Author: Chip Filson

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A CEO on Leadership and Legacy

I received the following from a credit union CEO  reacting to recent examples of mega-mergers.  The credit union’s market approach is clear:

From the Credit Union’s Website 

Why eat at a local restaurant? Why support your local non-profit? Why help out a neighbor? Simple: you care about your community, get better service from people you know, and want to feel good about the way you spend money. At our credit union, you’re a member, an owner, and a participant in a local, not-for-profit financial cooperative. Our cards look pretty awesome, too.

His Comments On Mergers

While I’m saddened by the loss of credit unions in number, I also believe each CU must do what’s right for them.  However, because the reasons given for these recent mega-mergers are fairly boilerplate no matter the size, I suspect that $20b won’t be “enough.”

As a CEO of a smaller shop, the thing I find scratchy is the tendency of some larger shops to take an imperialist posture combined with hubris. As they say in parts of the south: You ain’t all that.

During a multi credit union event hosted locally,  a rep from a larger shop told one of my star employees, “you know, credit unions your size are going away.”

Size Is Not What Members Seek

The thing is, a credit union at $20b is still a smallish bank. In my market, I have BOA, Wells, Chase, etc… Who cares what size you are – just don’t be a jerk.

I think the big shops need to get over themselves and, quite frankly, some little guys need to quit complaining about how hard things are.

My immigrant grandfather opened a restaurant 75 years ago and it’s still going strong. Business has always been tough! When people use that excuse, I always think that the real problem is a leader who can’t rise to the challenge rather than the challenge is too great. Ego won’t allow a leader to admit they might be the problem.

A Legacy, Not a Payday

Obviously, merger has also become a retirement plan for many…and that stinks. My goal: when I retire, pass the baton to the next gen…I’d rather have a legacy than a fat payday.

 

 

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A System Built on Hope

Yesterday I received the picture below from  a new Boston resident walking around town exploring the Commons.  The plaque was placed in 1959.

It reads in part, Edward Filene (1860-1937): author, scholar, outstanding citizen of Boston and public benefactor. Acknowledged as the founder of the credit union movement in the United States.

Great leaders require two defining characteristics: vision and optimism.  Together they produce hope.

Two Expressions of Hope

From Emily Dickenson:

“Hope is the thing with feathers –

That perches in the soul –

And sings the tune without words –

And never stops – at all …

Carl Sandburg in the midst of the Great Depression wrote of hope in the commonplace scenes of life-1936:

Hope Is a Tattered Flag

Hope is a tattered flag and a dream of time.

Hope is a heartspun word, the rainbow, the shadblow in white

The evening star inviolable over the coal mines,

The shimmer of northern lights across a bitter winter night,

The blue hills beyond the smoke of the steel works,

The birds who go on singing to their mates in peace, war, peace,

The ten-cent crocus bulb blooming in a used-car salesroom,

The horseshoe over the door, the luckpiece in the pocket,

The kiss and the comforting laugh and resolve—

Hope is an echo, hope ties itself yonder, yonder.

The spring grass showing itself where least expected,

The rolling fluff of white clouds on a changeable sky. 

Have a hope-filled weeken

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Withdrawing from the Game

While the administration’s trade policy may have only an indirect impact on credit union fortunes, it is an example of how public policy can become sideways with America’s long term interests.  And our standing with the rest of the world.

What follows is a brief critique of the underlying assumptions about tariffs and how the rest of the world will react.  The analyst’s point is that poor policy assumptions lead to poor policy outcomes.

Policy is one aspect of the NCUA board’s role. The board no longer exists.  Future meetings have been cancelled and/or called tentative.

The board’s statutory role is to manage the agency.  That also is on hold.

The consequences of these absences of regulatory oversight will not be known for a while.  Meantime some credit unions will take the opportunity to push the envelope on corporate interests.

There will be fallout from this regulatory abdication on policy and agency leadership.  Like the trade example below, the market won’t wait to fill the current vacuum in supervision.

The Challenge of False Policy Assumptions

The following summary of US trade strategy is by William Reinsch at the Center for Strategic and International Studies *CSIS).
Even while uncertainty persists, not only about Trump’s intentions, but also about the half-life of his policies, his actions are being treated as the death knell for the global economy. Trump’s message to the world is that the United States is no longer a reliable partner. The obvious corollary is to find other partners, and that is just what others are doing—with the United States on the sidelines.

 

What is noteworthy is that it appears we are still making progress—in the same way and in the same direction as always. The difference is that the United States is not there; not under Biden and not under Trump. It is typical of Americans to think that we are leading —whatever we are doing is heading down the right path, with other countries running behind to catch up. In this case, however, it appears no one is following.
The new negotiations tell me that the announcement of the old order’s death was greatly exaggerated, and that the case for trade liberalization remains a strong one. Since the current administration is not going to change its worldview, the challenge for U.S. companies is to find ways to stay in the game even as our government has withdrawn from it.

 

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NOW. . . A Poetic Call to Decide

Had not seen our next door neighbors for a couple of weeks.  She updated me about events in their lives while working in the yard.  Her father who had been in hospice for almost a year died two weeks ago in Baltimore.  That took her away for much of the time.

in this same time frame, after 27 years in her career as a government employee, she agreed to take a voluntary early retirement, She is  in her early 50’s and would have preferred to stay in her job.  But given the uncertainty and possible legal changes to benefits, she decided to leave.

A Poet’s Insight

Poet James Russell Lowell wrote about these life altering decisions in his poem, The Present Crisis.  In its musical form as a hymn, it is titled, Once to Every Man and Nation.  The opening stanza:

Once to every man and nation comes the moment to decide,
In the strife of Truth with Falsehood, for the good or evil side;
Some great cause, God’s new Messiah, offering each the bloom or blight,
Parts the goats upon the left hand, and the sheep upon the right,
And the choice goes by for ever ‘twixt that darkness and that light.

Lowell wrote the poem as a protest against the Mexican-American war in 1848.

Life’s Choices In Credit Union Land

Life happens for all.  Sometimes the moral choices are chosen by us.  Other times they are thrust upon one by events.

These turning points can shape the rest of our lives.  My neighbor is now open to finding a new opportunity to help others, perhaps in non-profit work.

In credit union land, these pivotal events are unfolding daily.  NCUA’s leaders are in unchartered territory.  Will they step up or step back?

CEO’s are being tempted with buyouts, some sought and others dangled with incentives to transfer their legacy to another CEO’s command.  Do I do the right thing, or take the money is an ever-present temptation. And the classic rationale, everybody is doing it makes taking the payoffs seem defensible. 

As if the daily industry challenges were not sufficient, all Americans face a growing crisis in democratic governance at the national level.

It is easy to hunker down and just follow distant events on the news.  That is not my problem.  My attention must be on those things I directly control.  One point of Lowell’s poem is that we all have a choice in these moments:

Hast thou chosen, O my people, on whose party thou shalt stand,
Ere the Doom from its worn sandals shakes the dust against our land?
Though the cause of Evil prosper, yet ‘t is Truth alone is strong,
And, albeit she wander outcast now, I see around her throng
Troops of beautiful, tall angels, to enshield her from all wrong.

Importantly, Lowell   expresses  hope that once engaged, we will make the right choice in these critical moments. Because “amid the market’s din” our “souls” will tell us  what is required.  Are we up to the multiple challenges confronting us in our personal, professional and public choices?

We see dimly in the Present what is small and what is great,
Slow of faith how weak an arm may turn the iron helm of fate,
But the soul is still oracular; amid the market’s din,
List the ominous stern whisper from the Delphic cave within,—
“They enslave their children’s children who make compromise with sin.”

Our Moment

In our credit union lives and our duty as citizens, we are not living in an era of business as usual. Now is the moment to decide.

 

 

 

 

 

 

 

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The Question Is . . .

I watched CNN’s ive Saturday broadcast of the New York play Good Night, Good Luck. It portrays CBS’s Edward R. Murrow’s challenge to Senataor Joe McCarthy’s political attacks using anti-communist rhetoric.

Set in the early 1950’s the play recreates an era of political name calling not dissimilar to today’s dscourse.

There is a six-minute final address in front of the curtain by George Clooney who plays Murrow.  The words are from an actual Murrow broadcast.

It begins questionning whether corporate-owned media(TV is dominant) will support critical discussions  in an era of entertainment driven broadcast popularity.

The middle of the “talk” is a collage of quick frames of news clips from the past 70 years interspersed with popular TV shows.

The close is Murrow’s question–not what will politicians do, but rather what are we the people prepared to do?

Here is the final speech from the CNN broadcast.  The message is more urgent than ever for our lives, our work places and our country.

(https://www.youtube.com/watch?v=1hU9bWiazGM)

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Larry Connell, NCUA’s First Chairman, Dies

Larry Connell, appointed by President Carter as the first NCUA Board Chairman in 1977, died this past week in New Hampshire.

After graduating from Harvard in 1958 with a BA degree in economics, Connell worked for the Comptroller’s office(OCC) in ban k regulation. During this time he earned his JD degree from Georgetown University.

Connecticut Governor Ella Grasso appointed Connell as Bank Commissioner in 1975.   In that office he supervised commercial and savings banks, credit unions, and loan companies as well as acting as securities commissioner.

The Credit Union Years

President Jimmy Carter’s appointment of Connell as Chairman of the National Credit Union Administration (NCUA) came at a pivotal time for both credit unions and federal financial regulation.  Congressional legislation converted the NCUA from a single person administrator to an independent federal agency with a three person, Presidentially appointed board.

The same legislation established the Central Liquidity Facility (CLF) within the NCUA.  This was the cooperative system’s public-private partnership establishing lender of “unfailing reliability.”  At that time credit unions did not have access to the national clearing system or to the Federal Reserve

The first NCUA full board included PA Mack, a senior advisor for Senator Birch Bayh,  and Dr. Harold Black an associate professor of finance at the University of North Carolina’s School of Business Administration.

The First NCUA Board in 1979

As NCUA chair Connell was also a member of the Depository Institutions Deregulation Committee (DIDC) which was charged with the deregulation of rates and terms on the savings accounts of all federally insured deposits.  He was Chairman of the new congressionally chartered National Consumer Cooperative Bank (NCB) until his departure from NCUA in early 1982.

In March 1979 Congress established the Federal Financial Institutions Examination Council (FFIEC) to bring consistency to multiple regulators’ oversight of rules and call reports.  Connell was vice chair.  That same year he asked if I would serve as the state representative for credit unions.  The term was for two years and included periodic visits to Washington for state liaison meetings.  The primary discussions were about the wording for the new Truth in Lending and Truth in Savings rules.

A Career in Public – Private Banking Oversight

After leaving NCUA, Larry became President/CEO of the $2.5 billion Washington Mutual Savings Bank in Seattle.   This began a peripatetic 12-year career in bank crisis management as CEO or Director for banks and S&L’s across the country from Washington, Texas, New Hampshire, Maine, Illinois, Michigan and Washington DC.

After his work for domestic inistitutions Connell was deployed as Senior Advisor for the U.S. Treasury Department’s Office of Technical Assistance.  In this role he  advised governments on bank privatization policies and practices in eastern and central Europe, as well as in Russia, Turkey, Colombia, South East Asia and Africa.

At the Founding and the Transition

October 1981 welcome reception for Ed Callahan with P.A. Mack and Larry Connell

Larry was at the founding of the NCUA as the agency transformed to an independent board.  At his departure his successor, Ed Callahan, spoke of his vital contribution:

While Larry Connell’s departure will be a major loss to NCUA and to the credit union movement, his visionary ideas will continue to influence the financial community. Larry’s expertise in so many areas–economics, law and banking–helped to elevate the stature of NCUA during one of the watershed periods in American financial history.

An ever expanding group of people—from government, industry and the media—now actively seek the Agency’s views on a variety of economic and financial matters, not  just credit union affairs.  I can’t pay him a higher compliment. (The NCUA Review February 1982, page 1)

However Larry did continue serving credit unions.  He was an original trustee of the TCU family of Mutual Funds launched in 1988 by Callahan & Associates.

Larry  laid the foundation for responsive, experienced, and professional NCUA leadership. He believed in credit unions as a vital alternative for individuals and communities left behind by the for-profit sector.  He was a friend, a colleague and always open for intelligent conversation.

The NCUA Board’s leadership and support of credit unions.

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Musical Moments of America at Its Best

For the anniversary of D-Day. Written in 1942 by Irving Berlin, I Paid my Income Tax Today supported the country’s income tax collection efforts during World War II.

The rights  are stilll owned by the Internal Revenue Service which distributed the song widely on its publication.

Proclaiming the patriotic virtues of paying taxes, this zippy little tune makes being “squared up with the USA” sound positively delightful. Clearly, the  national dialogue surrounding taxes, especially in  credit unions, has gone in a different direction.

(https://www.youtube.com/watch?v=IIT3xnYbmzQ&t=8s)

America’s Rising Generation at its  Best

The Lion Sleeps Tonight (Wimoweh)

To spark your day. The Young People’s Chorus of New York City sing at the Lincoln Center in 2021. These  are the future of the country.  Feel the joy and see the promise. I love the conductor’s enthusiasm.

(https://www.youtube.com/watch?v=erCq44KSEHQ)

An Encore

How Can I keep from Singing

Performed at the 16th Annual Anabaptist Choral Festival 2023 of Shenandoah Christian Music Camp (VA).  

The choir covers their faces to represent the text which speaks of darkness closing in around us: “What though the tempest loudly roars, I hear the truth, it liveth! What though the darkness ’round me close, Songs in the night it giveth.”

And the words of hope: I hear tne bells of freedom ringing; how can I keep from singing? 

(https://www.youtube.com/watch?v=Cw-ycev482k&t=9s)

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NCUA Flying Solo

On May 22, the NCUA held its first public board meeting with its one and only member, Chairman Hauptman, overseeing staff reports.

This was the first public meeting since February, where the only agenda item then was the NCUSIF  update. Both March meetings were closed.  The March 27 and April 17 open meetings were  cancelled.  On April 16 President Trump fired the two democratic board members. That event is now being challenged in court with no specific timetable for resolution.

Observations from the May 22 Meeting

At the meeting’s conclusion Chairman Hauptman assured the public that NCUA was fully capable of meeting its statutory responsibilities.  He repeated the message from an earlier NCUA press release  on April 18:

Please be assured that the NCUA has precedent and standing delegations of authority in place to continue performing all operational and statutory requirements under the authority of a single Board Member. 

During the Bush Administration (2001–2002), Chairman Dennis Dollar acted as a sole Board Member. He held a Board meeting, voted, and took several actions, both administrative and operational. 

However the circumstances between these two situations is entirely different. In 2002, both nominees filling the expired terms were known and required only Senate confirmation. That happened very quickly in March.  This time, confirmed nominees have been fired creating two “vacancies.”  These two board members are challenging the President’s  removal in court.

Chairman Dollar held only one board meeting in which he received an NCUSIF  briefings and then tabled three other actions until a full board was in place.

Moreover, in a May 25, 2005 Delegation GEN 5 update by General Counsel Bob Fenner,  all delegations of Authority in the final paragraph is subject to the phrase “In a state of national emergency, all authorities retained by the board are delegated to . . .”  Are we-NCUA- in a state of national emergency? 

Hauptman’s situation is unique in how the vacancies occurred, the seemingly open-ended time period for single leadership, the dramatic internal staff and reorganizations underway, and the uncertain legal status of the fired members-especially if returned to their positions.

Board Item One: NCUSIF Update

The publc format of the March financial NCUSIF   update was changed. A  series of “dashboard” charts showing five-year trends for key balance sheet and performance ratops was unveiled.

These presentations provided interactive “eye-candy” but no increased transparency for how critical numbers such as the increase in loss reserves of $5.4 million were calculated. The loss reserves to insured shares ratio far exceeds the long term loss rate on insured savings.

Most importantly while reporting zero losses in the first quarter, there was complete silence on the recent liquidation of the $ 47 million Unilever FCU. This was finished in such haste that there was no conservatorship or apparent effort to find a willing merger partner.  The situation echoes the $13 million unexplained loss (20% of assets) at the $65 million  Creighton FCU in mid 2024.

The most important  issue, the underperformance of the NCUSIF portfolio, was documented in the new dashboard slide Portfolio Performance. It shows the NCUSIF’s return has trailed significantly the 90 -day T bill rate since mid 2022.  The year-to-date yield in the first quarter of 2.59% is significantly below the overnight return as well.

NCUA CFO Schied said staff’s policy was to continue the investment ladder out as long as ten years in order to ensure “a steady fund income.”  This ladder generates “steady income” that has trailed market returns by over 2.0% or more as shown in the bottom graph for over three years.

There was no reference to either interest rate risk (IRR)or ALM, the two basic factors in managing any portfolio. Especially one which cannot be adjusted once invested.  There is an obvious need for better policy and experienced investment management.

Chairman Hauptman likes to describe NCUA as an “insurance company.”  It would be helpful if there was much more transparency and thoughtful discussion about how this “company” manages its $23 billion  asset on behalf of credit unions.  This underperformance damanges both the fund’s finances and credit union’s returns.

Board Item Two: The Voluntary Separation Program

The staff stated that the voluntary layoff program had been agreed to in the March 21 closed full board meeting.  By  the May meeting the employee responses were  known.

A total of 250 employees elected to leave voluntarily. There were no forced departures.  Almost all will be placed immediately on administrative leave with full pay and benefits but doing no work.  This paid leave status extends until December 31, 2025.  This means most of these departing employees will be paid in full while not contributing for at least six months orlonger.

To incentivize the two options, there was a $50,000 bonus provided to each participant.  In addition, all will receive their 2025 merit bonus which will average $15K for junior staff and from $29K-$42K for senior staff.

In addition Hauptman announced there would be no restrictions on these employees’ future employment so they might find another job while on leave. He commented, “They might even be paid more than what they earned at NCUA.”

As explained by Executive Director Larry Fazio, the program was designed by the staff for the staff. There will be no budget savings for 2025.  The special severamce benefits will fully utilize the  NCUA’s operating funds for this year. The estimated total  of $75 million in potential “savings” means the average cost for the 250 departures was $300,000 each.

Staff was ambivalent about whether there will actually be anything close to these savings in 2026.  The gross cost of $75 million paid departing employees will be offset by new contracts, salary increases, new hires, technology investments and other expenditures setting up a new future state for the Agency.  In other words any savings are yet to be determined.  And  the generous terms of the 2025 voluntary departures will leave no surplus from the current year.

There were no specifics provided for how NCUA’s future organzarion  will be structured.  No departments closed or consolidated, no programs (eg. consumer exams, DEI conferences, etc) to be reduced. No reference to any DOGE recommendations for eliminating unnecessary expenses.

There ws  one specific example of change however.  Thiswas to extend the time between on-site exams based on a credit union’s net worth.  For credit unions $1-15 billion in assets, the exam interval would be from 12 to 18 months.  For less than $1 billion, the period between field contacts would be 14 to 24 months.

This one concrete step will reduce the agency’s in person safety and soundness exams as long as the net worth seems sufficient-above 10%.  This first line of defense for the NCUSIF is being weakened at a time when the sudden falures of Unilever and Creighton FCUs are still unexplained.

 Flying Solo & Landing Safely

Thia is not a business as usual moment  in this era of single board leadership. This circumstance  is exacerbated by the fact that Chairman Hauptman’s term expires in August of this year.  What happens then?  An acting Chair?  Who designs and follows through on NCUA’s future state?  Staff whose 25% voluntary separations outcome used up this enire year’s budget?

In a March 3, 2025 CUSO Magazine article,  Hauptman’s agnostic approach to the future of credit unions was presented:

On the topic of the NCUA’s future, Hauptman declined to speculate or advocate for one outcome or another, noting that while he does not shy away from controversial topics, he keeps himself from getting into debates when he has no authority over the outcome. The fate of the NCUA, he argues, is outside his control and lies in the hands of Congress and the White House.

Congress created the NCUA in 1970, and there were 27,000 credit unions operating before then…my only view on it is that it is important for people to understand that credit unions are different. So whoever in the future is going to be regulating needs to be aware of this.” 

In an April 23, 2025 memo to All NCUA Staff, Hauptman wrote in part: NCUA will be returning to the headcount that it had a few years back—but be assured we know it takes teamwork and creativity to “land the plane safely.” And NCUA is doing that quite well thus far.” 

The outcome from the first solo board meeting since 2002 suggests that there is still a great deal of turbulence.  It is not clear who is piloting the plane or where it is trying to land.

This first flyby of the pubic landing zone with credit unions leaves more questions than answers.  The future of NCUA with its implications for credit unions and their 100 million members seems at best cloudy.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Should Credit Unions Facilitate the Purchase of Crypto Currencies?

A number of credit unions already partner with crypto exchanges enabling members to purchase and store crypto.  More are considering the service. The fees can be attractive with apparently little risk.

But should this be a credit union endorsed activity? That is a question that arises in other contexts. For example other activities some might perceive as outside core purpose include  supporting state authorized cannabis banking,  interval vacation home ownership or various forms of legal betting.

Crypto issuance and lighter regulation are a priority for the Trump administration and for his family’s personal investing.

Yesterday substack columnist Jared Brock published his analysis of the pros and cons of  crypto currencies.  Following are excerpts from the article.

Can Bitcoin Save Us?

One model of currency creation is to let everyone privately create money and let the market decide.

This is where Bitcoin comes in.

Cryptocurrencies are pseudo-money built on a blockchain, which is a trustless, decentralized, encrypted digital spreadsheet.

Anyone can privately create one.

And boy, do they.

As of this morning, there are over 16,560,000 cryptocurrencies and tokens, with 57,335 new ones coming online just yesterday.

Nearly 100% of these are straight-up scams.

Allowed unbridled private money creation has all sorts of challenges:

  1. Obviously, it leads to a proliferation of fraud. Why would we want to put our young people, old people, unintelligent people, and vulnerable people at further risk of exploitation? . . .
  2. Market instability. It’s hard for people and businesses to plan and budget effectively when there are millions of currencies all whipsawing in price.
  3. Inequality. Rich people and rich corporations have more resources to create and promote their currencies, even if they’re inferior products. This further concentrates economic power and grows economic inequality.
  4. Transaction costs. Mastercard, Visa, Stripe, and the rest of the payments processing ilk already rob a huge percentage of our money, not unlike the moneychangers that Jesus drove out of the temple. With tens of millions of currencies in circulation, virtually every purchase would require several currency exchanges.
  5. Monetary policy. When all money is created privately, democracies lose the ability to direct the economy toward national goals and objectives like ending poverty.
  6. Currency wars. When there are millions of currencies fighting for customers, it incentivizes all of them to undermine and devalue their competitors to gain an advantage.

You don’t have to believe me.

You can just look at history.

America used to do private money creation.

At one point, nearly every city in America had its own city bank that issued its own currency.

Each value of each bank’s money was based on its reputation and financial stability.

It was the Wild West, and it led to endless bank runs, millions of bankruptcies, untold suicides, and the creation of the fraudulent, quasi-government (but actually private) money monster called the Federal Reserve.

Can you hear the Bitcoiners howling?

“Yeah, but Bitcoin has a limited supply!”

Right.

Bitcoiners have an autistic obsession with the fact that Bitcoin has a limited supply.

“Only” 2.1 quadrillion satoshis will ever exist.

My note: this is where I do not understand Brock’s logic.  This is the stated limit for bitcoin creation- 21 million. Is he speculating about infinite computer creation?)

How very impressive.

That’s 2,100 trillion.

That’s 2.1 million billions.

That’s 2.1 billion millions.

That’s more than 10 times all the money currently in existence.

So let me get this straight — you hate U.S. bankers for creating $21.86 trillion out of thin air… but you’re okay when someone else creates 96Xs more money out of thin air? Are you demented?

Bitcoiners insist they’re different, but it’s actually just more of the same — economic injustice and exploitation for all. . .

And what are all these Bitcoiners doing with all their hoarded Bitcoin?

They’re just hoarding it.

They’re lending it out on decentralized finance platforms for interest.

Millions of Bitcoiners have zero plans to ever sell or spend a single Bitcoin. The plan is to lock it in digital vaults as a reserve currency, then create digital Bitcoin-backed tokens that they can lend at interest.

In other words, they want to be the new central banksters, the new monopolistic overlords of finance who decide who gains access to money and who gets shut out. . .That’s the problem with all these Bitcoin-worshippers.

They still love money; they just call it by a different name. . .

Conclusion

Obviously, everything has costs and benefits.

I’m not against Bitcoin. . .

I’m against monopolization. I’m for sharing.

And frankly, millions of Bitcoiners are far-right libertarian rules-free-market hyper-individualist sociopaths. I wouldn’t want to be forced into using a single currency on their terms any more than on central bankster terms. . .

Thus, why I prefer sovereign money — democratic, accountable, safeguarded, fair, just, non-exploitative, accessible, nation-building currency.

I want honest money.

What do you think?  Is this a valid analysis for credit union’s contemplating facilitating crypto purchases?