Crypto Legislation Front and Center this Quarter
Regulation and legislation was once again a major theme this quarter. The GENIUS Act, governing the issuance and oversight of stablecoins, was passed and signed into law. With total stablecoin supply exceeding $300 billion recently, this sector remains one of the most significant components of the broader crypto economy. Although the law has not yet taken effect, it formally recognizes stablecoins, sets important standards and rules for issuers, and introduces important consumer protections. As prospective and current issuers prepare to capitalize on this new regulatory framework, we anticipate continued heightened activity across the stablecoin landscape.
The other major piece of legislation, comprehensive crypto market structure reform, remains under negotiation in Congress. Although both the White House and pro-crypto lawmakers had hoped to see a bill enacted by year-end, its fate is uncertain. Recent reports suggest that discussions have stalled over several contentious issues, including the regulation of DeFi, wallet development, and related areas. While we remain confident that a framework will ultimately be passed, the timing of such legislation is still unclear.
SEC Moves to Usher in New Crypto ETFs, Up Options Limits
The SEC made an important step forward that should usher in a variety of new crypto ETFs with generic listing standards for commodity-based trust shares. Under these rules, exchanges can list qualifying ETFs holding spot commodities (including crypto) without submitting a 19b-4 filing, which is subject to a 240-day review process. Instead, ETFs must file a registration statement which the SEC will review and rely on self-attestation by the listing exchange. As it stands, a handful of crypto assets are likely to get spot ETFs, but the available investable universe in the ETF wrapper is about to expand meaningfully compared to just BTC and ETH today.
The SEC also approved in-kind creation and redemption orders for the spot bitcoin ETFs, something that issuers had wanted from the beginning. The change allows Authorized Participants (APs) to satisfy orders with the trust sponsor using bitcoin rather than cash. Operationally, it should simplify a complex process, allowing ETFs to trade at tighter spreads and closer to NAVs. There should be reduced costs for investors and lower tracking error–both good outcomes. However, the change may have put some APs and market makers that can’t trade or custody spot bitcoin at a disadvantage.
The final notable development this quarter involved options position limits on several spot bitcoin ETFs. Previously, traders were restricted to 25,000 contracts per ETF, but the SEC has now increased those limits by 10x for select funds. This adjustment is expected to further dampen bitcoin’s volatility, which has already been in secular decline throughout the year. In turn, this could enhance the attractiveness of structured products linked to bitcoin and bolster the asset’s role within risk-parity and multi-asset portfolios. However, it may also place continued pressure on certain derivatives strategies, such as covered-call selling, which tend to benefit from higher volatility.
Rate Cut the Macro Highlight of the Quarter
The major macro development this quarter was the FOMC’s 25-basis-point rate cut in mid-September, its first reduction since late 2024. While widely anticipated by markets, the move underscored the Fed’s challenging balancing act. Chair Powell emphasized the committee’s careful navigation between a softening labor market and persistently firm inflation, noting that the full effects of recently implemented tariffs have yet to be fully assessed.
Another significant monetary policy development this quarter was the appointment of the White House’s Stephan Miran to the FOMC, the first time since the 1930s that a member of the executive branch has sat on the FOMC. And while he’s just one of the 12 voting members, it’s possible his voice could have outsized influence given his position in the administration. It’s no surprise that the administration wants interest rates lower (by 3% is the call) and this appointment may have some impact on that. Regardless, Powell’s term as Fed chair ends in May 2026, at which point President Trump will be able to appoint someone more amenable to his monetary policy goals.
Network Activity Points to Increased Financialization of Bitcoin
We highlighted this at the start of Q3, but it remains a key observation: despite the price of bitcoin reaching new all-time highs, on-chain network activity has not kept pace. This divergence suggests an ongoing financialization of the Bitcoin network within traditional finance.
The mempool remains largely empty following the inscriptions boom, with target transaction fees at just 1–2 sat/vB. Transaction fees now make up less than 1% of miner revenue, compared with spikes above 50% (for certain blocks) during the inscriptions craze, as the 3.125 BTC block subsidy continues to dominate miner earnings. Meanwhile, daily active addresses are flat to declining.
Conversely, total and change-adjusted transfer volumes (per Glass Node’s methodology) are rising, and entity-adjusted transfer volume (again per Glass Node’s methodology) is near all-time highs. In our view, this points to fewer entities moving larger amounts of bitcoin, consistent with the ongoing shift toward institutional and corporate usage, including ETFs, corporate treasuries, and bitcoin-focused DATs.
IBIT Hoovers Up 93% of ETF Inflows
BlackRock’s iShares Bitcoin Trust (IBIT) remains the standout performer among U.S. spot Bitcoin ETFs, further extending its lead over competitors this quarter. The fund attracted $12.4 billion in inflows, accounting for nearly 93% of total net flows into the U.S. spot bitcoin ETF complex. With recent increases to options position limits, where IBIT was already the clear leader, the fund’s position as the dominant vehicle for Bitcoin exposure appears even more firmly entrenched.
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