同时，私营公司上市却面临诸多障碍，其中之一就是遵守我们规则和披露要求的成本，尤其是每年必须提交的年报、委托书声明等繁重要求。

But at the same time, there is there are inhibitions for for private companies to go public, and one of them is the the, the cost of our rules to comply with our rules and the disclosure ones, especially where you have all the annual report requirements, proxy statements, and all of that.

还有季度报告等等这些负担。

And so, and the quarterly reporting and and so forth.

因此，这是一个巨大的障碍，导致企业不再专注于实质性信息。

So that is one big inhibition where things are not necessarily focused on materiality anymore.

你能否召集一群人，逐项审查或修改这些规则？还是必须经过一个更复杂的流程，因为各方利益相关者——比如一些游说团体——可能有各种理由希望保留这些规则？

Are you allowed to convene a group of people and start to line item these rules out or change them, or does it have to go through some much more robust process where there's a lot of competing reasons why some people, some lobbies maybe, may want these rules?

当然可以。

Oh, sure.

我的意思是，任何领域都有既得利益者，但今年及明年我的工作计划之一，就是全面梳理我们的规则手册。

I mean, there are vested interests in everything, but that is part of my program, for this year and going into next is to go through our rule book.

我们需要一次彻底的清理。

We need a spring cleaning.

我们需要清理阁楼、地下室和车库，真正以对重要性的全新关注来审视这些事项，这是该机构以前从未做过的。

We need to clean out the attic, the basement, and the garage, and to really look at things unlike the agency has ever done before with a real focus on materiality.

这是第一点。

So that's one.

第二点，要让首次公开募股再次辉煌，就是要关注诉讼问题。

The second, to make IPOs great again, is to focus on litigation.

这也是一个关键的障碍，我认为，阻碍了企业从私募市场走向公开市场。

And and so that is another thing that is a key inhibition, I think, for people to go from the private markets to public.

每次股价下跌，都会面临集体诉讼和无理诉讼的威胁。

The threats of class action lawsuits and vexatious litigation with every dip in the in the stocks.

你还有一些问题，比如强制仲裁、费用转移，也就是‘败诉方付费’之类的措施，这些 Delaware 州最近已对上市公司禁止了，但其他州仍然存在。

You have, issues like mandatory arbitration, fee shifting, you know, loser pays, that sort of thing, both of which Delaware has recently, outlawed for public companies, but there are other states out there.

第三点是将公司治理武器化，比如股东提案之类的事情。

And then the third is the weaponization of corporate governance around shareholder proposals, that sort of thing.

因此，处理年度股东大会之类的事情变得非常麻烦。

So it becomes a pain to deal with the annual general shareholder meeting and and that sort of thing.

所以这三点或许不是唯一的阻碍，但它们是我过去三十多年里，从风险投资人、私募股权人士、投资银行家、律师等人那里反复听到的三个关键问题。

So those three are maybe not the only inhibitions, but they're three key ones that I've heard over and over and over again over the last thirty some years from venture capitalists, private equity folks, investment bankers, lawyers, and etcetera.

迈克，你在商品期货交易委员会2026年的首要任务是什么？

Mike, what are your top priorities for 2026 in the CFTC?

和保罗一样，我最初在一家律师事务所从事私人执业。

Well, like Paul, I started off working in private practice at a law firm.

大约在2021年到2022年期间，每周我的客户都会收到加里·詹泽勒或商品期货交易委员会发出的传票，面临一波又一波的执法型监管。

And right around 2021, 2022, every week, my clients would get a subpoena from Gary Gen Zler or from the CFTC, and were faced with this onslaught of regulation by enforcement.

他们面对的是与自身商业模式不匹配的监管规定，这些客户包括加密公司、预测市场、人工智能公司，以及我们传统的金融市场参与者。

They were faced with regulations that did not work for their business models, and these were crypto firms, prediction markets, artificial intelligence firms, as well as our traditional financial market participants.

在上一届政府时期，他们一直遭受联邦政府的持续打压。

They were just relentlessly attacked by the the federal government under the prior administration.

所以我进入政府工作，是为了帮助掌舵，确保我们为新兴的创新技术和金融产品制定量身定制的规则和监管。

So I really came into government to help ride the ship, to help make sure that we have purpose fit rules and regulations for new innovative technologies and financial products.

因此，我的议程中一个重要部分就是加密货币和我们的加密资产市场。

And so a big piece of my agenda has been crypto, our crypto asset markets.

正如你们所有人可能都在关注的，我们正与戴维·萨克斯密切合作，希望推动一项立法最终通过，总统也会支持，这将是关键的一环。

As as you all, I'm sure, are tracking, there's some legislation that we're really hopefully working with DavidSacks to get across the finish line and the president, but but that's gonna be a key piece.

因此，商品期货交易委员会将对现货市场拥有广泛的监管权，我们正准备在立法通过后实施这些规则。

So the CFTC would have a broad amount of authority over the spot markets, and we're getting ready to to implement those rules should the legislation get across the finish line.

我们议程中的另一项重点是，无论立法是否通过，都要现代化和升级我们对链上软件系统、区块链网络以及其他数字资产产品的监管规则。

Another key piece of our agenda has also been modernizing and upgrading our rules and regulations for on chain software systems, blockchain networks, and other types of digital asset products regardless of legislation.

确保我们拥有面向未来的监管规则至关重要，这些规则必须能应对今天和明天的创新。

It's really important that we have future proof rules and regulations that are ready for the innovations of both today and tomorrow.

这不仅包括区块链，也包括人工智能以及其他技术革新领域。

And that's blockchain, but that's also artificial intelligence and and other areas of technology innovation.

因此，我们需要对监管框架进行大量调整，以确保我们能够适应这些变化。

So there's a lot of things we need to change within our regulatory framework to make sure that we're ready to accommodate that.

我想问你们两位一个问题。

Let me ask both of you guys a question.

这涉及到代币化、加密货币，以及我所说的系统性风险的交汇点。

So this sits at the intersection of tokenization, crypto, and what I would call systemic risk.

如果所有东西都变得通证化、数字化并实现7x24小时运行，你认为需要采取哪些措施来确保系统性风险得到有效管理？

So if all if everything becomes tokenized and digitized and 24 by seven, what do you think needs to happen to make sure that the systemic risks to the system are managed?

让我解释一下我的意思。

And here's what I mean.

如果你去X平台看看，我已经深入探索了自动化交易的领域。

If you go on x, I've gone down the automated trading rabbit hole.

我不知道你们是否知道，但现在有一些非常出色、充满活力的项目，正在取代 Citadel 和 Millennium，它们正在构建基于自动化代理的对冲基金，全天候在各种市场中进行交易。

So I don't know if you guys know, but there are these incredible young vibrant projects that are basically replacing a citadel, replacing a millennium, and they're building these automated agent based hedge funds that are transacting across all kinds of markets all the time.

一方面，我完全被它吸引。

And on the one hand, I'm completely attracted to it.

我觉得这完全实现了民主化。

I think it's totally democratic.

这是自由市场。

It's the free market.

让我们弄清楚那里到底发生了什么。

It's like, let's figure out what's going on there.

另一方面，我问自己一个问题：哪里是紧急停止按钮，或者说是熔断机制呢？

And on the other hand, I ask myself the question, where's the kill switch or where's the circuit breaker, if you will?

我想给你们一个机会，谈谈你们如何看待这些市场的融合，以及其中的利与弊。

And I just wanna give you both a chance to talk about how you see these markets converge and both the positives and the negatives of it.

当然。

Absolutely.

我们在制定规则时，必须考虑这些风险，这对我来说正是我们需要为这些产品、自主代理等建立有针对性的监管框架的全部原因。

We need to be considering these risks as we're developing rules, and and this to me is is the whole reason we need to have a purpose fit regulatory framework for these products and and autonomous agents and all of that.

到目前为止，我认为我们的做法一直是套用旧的规则和法规，以为这样就能顺利运行，确保没人能真正创新或创造新事物。

Up until now, I think the approach has always been let's apply the old rules and regulations, and and that's gonna work out and make sure that nobody can actually innovate and and create something new.

因此，我们正在拥抱市场中的这些机遇。

So we are embracing these opportunities in the markets.

我们需要研究它们，确保理解其中的风险，但同时也能制定出能够容纳这些风险的规则。

We need to study them and make sure that we understand the risks, but we can develop rules that accommodate that.

因此，我们需要建立一种机制：去大胆建设，不必事先征得许可，但我们需要研究，与市场参与者合作，理解其中的风险。

So having a regime in place that says go build, don't ask us for permission, but we need to study that work with the market participants, understand the risks.

在我们这边，我们需要设立护栏。

And on our end, we need to set up guardrails.

所以我认为，当一个代理能够以近乎自主的方式对外部署资本时，确实存在独特的风险。

So I do think there are unique risks when you have the ability for an agent to go out and deploy capital on on basically an autonomous basis.

这对我们监管者来说是一种前所未有的情况，但这并不意味着我们必须阻挠或阻止它。

And and that's gonna be something that our markets, we've really really never seen before as regulators, but that doesn't mean we have to stand in the way and block it.

我认为我们必须深入理解这些风险，确保建立正确的护栏，无论是由我们来运营区块链节点，还是让技术人员研究合约和代码。

I I think we need to really understand the risks, make sure that we have the right guardrails, whether that is us operating nodes on blockchains or or really having technologists that are studying the contracts and the code.

但我认为，没有任何理由不能在美国本土开发这些技术。

But I don't think there's any reason we can't have these technologies built here in America.

我同意这一点。

I agree with that.

从我的角度来看，分布式账本技术为金融服务行业带来了诸多好处，我们正站在实现T+0结算的门槛上——即通过数字资产实现链上即时交割与支付。

And from from my point of view, there are so many benefits to come from distributed ledger ledger technology for the financial services industry where we're right at the cusp of achieving a t zero, basically, you know, immediate delivery versus payment, receipt versus payment on chain by, you know, digital assets.

这非常令人兴奋。

And, so that's pretty exciting.

我们可能甚至需要设置一些减速带，以防止欺诈和其他类似问题。

What we may even have to build in speed bumps, you know, to prevent fraud and and things like that.

但对于许多工具而言，这可能是不可能的。

But for many and for some instruments, it might not be possible.

但你们谈到的24/7全天候运行等等，我认为这确实是一个令人兴奋的前景。

But your discussion there twenty four seven and all that, I think, is is really an exciting prospect.

但从流动性角度来看，确实存在挑战，比如‘最佳买卖报价’这个概念到底意味着什么？

But there are challenges from, you know, the liquidity perspective, you know, having a you know, the whole concept of best bid and offer, what does that mean?

所以，这将是我们要应对的一个问题。

So, you know, that's one that, we will we will be wrestling with.

但最终，至少我们和迈克努力协调两个机构的做法，是希望从当前国会正在讨论的《清晰法案》中推动出台一部法律，以确保我们当前的工作未来不会倒退。

But ultimately, at least our approaches and and what Mike and I are striving to do in harmonizing the approach of our two agencies is to and hopefully, we'll get a a statute out of the whole Clarity Act discussions going on in the hill right now that's really necessary to future proof what we're doing so there is no backsliding in the future.

但如果某种资产本质上是证券，并且被代币化了，它仍然是证券，证券法依然适用。

But we need to focus on, you know, if it's a security underneath and it's tokenized, it still is a security and it's still the securities laws still apply.

但我们的责任是确保我们的规则切实可行。

But it's up to us to make sure that, our rules are fit for purpose.

随着整体目的和交付方式的变化，我们需要对此作出调整。

And as the whole purpose changes and as the delivery mechanism changes, we need to accommodate that.

不幸的是，在上一届政府时期，他们常说：‘来吧，和我们谈谈。’

Unfortunately, in the previous administration, you know, was said, oh, come in and talk to us.

我们为你准备了一份简单的表格。

You know, we have a simple form for you to fill out.

表格就在我们的网站上。

It's on our website.

这份表格叫S-1，对于一家现有公司来说，要弄清楚如何填写它就需要大量律师和会计师，更不用说对于一种全新的数字资产、加密资产了，因为这种资产的情况完全相反。

Well, It's called an s one, and it takes lots of lawyers and accountants to try to figure figure out how to do it for an existing company, much less for a new digital asset, a crypto sort of asset that, you know, where the form is completely in opposite.

没有董事会。

There's no board of directors.

也没有遍布全国或全球的办公室。

There are no offices around the country, around the world, or whatever.

我们需要对它进行调整，使其真正符合实际需求。

It's, you know, just the thing needs to be adjusted, so that it is fit for purpose.

因此，我们正在努力通过审查我们的规则手册，确保其能够适应新技术。

So that's what we're striving to do going through our rule book to make sure it it can accommodate the new technologies.

让我们基于查马斯的对话和他的观点继续深入。

So let's build on Chamath's conversation here and his points.

市场中一个关键的风险与创新机遇在于杠杆。

One of the key dangers and innovations opportunities in the market is leverage.

我们显然看到对冲基金长期以来一直在使用杠杆。

And we see it obviously, hedge funds have been doing this for a long time.

我们现在也开始在预测市场中看到这一点，迈克，而且在加密货币中也出现了。

We're starting to see it in prediction markets, Mike, and we're seeing it in crypto.

适当的杠杆水平应该是多少？谁应该制定这些规则？

What is the proper amount of leverage and who should set those rules?

显然，国会负责制定法律。

Obviously, you have congress making laws.

主席，您负责执行这些法律，以确保市场有序运行并保护投资者。

You're responsible for executing them, chairman, in order to make sure the markets are orderly and that you protect investors.

所以请你详细说明一下，你认为合适的杠杆水平是多少，你的框架是怎样的。

So just walk us through what you think is the proper amount of leverage and your framework.

而且正如我们提到的，你在这方面已经有很多年经验了。

And and you've been at this for a while, as we mentioned.

这些年来，情况发生了哪些变化？

How has that changed over time?

给我们普及一下，我们是怎么走到今天这个地步的——比特币投资者的杠杆可能高达100倍或50倍，人们在预测市场上也广泛使用杠杆，这似乎有其功能，但几乎每个故事都始于杠杆，也终于杠杆。

Educate us a bit on how we got to a world in which Bitcoin investors might be a 100 x or 50 x, and people might be leveraging their prediction market and seems like it has a function, but it also seems like almost every story starts and ends with leverage.

是的。

Right.

我认为这取决于市场类型和具体情境，因为银行体系本质上就是基于存款准备金和放贷的。

Well, so I think it depends on the marketplace and and on the type because obviously of banks and they're all about fractional, deposits and and all of that and and lending.

我们早在2008年和2009年的金融危机中就经历过这些，再往前追溯到1929年，甚至19世纪，金融动荡和市场问题反复出现。

So, you know, so we we've gone through that back in 2008 and 2009 and the financial crisis and going all the way back to 1929, and then even in eighteen hundreds, obviously, all the repeated problems with, you know, financial disruption and financial markets.

所以我们必须对此保持警惕。

So we have to be careful about that.

经纪交易商、银行、期货市场、保证金等方面都有各种各样的规则，用来对这些行为加以限制，确保有相应的管控和透明度。在期货市场中，交易所对其会员以及保证金管理拥有很大的权力，甚至可以强制平仓。

There are all sorts of rules for broker dealers, for banks, for in the futures markets, for margin, and all of that to, like put a lid on some of this and to have some controls around it and and transparency, you know, in the futures markets, the the the exchanges have a lot of power, you know, over their members and over margin and, you know, closing things down.

我们甚至在疫情期间也看到了这种情况，当时市场变得非常动荡。

We saw that even in the COVID time and and whatnot when the markets got hairy there.

所以，这些方面一直在被持续审视。

So, you know, those things are constantly looked at.

美联储在保证金和证券市场方面也发挥着作用。

The Fed plays a role as well, you know, with margining and the securities market.

因此，所有这些都需要不断调整。

So all that has to be adjusted.

现在，我们需要仔细审视这些新兴市场，找出哪些是类似的，明确我们有哪些监管权限，确保我们不会扼杀交易，同时也要未雨绸缪，防止未来再次出现系统性崩溃。

And now we need to look carefully at these new markets and then see what's analogous and see what authority we have and and then make sure that, you know, we're not killing, trading, but we also have to keep an eye out for the future to make sure that we're not allowing things to then blow up in our face.

这里有个问题，可能听起来很傻，如果真是这样，我先道歉，这个问题想问你们两位。

Here's a question that may sound dumb, so I apologize if it does, and this is to both of you.

很多人，或者至少我不太清楚，SEC和CFTC在哪些方面合作得最有效。

I think a lot of people don't understand, or at least I don't, where the SEC and the CFTC cooperate most effectively.

但和所有事情一样，协调可能在哪些地方出现断裂？

But then as with all things, where does coordination maybe break down?

你们能否向大家解释一下，让我们明确各自机构的预期，以及在需要时你们日常是如何真正合作的？

Could you just explain that to people so that we understand and level set about what the expectations of each organization are and how you guys actually work together day to day when you have to?

我在两家机构工作了三十多年，可以说，不幸的是，这两家机构——不一定是专员层面，但确实在工作人员层面——经常互相攻击。

Having been around the two agencies now for thirty some years, can really say that, unfortunately, the two, and not necessarily at the commissioner level, but, certainly at the staff, there was a lot of sniping, you know, back and forth.

所以我把它比作两座堡垒，中间隔着一片无人区。

So I compare it to two, fortresses with a no man's land in between.

这片无人区里遍布着那些因人们犹豫不决而夭折的产品：这到底是CFTC的管辖范围？

And so the no man's land is littered with the bodies of would be products that people were unsure, like, is it CFTC?

还是SEC的？

Is it SEC?

两家机构之间的交火直接扼杀了这些产品。

And the crossfire between the two just killed the products.

它们从未进入市场。

They never went to market.

个股期货、投资组合保证金，这些措施对提升金融市场的安全性和效率具有巨大潜力。

Single stock futures, portfolio margining, which has so much potential benefits for making the financial markets safer and more efficient.

但迈克和我正致力于改变这一现状，迈克，接下来你来详细说说吧。

But Mike and I are setting out to change that, and I'll let you, go forth on that one, Mike.

当然。

Absolutely.

这两家机构不幸的是很少能良好协作，而我们现在正通过协调努力迈向一个全新的方向。

The the two agencies have unfortunately rarely worked well together, and what we're really, moving, forward in a new direction with our harmonization efforts.

我们正在制定一份谅解备忘录，两家机构正共同努力敲定并落实，以便共享信息、协调具体问题，并确保未来不再出现两家机构之间的地盘争夺。

We have a memorandum of understanding that the two agencies are working on hammering out and getting in place that will allow us to share information, coordinate on specific issues, and make sure that we don't have this turf battle between the two agencies going forward.

而这一切当然要从高层开始。

And part of that starts, of course, at the top.

阿特金斯主席和我紧密合作，确保我们在政策上保持协调，同时也在员工层面做到协同。

Chairman Atkins and I work very closely together to make sure that we're coordinated on policy, but also at the staff level.

因此，当交易所、经纪商和市场参与者前来注册或推出新产品时，我们必须确保不再出现关于他们应该在哪家注册、能提供什么产品的争执。

So when exchanges and brokers and market participants are coming in to register or to offer new product, we need to make sure that there's not this fighting over where they're supposed to be registered and what they're able to offer.

这些产品跨越了不同司法管辖区。

Some of these products cross jurisdictions.

一个很好的例子是某些预测市场产品。

A great example are some of the prediction markets products.

其中一些涉及上市公司和证券，另一些则与体育和政治等事项相关。

Some of them involve public companies and securities, and others are related to things like sports and politics.

这跨越了司法管辖区，因此我们必须明确界限，确保我们的市场参与者不会受到重复的监管框架约束。

And that crosses jurisdictions, so we need to make sure that we have clear lines and that our market participants aren't subject to duplicative regulatory frameworks.

阿特金斯主席和我讨论过替代性合规机制，即由SEC或CFTC作为主要监管机构，但我们共同协作，厘清六类交叉产品的监管归属，避免出现重复监管和注册的情况。

And chairman Atkins and I have talked about substituted compliance regimes where you have a primary regulator at the SEC or the CFTC, but we work together to figure out the crusher of six channel products so that you don't get stuck with duplicative regulation and registration.

另一个领域是加密货币，我们面临区块链网络。

Another area is crypto where we've got blockchain networks.

我们有智能合约。

We've got smart contracts.

我们有协议，其上同时交易证券和非证券类资产，且跨越司法管辖区，我们必须确保标准一致，因为如果为证券设立一条区块链、为商品设立另一条区块链，而两者之间没有任何衔接，这种模式是行不通的。

We've got protocols that have both securities and nonsecurities trading on them cross jurisdictionally, and and we need to make sure that the standards are consistent because it won't work if we've got one blockchain for securities and another blockchain for commodities and nothing in between.

所以我认为，各机构必须放下成见，采取协调一致、和谐统一的方针，这至关重要。

So I I think this is really critical that the agencies bury the hatchet and move forward with a harmonized and coordinated approach.

当我们展望未来时，我想接着说一下，是的。

As we look towards the future, I mean, to build on yeah.

目前存在两种不同的监管体系，并且由于各自所依据的法律不同，监管方式也存在差异。

There are two separate regimes and and there are differences in approaches, based on the statutes that govern us.

但就证交会而言，我们在豁免授权等方面拥有很大的灵活性。

But, we also and speaking for the SEC, we have a lot of flexibility with respect to exemptive authority and whatnot.

所以我的理想是，有朝一日——我希望在未来几年内能实现——能够采用一种‘超级应用’的模式，即两者之间的界限变得模糊，但我们已经协调了监管方式。

So my dream is one day that and I hope we can achieve that here in the next couple of years to have like a super app approach where, you know, there is, okay, blurred lines between the two, but we've coordinated our approach.

我们已经协调一致，旨在减少双重注册公司之间的摩擦，让一切运作得更加高效。

We've coordinated, you know, to reduce the friction between dually registered companies and and to make everything work very efficiently.

我想就预测市场问一个问题。

I wanna ask a question around prediction markets.

让我试着从我自己的理解角度来阐述一下。

Let me try to set this up the way that I think about it.

我认为，当涉及到公开交易的证券、商品或衍生品时，投资者保护与公司或其他寻求获取资金的主体所必需的资本形成过程之间，始终存在一种不可避免的张力，并且这种张力将永远存在。

So I think that there is this inexorable tension that's always existed and will always exist between the investor protection that has to happen when you have publicly traded securities or commodities or derivatives, but then the capital formation process that on behalf of the company or whatever that wants to get access to this.

这种来回拉扯的紧张关系一直存在。

And there's always been this kind of back and forth tension.

这方面最好的例子是《公平披露规则》（Reg FD），当时我们说：嘿，让我们暂停一下。

The best example of this is Reg FD where we said at some point, hey, let's hold the trains.

如果一个人知道了某件事，那么每个人都需要知道这件事。

If one person knows something, every person needs to know that thing.

这非常合理。

Makes a ton of sense.

当你进入预测市场时，我认为这将把这一假设推向极致的考验。

When you get into prediction markets, I think that this is gonna stress test this assumption to the nth degree.

原因是，总有一些信息是只有部分人知道的，而我们现在几乎每隔几天就能看到这种情况。

And the reason is that there are just certain things that some people know, And we see it now every other day.

总会有文章报道某些预测市场最终被证明是正确的，或者许多其他市场几乎被操纵了。

There's an article about some prediction market that turned out to be right or a bunch of other markets that were almost manipulated.

这似乎让这个问题再次反复出现变得顺理成章。

It seems like it's ripe for this question to come up all over again.

与此相关的是，布莱恩·阿姆斯特朗发了一条推文，我觉得他对预测市场发表了一个非常有趣的评论，即某些预测市场只依赖内幕信息生存，也就是说，它们掌握着秘密。

The corollary to this is Brian Armstrong tweeted something which I thought was quite an interesting comment about prediction markets, is that certain prediction markets only thrive on insider information, which is to say that they know a secret.

因此，市场才能存在并真正反映结果，而这造就了这两方面的对立。

And so that's how the market can exist and actually conform to an outcome, and that creates these two sides.

我只是想听听你对预测市场的看法。

I just wanna get your thoughts on prediction markets.

它们扮演着什么角色？

What role do they play?

我们该如何平衡市场带来的资本形成与投资者保护、可能发生的内幕交易？

How do we balance the capital formation that the market creates versus the investor protection, the insider trading that may be happening?

这是一个非常复杂的领域。

It's a very complicated space.

我不会让你对这些观点负责。

I'm not gonna hold you to any of it.

我只是想大声地思考一下。

I just want to think out loud.

这些市场并不新鲜。

Well, these markets aren't new.

它们从九十年代就开始存在了。

We've had them since the nineties.

它们最初起源于爱荷华州的电子市场，人们在那里预测选举的政治结果。

They started off with the electronic market in Iowa where folks were predicting the political outcomes on elections.

我们长期以来一直在监控、观察并打击这些市场中的欺诈和操纵行为。

We've been surveilling and monitoring and and policing fraud and manipulation in these markets for a very long time.

在某些市场中，存在一些合约，比如预测超级碗上被泼在教练身上的健怡可乐会是什么颜色，这类合约有可能被操纵，而且存在风险：球队内部人员可能因为知道冷却器里放的是哪种健怡可乐而进行交易。

And to the extent that there are contracts in certain markets, for example, what color Gatorade's gonna be, you know, dunked on the the coach at the Super Bowl, some of this stuff is potentially at risk of being manipulated, and there's a risk that somebody on the team is able to go trade because they have special information about the Gatorade they put in the cooler.

我们有标准来确保这些合约不应被上市，交易所作为第一道防线，作为自律组织，必须评估每个合约并向我们监管机构——商品期货交易委员会（CFTC）认证，这些合约不易受到内幕交易、操纵和欺诈的影响。

We have standards to make sure that those contracts should not be listed, and and it's on the exchanges as the first line of defense as self regulatory organizations to evaluate each contract and certify to us, the regulator, the CFTC, that those contracts are not readily susceptible to insider trading, manipulation, fraud, and the like.

我们最近实际上看到，其中一个预测市场对两名参与者采取了执法行动。

And we saw actually recently, one of the the prediction markets brought two enforcement actions against participants.

其中一个涉及与MrBeast的YouTube频道相关的合约，他的一名员工利用关于视频何时发布或视频内容的信息进行了内幕交易。

One involved a contract related to mister beast's YouTube channel where one of his employees insider traded based on information of when a video was gonna launch or what was in the video.

我们在市场中也普遍存在类似于SEC所要求的对雇主尽职尽责的义务。

And the same sort of authority that you have at the SEC around a duty of of, you know, care to your employer is prevalent in our markets.

因此，如果有人利用内幕信息进行交易，我们会进行监管。

So to the extent somebody insider trades on information, we police that.

而且让公众了解这一点非常重要。

And and it's really important for folks to know.

这不仅仅是证券市场的内幕交易，商品市场中也同样存在。

It's it's not just securities insider trading, we've got it in the commodities world as well.

交易所正在监管这种行为，我们也在进行监管。

And the exchanges are policing that, we're policing that.

如果有人列出容易被操纵的合约，将会面临相应后果。

And to the extent folks are listing contracts that are susceptible to manipulation, there's consequences to that.

我们可以拒绝这些合约，或者在事后监管欺诈行为，但确实有监管人员在一线把守。

We can reject those contracts or we can police fraud on the back end, but there is a cop on the beat there.

我想提醒一下，内幕交易在我们的市场中并不是被允许的，但我们相信市场是真相机器，能够产生非常强大的信息来源。

And I I do wanna caution that insider trading is is not something that's necessarily allowed in our markets, but we do believe that markets are truth machines, that they do create a really powerful source of information.

我们已经看到了各种谣言、假新闻和民意调查的操纵。

We've seen the hoaxes, the fake news, and the manipulation of the polls.

上届政府试图在2024年大选前禁止这些市场，但结果反而提高了投票率。

The prior administration tried to ban these markets ahead of the twenty twenty four election, and they really increased turnout.

当大量虚假民调在选举前夕发布时，这证明了他们的判断是正确的。

It showed that they were correct when a bunch of the fake polls were put out right ahead of the election.

因此，我们真的必须在美国扶持这些市场，确保它们不会在俄罗斯或其他地方蓬勃发展，否则这些市场最终可能成为虚假信息的来源。

So we really have to foster these markets here in The United States and make sure that they don't flourish in Russia or somewhere else where they really will turn out to be a source of disinformation.

因此，我们确实认为让交易和信息在市场中流动是有价值的，但内幕交易在这里仍然是非法的

So we do believe it's valuable to have that trading and information flowing through the markets, but insider trading is is still still illegal here in

在美国。

The US.

迈克，给我们讲讲一些具体的例子吧。

Take us through some examples there, Mike.

对于在微软工作的人来说，这一点非常明显和清楚。

Like, it's very obvious and clear to people who work at Microsoft.

如果即将推出新版本的软件，或者销售数据尚未公布，显然你不能基于这些信息进行交易。

If some new version of software's coming out or the sales are dynamic and the numbers haven't been released, obviously, you can't trade on that.

你会坐牢的。

You're going to jail.

这是内幕交易。

It's insider trading.

如果我是微软软件的经销商，或者我的朋友在微软工作，告诉我：‘我们这个新产品进展非常顺利。’

If I am a reseller of Microsoft software or a friend of mine works at Microsoft and says, hey, things are going great with this new product we have.

然后我基于这个信息，在预测市场上做出一个审慎的投注。

And I make a thoughtful, you know, wager on a prediction market.

或者，如果我故意做一些事情，比如最近提到的一个例子：我在超级碗上裸奔。

Or if I intentionally do something like I'm a streaker at the Super Bowl was one that came up recently.

而我本人就是那个裸奔的人——当然，我并没有计划做这种事，只是为了下注。

And I actually am the streaker, not that I'm planning any of this, to make the bet.

这些规则在哪里？

Where are those rules?

它们存在于哪里？谁负责？

Where do they live, and who's responsible?

是预测市场吗？

Is it the prediction market?

是你吗？

Is it you?

还是待定？

Or is it TBD?

因为正如查马斯在这里隐约提到的，确实存在一些灰色地带。

Because it does seem that there's a bit of gray area as Chamath was sort of alluding to here.

这是否需要被明文规定，公众是否也需要更多的教育来理解这一点？

And and does this need to be codified, and there's a need to be a bit more education for the public on it?

许多灰色地带最初源于上一届政府试图禁止这些市场，却没有推动适当的规则制定和指导。

A lot of the gray started off with the prior administration really trying to ban these markets and not facilitating proper rulemaking and guidance in the markets.

在过去一年里，你知道，我现在已经在办公室待了几个月了。

Over the past year, you know, I've been in the the office for a couple months now.

在过去一年中，在代理主席的领导下，这些产品的人气急剧上升，因此现在是时候发布指导方针，确保我们不再像上一届政府那样通过执法来监管。

For the past year under the acting chairman's leadership, a lot of these products have really exploded in popularity, and so now is the time to put out guidance and make sure that we're not regulating by enforcement as the prior administration did.

但我们正在制定标准。

But we are setting standards.

我们正在明确说明我们的法规内容，即如果这些合约容易被操纵，则不得上市。

We are making clear what our statute says, and that is that these contracts cannot be listed if they're susceptible to manipulation.

我们对此非常重视。

And we take that very seriously.

标准。

Standard.

是的。

Yeah.

是的。

Yeah.

是的。

Yeah.

因此，交易所负责监督并审查这些合约，并向我们监管机构认证它们不存在被操纵的风险。

So the exchanges are responsible for policing that and reviewing the contracts, and they certify to us, the regulator, that they are free of the the risk of manipulation.

如果存在操纵行为，市场本身会进行监督。

And if there's manipulation, the markets were policing that.

交易所正在监督这一点。

The exchanges are policing that.

所以已有控制措施，但关于哪些合约容易被操纵，许多问题仍存在争议。

So there are controls in place, but a lot of these questions as to what's susceptible to manipulation are are up for debate.

我认为存在一些风险。

And I think there's some risks.

有可能，比如你提到的裸奔者例子，如果有人从观众席跳出来冲过场地并赢得合约收益，这确实看起来有可能被操纵和欺诈。

There's possibility, you know, your example with the streaker, if somebody can just jump out of the stands and go streak across and collect on the contract, I mean, that's something that does seem potentially at risk of manipulation and and fraud.

因此，我们需要对此保持谨慎。

And so we need to be careful about that.

交易所需要对此保持警惕。

The exchanges need to be on the lookout for that.

如果他们没有做到，作为监管机构，我们会采取相应措施。

And if they're not, you know, there's consequences with us as a regulator.

市场应该首先采取行动，谨慎选择哪些合约上线，我们已经看到了这一点。

The markets should take the first step and make sure they're thoughtful about which ones to fire up to begin with and we have seen that.

他们并不是说‘这位独裁者被处决了’。

They are not saying, hey, this dictator is executed.

他们说的是‘这位独裁者被推翻了’或‘不再掌权’。

They're saying this dictator is deposed or is no longer in power.

这似乎也是一个非常棘手的问题。

That seems to be a very tricky one as well.

是的，迈克？

Yes, Mike?

合约必须保持诚信。

Well, there's gotta be integrity in the contracts.

我们的规则要求合约具备某些可互换性和标准化。

Our rules require that the contracts have, for example, certain fungibility and standardization.

它们是衍生品合约。

They're derivatives contracts.

这不仅仅是像在赌场里找赌徒下注那么简单。

This isn't simply just betting at a, you know, with a bookie in a casino.

所以每一份合约，确实如此。

And so each contract, that's that's correct.

你会去查看，它是否与选举相关，或者是否与某个特定事件相关？

You you would look for, is it tied to an election or is it tied to a very specific event?

是否存在该事件被操纵或内幕交易的风险？

Is there a risk that that event can be manipulated or insider traded?

交易所正在评估这些情况。

And the and the exchanges are evaluating that.

确实存在一些案例，某事发生了内幕交易，而这是他们无法预见的。

And there are instances where something is insider traded, and it wasn't something they could have foreseen.

它并不容易被操纵。

It wasn't readily susceptible to manipulation.

因此他们对此进行监管。

And so they police that.

他们会对交易员采取行动，过去几周，Call Sheet 就正是这样对一些人处以罚款的。

They bring actions against the traders, and call sheet did just this with some of its fines in in the past few weeks.

我想问一下关于季度报告的问题，因为过去最可能出现操纵的地方可能就在这里。

Let me ask a question about quarterly reporting because maybe where there was the most manipulation in the past was around that.

对吧？

Right?

人们会试图提前交易这些季度报告。

People would try to front run these quarterly reports.

他们会试图做出猜测。

They would try to make guesses.

不可避免地，你会发现一些人越过了那条明显的红线。

Invariably, you would find some people that had crossed the bright red line.

但最近，特朗普总统表示，也许我们应该改为半年报或年报，这一提议得到了许多人的积极响应。

But recently, Paul president Trump said maybe we should move to six month reporting or one year reporting, and it was really well received by a lot of people.

你认为季度报告在某种程度上也扼杀了IPO吗？

Do you think that quarterly reporting has sort of also killed the IPO?

也就是说，当我们思考如何让IPO重焕生机时，这种短期主义带来的复杂性和负担，你认为是让市场变得更好还是更糟？

Meaning, when we think about making an IPO great again, just the complexity and the burden of such short termism, has it made the markets better or worse, do you think?

是的。

Yeah.

这是一个很好的观点。

Well, that's a great point.

我想补充一点，关于之前讨论的内容：如果某种资产是代币化证券，那么联邦证券法同样适用。

And I just wanted to add one kinda a little note to the previous discussion there that, you know, if if something is a tokenized security, you know, the federal securities laws apply.

因此，无论证券是在线上、交易所交易大厅，还是其他任何地方交易，内幕交易的相关规定都适用。

And so that goes for insider trading, you know, with respect to trading securities, wherever they may be, you know, on the online or or on an exchange floor or wherever.

总之，关于报告周期的问题，我认为这确实很重要。

So anyway, but but then to your point about the cadence of reporting, I think that's an important one.

我们即将发布一项拟议规则，并征求公众意见。

And we are going to come out with a proposed rule and and seek comment on it.

坦白说，我个人对此持中立态度，因为如果你回顾一下，我们并非一直都有季度报告。

And I frankly am a bit agnostic myself, personally, because if you look at things, we haven't always had quarterly reporting.

事实上，当证券交易委员会在1934年成立时，它基本上将纽约证券交易所的规则手册法典化了，而当时的规定是要求提交年度报告。

In fact, when the SEC was, you know, formed back in 1934, it basically codified the New York Stock Exchange rule book, which at the time called for annual reports.

因此，年度报告一直占主导地位，直到1955年，证券交易委员会才改为半年度报告。

So annual reports prevailed until 1955, and the SEC went to semi annual reporting.

顺便说一句，英国在同一时期也采取了同样的做法。

And by the way, The UK did the same thing around the same time.

然后到了1970年，才正式改为季度报告。

And then in 1970, only did things go to quarterly.

英国后来也跟进实行了季度报告。

And then The UK parted way they did quarterly as well.

但到了2014年左右，他们又改回了半年度报告。

But then in 2014 or so, they, they changed to go back to semiannual.

但如果你仍然希望按季度报告，那当然好，尽管去做吧。

But if you wanted to still report quarterly, you know, God bless you and go ahead and and do that.

所以我们选择了按季度报告，总统也为此发出了电子通知。

So we're select quarterly, and and so the president did send out a, you know, electronic message about that.

因此，我们的工作人员正在研究我们所说的申报者状态。

And so, but our staff was looking at so we're looking at what we call filer status.

申报者有各种不同的类别，适用不同的规则，比如大型加速申报者、加速申报者、新兴成长公司等等。

There are all sorts of different, categories of filers with different rules, like large accelerated filers, accelerated filers, emerging growth companies, and so forth.

所以我们正试图简化所有这些规定。

So we're looking to kind of simplify all of this.

其中一部分也可能是较小公司可以从降低报告频率中受益，但也可能不会。

And part of that also is perhaps smaller companies could benefit from, you know, reduced, you know, cadence of reporting, but maybe not.

它们难以找到分析师跟踪其股票，这也是小型公司上市的另一个障碍，也许分析师希望按季度报告，也许不希望，也许他们也更偏好半年度报告。

They they have trouble finding analysts to follow their stock, that's another thing that might be an inhibition to go public for small companies, and maybe analysts want quarterly, maybe they don't, maybe they would prefer semiannual too.

所以我认为现在展开这场讨论非常合适。

So I think this is a great debate to have right now.

而且你确实有巴里·迪拉德持相反观点，他说：我只是厌倦了做预测。

And you did have Barry Dillard even taking the other side of it where he's like, I'm just tired of giving predictions.

我厌倦了这种季度性的博弈。

I'm tired of playing this gamesmanship quarterly.

我就每个月发布我们的会计数据，你们想怎么玩这些数字都随便。

I'm just gonna release our accounting numbers every month, and you all can have fun with numbers as much as you like.

但这太棒了，因为你现在就可以这么做。

But that's amazing because you can do that now.

对吧？

Right?

你可以使用功能强大的软件，直接由杰森发布数据流，会有人开发出代理程序和这些人工智能，自动处理所有数据，然后生成仪表盘，整个过程几乎实时进行。

You can have software that's so vibrant that it can just, Jason, release a stream and there'll be people that have, you know, developed agents and developed these AIs that will just process all of that and they will then publish out a dashboard and the whole thing will be almost real time.

它可以是实时的。

It could be real time.

是的。

Yeah.

而且已经有一些服务在做些半有趣的事情，你可以购买这些服务，也许那些有数据搜索流预算的人可以使用。

And and there are services that do semi interesting things already that you can buy that maybe people with budgets for data search streams can do.

让我们稍微谈一谈，阿特金斯主席，关于我国认证制度的历史。

Let's talk a little bit, chairman Atkins, about the history of accreditation in this country.

我想当你在你职业生涯早期提到微软时，看着这些公司上市，我趁你讲话的时候做了一些研究：微软和苹果上市时各有约1200名员工，收入约为4亿美元（按今天的美元计算），相当于当时1.2亿美元。

I think when you brought up Microsoft in the early part of your career watching these companies go public, I did a little research while we're here when you were speaking, Microsoft and Apple went out with a 1,200 employees each and about $400,000,000 in revenue in today's dollars, 120,000,000 in those dollars.

因此，显然，作为个人投资者，你有机会通过股票交易账户投资这些公司，从而可能从社会财富的某一阶层跃升到另一个阶层。

So, obviously, there was this incredible opportunity for you to create and place a bet on these companies as an individual with a stock trading account, and maybe move from, you know, one tier in societal wealth to another.

而这正是美国梦的重要组成部分。

And that's a big part of the American dream.

但当我们讨论私募市场时，美国证券交易委员会（SEC）现在执行的规则已经非常古老，接近一个世纪之久，这些被称为认证法规的规则旨在保护投资者。

But as we talk about private markets, the SEC has ancient rules now, going on close to a century old to protect investors called accreditation laws.

这些法规似乎适用于全国95%的人口，只有大约5%的人有资格以某种方式参与私人公司的交易，而这些公司的价值正是在这里创造的。

They apply to 95% of the of the country apparently, and about 5% of us get to trade in some way in private companies where the value is created.

SEC一直面临压力和要求改革这些规则、使其与时俱进，但似乎从未真正发生过。

The SEC has been challenged and charged with changing these, evolving these, and it never seems to happen.

我的看法是，哪一位证交会主席会愿意接手这个问题呢？因为说实话，维持现状更容易。

My perception is which SEC chair is ever gonna take this on because, hey, it's just easier to keep the status quo.

但难道没有这样的论点吗？

But is there not an argument?

我知道现在有一些立法正在推动建立一个成熟投资者测试标准。

I know there's some legislation now to create a sophisticated investor test.

所以，不是因为你继承了一百万美元就有资格购买优步这样的私营公司股票，而是通过其他方式获得资格。

So instead of you inherited a million dollars, you're qualified to buy stock in Uber when it's a private company.

为什么不采用类似驾照的成熟度测试呢？你学习如何交易私营公司股票，然后获得参与这个市场的权利，而不是对人们说：‘你只能参与体育博彩或拉斯维加斯的二十一点，但不能投资。’

Why not a sophisticated test like a driver's license and you learn how to trade in private companies and you get to participate in that market instead of just saying to people, well, you can only participate in sports betting or blackjack in Vegas, but you can't.

如果你是优步司机、爱彼迎房东，或是使用领英的HR人员，就该让你购买这些公司的股票。

If you were an Uber driver or an Airbnb host or an HR person using LinkedIn as a private company, buy those stocks.

因为你拥有独特的洞察力和直觉，可能更懂得如何做出投资决策。

Well, you have an insight and you have an instinct into maybe purchasing.

所以谈谈认证标准和成熟投资者测试，以及你个人对此的看法。

So so talk about the accreditation test and sophisticated investor tests and and your personal view on it.

是的。

Yeah.

很好的观点。

Well, great point.

所以，有一位主席将着手解决这个问题，我们打算这样做，即修订合格投资者的定义。

And so well, here's one chairman who is going to tackle that issue, and so we intend to do that, the accredited investor definition.

有趣的是，正如你所提到的，在1940年的《投资顾问法》或《投资公司法》中，确实有关于这一概念的定义，它不仅包括资产或财力，还明确包含了‘知识’这一要素。

And so interestingly, I mean, to your point, in the statute, in the Investment Advisors Act of 1940, I believe, or Investment Companies Act of 1940, it there's a definition of that, and it includes knowledge, not just, you know, wherewithal or sort of assets that you have, but include it has the word knowledge in it.

因此，正如你所说，为什么我们不能像驾照考试那样设立一个类似的测试，或者认可拥有CPA、CFA或其他类似资质的人？也许可以设计一种类似系列七考试的简化版本，但不需要FINRA管理的那么复杂。

So to your point, why can't we have, and people have suggested this over time, equivalent of a driver's test or something like that, or recognize somebody who has a CPA or, you know, a CFA or or whatever, but, you know, maybe a type of series seven, but, you know, not so complicated as that that FINRA administers.

那么问题来了，谁来制定这个测试？

So part of the thing is like, who's gonna make the test?

谁来负责实施？

Who's gonna administer it?

我们该如何实现这一点？

And how do you get there?