Tokens of Wisdom

40 Episodes
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By: Dave Rothschild

Do you love investing? Ever thought about turning that passion into a business? Listen up to learn to navigate the legal loopholes in forming, launching, and running a private investment fund, including considerations unique to digital asset/crypto funds. Dave Rothschild is a partner at Cole-Frieman & Mallon, one of the country's premier boutique investment management law firms with deep experience in traditional assets, as well as esoteric asset classes like digital assets. For questions or comments, email [email protected]. Visit our website: https://colefrieman.com

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Episode 90: Perpetual Futures, Explained with Hugo Stack, Mecone
#90
Today at 3:00 PM

Episode 90: Perpetual Futures, Explained with Hugo Stack, Mecone

 

Hugo Stack, President & Co-Founder of Mecone joins the Tokens of Wisdom Studio to shed some light on the intersection of prediction markets and perpetual futures. Mecone leverages prediction market data to build the infrastructure exchanges need to expand their Perp offerings, broadening the assets their users can trade. Hugo shares his story and how his company is working to make everything tradeable.

 

Key Points From This Episode:

 

What is a future contract?What is a Perpetual Fut...


Episode 89: SEC Proposal to Update the Custody Rule
#89
10/12/2026

Episode 89: SEC Proposal to Update the Custody Rule

 

On October 1, the SEC proposed updates and revisions to the Custody Rule that would – at long last – address some of the most glaring issues we’ve been talking about for years. 

 

While it wouldn’t solve every problem crypto RIAs face, this is an extremely positive proposal for the industry. It would remove much of the biggest regulatory uncertainty for crypto RIAs, and would firmly establish us on the second rung of the regulatory ladder.

 

Key Points From...


Episode 88: Does California's DFAL Apply to Digital Asset Funds and Managers?
#88
09/16/2026

Episode 88: Does California's DFAL Apply to Digital Asset Funds and Managers?

 

California's Digital Financial Assets Law ("DFAL") creates a fun new registration regime for certain businesses in the digital asset ecosystem. 

 

Specifically, it requires registration for any person engaging in, or holding itself out as engaging in, any digital financial asset business activity with or on behalf of a California resident with several specific exemptions.

 

Key Points From This Episode:

 

Defining some important terms.What does registration entail?So, does this...


Episode 87: A Brave New World with Frank Napolitani, Cartesian
#87
09/02/2026

Episode 87: A Brave New World with Frank Napolitani, Cartesian

 

Frank Napolitani, Managing Partner of Cartesian, joins the Tokens of Wisdom Studio to shed some light on the fascinating times afoot for investment professionals and the firms that service them. Frank shares insights on the ongoing tokenization of securities, unique considerations when trading on prediction markets, and the quickly approaching 23-hour trading day and rolling market close.

 

Key Points From This Episode:

 

DTC's ongoing efforts in tokenization of securities, and what it means for fund man...


Episode 86: The Annual Review with Annie Kong, IQ-EQ
#86
07/09/2026

Episode 86: The Annual Review with Annie Kong, IQ-EQ

 

Annie Kong, Regional Lead (West) of Regulatory & Compliance, U.S. at IQ-EQ joins the Tokens of Wisdom Studio to explain what’s actually involved in an investment adviser’s annual review. Annie shares insights on the importance of ongoing compliance reviews, how to approach annual reviews proactively, and the ever-evolving regulatory landscape.

 

Key Points From This Episode:

 

Ongoing compliance review vs. check-the-box approachBreaking down the annual review into quarterly testingTailoring reviews to specific manager strategies and risksSE...


Episode 85: Qualified Client Thresholds Are Going Up
#85
06/01/2026

Episode 85: Qualified Client Thresholds Are Going Up

 

Quick housekeeping episode today. The SEC just increased the qualified client thresholds, effective June 29, 2026 – mere weeks away. If you charge a performance allocation — or if you invest in a fund that does — this affects you. It's not complicated, but the deadline is real, and the numbers moved more than they usually do. Thanks, inflation.

 

Key Points From This Episode:

 

What Is a Qualified Client?Why Does It Matter?What are the New Thresholds?Brief explanation of the Grandfath...


Episode 84: Crypto Prime Brokerage with Matt Boyd, Coinbase
#84
04/29/2026

Episode 84: Crypto Prime Brokerage with Matt Boyd, Coinbase

 

Matt Boyd, Head of Prime Finance at Coinbase joins the Tokens of Wisdom Studio to explain all things crypto prime brokerage and how to navigate the transition from managing your own money to managing a fund. 

 

Key Points From This Episode:

 

Crypto custody and the importance of qualified custodians.How Coinbase Prime connects custody, execution, financing, and operations.Best execution in fragmented crypto markets.Leverage and risk management in crypto trading.Staking assets and collateralization in cryp...


Episode 83: Outsourced CFOs with Eugene Tetlow, V17
#83
04/21/2026

Episode 83: Outsourced CFOs with Eugene Tetlow, V17

 

Eugene Tetlow visits the Tokens of Wisdom Studio to explain how outsourced CFO shops help new and established fund managers. Eugene is the CEO of V17 Advisors, but he is more widely known for his critically acclaimed role as the first guest host in Tokens of Wisdom history. 

 

Key Points From This Episode:

 

How does an outsource CFO engagement work? How does it differ from what a fund admin does?What is The Real Value of Outsourced CFO...


Episode 82: Reasonable Expectations: How the SEC (Now) Applies Howey to Crypto
#82
03/24/2026

Episode 82: Reasonable Expectations: How the SEC (Now) Applies Howey to Crypto 

 

By now, you’ve all heard about the latest SEC release on the application of federal securities laws to certain crypto assets and related transactions. You’ve probably read 12 law firm memos and seven million hot Tweets on the topic by now. But few of them answer the burning question: what does this mean for digital asset fund managers? Well, today’s your lucky day because Tokens of Wisdom is here to answer that very question.

 

Key Points Fr...


Episode 81: Slopeside with the Summit Syndicate
#81
03/09/2026

Episode 81: Slopeside with the Summit Syndicate

 

Different episode today, featuring slopeside interviews from our second Summit Syndicate trip of 2026.

 

The Summit Syndicate is a Lake Tahoe day trip event co-hosted by Cole-Frieman & Mallon, Eisner Amper, V17 Advisors and Juniper Square. We chartered a bus from SF, drove to Northstar, skid a full day and drove back to the city.   

 

We had excellent turnout from industry friends old and new, and even if you didn’t make the trip you can re-live it right here, on Tokens...


Episode 80: Fair Investment Practices by Venture Capital Companies Law
#80
02/11/2026

Episode 80: Fair Investment Practices by Venture Capital Companies Law

 

Quick hit today to discuss California's new Fair Investment Practices by Venture Capital Companies Law (“California Regulatory Overreach” as I call it), which mandates venture capital firms to collect and report demographic data about the founding teams of the companies they invest in. I outline the requirements, implications, and potential challenges that VCs may face due to this law, and share my concerns about its practicality and the reliability of the data collected.  

 

Key Points From This Episode:

 <...


Episode 79: Liberate the Yield with Ronald Falls, Jr.
#79
01/28/2026

Episode 79: Liberate the Yield with Ronald Falls, Jr.

 

Ron Falls visits the Tokens of Wisdom Studio to shed light on the epic showdown of Brian vs The Banks. We discuss the controversy surrounding yield provisions for stablecoins, the banking industry's response, and the potential future of financial services as digital assets gain traction. 

 

Key Points From This Episode:

 

The Clarity Act aims to provide a regulatory framework for digital assets.Stablecoin issuers are prohibited from paying interest to holders under the Genius Act.Exchanges have...


Episode 78: Outsourced Compliance with Fizza Khan, Silver Regulatory Associates
#78
01/13/2026

Episode 78: Outsourced Compliance with Fizza Khan, Silver Regulatory Associates

 

Fizza Khan from Silver Regulatory Associates visits the Tokens of Wisdom Studio to enlighten us about all things compliance. From deciding when to engage an outsourced provider to the nuts and bolts of compliance policies and navigating SEC exams, Fizza shares the wisdom. 

 

Key Points From This Episode:

 

How does an outsourced compliance engagement work? Compliance policies – is it one size fits all, or are they custom to the adviser?What goes into compiling an effecti...


Episode 77: All the Wisdom from 2025
12/23/2025

Episode 77: All the Wisdom from 2025

 

It’s a ho-ho-holiday clip show! So many distinguished guests joined the show this year to share their wisdom. I figured, why not share some of their best advice in one EOY clip show extravaganza. If you’re listening to this – not watching – see timestamps below so you know who you’re listening to.

 

Key Points From This Episode:

 

4:22: Bert McCooey, Ascent (Fund Admin)
 Full episode: https://www.youtube.com/watch?v=sNskOufkTE4&t=282s 5:11: Salman Ali, CBIZ (Auditor)
 F...


Episode 76: SF Gross Receipts Tax with Kevin Leiske, Cole-Frieman & Mallon
12/15/2025

Episode 76: SF Gross Receipts Tax with Kevin Leiske, Cole-Frieman & Mallon

 

On the very first Intrasquad edition of Tokens of Wisdom, my partner Kevin Leiske joins the show to tell us about recent changes to San Francisco’s gross receipts tax. Spoiler alert: even if you are an investment manager with zero operations in SF, the City is trying to extract its pound of flesh from any SF-based LPs. 

 

Key Points From This Episode:

 

What is a gross receipts tax? What is changing about SF’s gross r...


Episode 75: Cayman Directors with Darragh Murphy, Marfire
12/09/2025

Episode 75: Cayman Directors with Darragh Murphy, Marfire

 

Darragh Murphy from Marfire joins me in the Tokens of Wisdom Studio to tell us all about the wonderful world of Cayman fund directors. From choosing the right director, to working with them once chosen, to navigating the complexities across a fund’s lifecycle, Darragh shares the wisdom. 

 

Key Points From This Episode:

 

What is the role of an independent director in the Cayman funds space? Does engaging an independent director mean I am losing control of my fund...


Episode 74: Cayman Funds with Patrick Colegrave, Forbes Hare
#74
11/25/2025

Episode 74: Cayman Funds with Patrick Colegrave, Forbes Hare

 

Patrick Colegrave joins me in the Tokens of Wisdom Studio to discuss all things Cayman funds. From local regulatory requirements to investor expectations to setup costs, Patrick covers the ins and outs of Cayman fund formation. 

 

Key Points From This Episode:

 

Why should I choose Cayman over BVI (or should I?)?Does my Cayman fund always need to register with CIMA?What does the formation process cost/involve?What are the most common entity types for Caym...


Episode 73: Prime Brokerage with Harry Shillingford, Marex
#73
11/13/2025

Episode 73: Prime Brokerage with Harry Shillingford, Marex

 

My old pal Harry Shillingford from Marex joins me in the Tokens of Wisdom Studio to talk about the intricacies of prime brokerage. We delve into scintillating topics like “what does a prime broker actually do?” (answer: a lot) and “should I draw fund inspiration from Field of Dreams?” (answer: no). Harry also shares some serious wisdom on budgeting and choosing the right broker. 

 

Key Points From This Episode:

 

Difference between an introducing broker and a prime broker.What...


Episode 72 - The Main Event
#72
10/24/2025

A special episode that has nothing to do with funds or law and everything to do with baseball glory.


Episode 71: Fund Manager Insurance with James Tallarico and Kevin Flasch, Risk Strategies
#71
10/15/2025

Episode 71: Fund Manager Insurance with James Tallarico and Kevin Flasch, Risk Strategies

 

Joining me in the Tokens of Wisdom Studio today are James Tallarico and Kevin Flasch from Risk Strategies to discuss the evolving landscape of insurance in the crypto space. They delve into the differences between insurance brokers and providers, the challenges faced in obtaining adequate coverage for crypto-related businesses, and the importance of tailored insurance policies. The conversation covers essential coverages for fund managers, the evaluation of insurance costs, and common mistakes made by new managers when purchasing insurance. 

 

<...


Episode 70: The SEC Knows Action
#70
10/08/2025

Episode 70: The SEC Knows Action

 

Last week we saw the SEC release not one but two No Action Letters that were each deeply positive for the crypto industry.

 

Tune in to today’s episode for a quick recap of each and a reminder of where we currently stand on the regulatory ladder.

 

Key Points From This Episode:

 

DoubleZero No Action Letter.Crypto custody No Action Letter.

 

Disclaimer:

 

This show is for informat...


Episode 69: Fund Valuations with Joe Brennan, Houlihan Capital
#69
09/24/2025

Episode 69: Fund Valuations with Joe Brennan, Houlihan Capital

 

Joining me in the Tokens of Wisdom Studio today is Joe Brennan, a director at Houlihan Capital, to discuss the intricacies of fund valuations, particularly in the context of crypto assets. 

 

Key Points From This Episode:

 

The importance of establishing proper valuation policies. When would a fund need specialized valuation services?When is the right time to engage a provider like Houlihan?How do they work with auditors and other fund service providers?How to choose the r...


Episode 68: Crypto Fund Audits with Gautam Ganeshan, KPMG
08/27/2025

Episode 68: Crypto Fund Audits with Gautam Ganeshan, KPMG

 

Today I’m joined by Gautam Ganeshan from KPMG to talk all about digital asset fund audits! 

 

Key Points From This Episode:

 

Are crypto assets categorized in the same Level 1, Level 2, Level 3 framework as traditional assets? What are examples of each Level in the crypto world?How does the scope of a crypto fund audit compare to a tradfi fund audit?What are the unique challenges involved in auditing a fund with a digital asset strategy?Valuati...


Episode 67: SEC Commissioner Hester Peirce
#67
07/23/2025

Episode 67: SEC Commissioner Hester Peirce

 

I am honored to welcome SEC Commissioner Hester Peirce – Crypto Mom herself – to the Tokens of Wisdom Studio today to talk to us about crypto, regulation, zombies (not really) and parenthood. You don’t want to miss this one. 

 

Key Points From This Episode:

 

How have the SEC’s vibes shifted so quickly?How can we move up the regulatory ladder toward formal rulemaking?What should we do about the custody rule?What is the best way for industry participants...


Episode 66: BVI Funds with Phil Graham, Harneys
#66
07/09/2025

Episode 66: BVI Funds with Phil Graham, Harneys

 

When I set out to do this show, my goal was to arm aspiring fund managers with the information they need to launch and operate a fund.

 

In the legal realm, I happen to possess a lot of that information from my day job, but there’s so much more that goes into launching and operating a fund. And wise though I may be, my area of expertise doesn’t cover it all. So I’m going to bring in some friends to share...


Episode 65: The Zombie Episode (Three Rungs of the Regulatory Ladder)
#65
07/02/2025

Episode 65: The Zombie Episode (Three Rungs of the Regulatory Ladder)

 

For as long as I’ve worked in crypto, the industry has been plagued by the dreaded REGULATORY UNCERTAINTY. That is, apparently, until the last couple months. All of a sudden I’m seeing clients putting stuff like “Regulatory Clarity Achieved!” in marketing decks and celebrating the demise of uncertainty’s reign. Maybe pump the brakes a bit. I don’t think we’re quite there yet.

 

The new SEC has certainly moved quickly to dismantle the anti-crypto reputation its predecessors...


Episode 64: Fund Taxation with Colleen Fay, Withum
#64
06/25/2025

Episode 64: Fund Taxation with Colleen Fay, Withum

 

When I set out to do this show, my goal was to arm aspiring fund managers with the information they need to launch and operate a fund.

 

In the legal realm, I happen to possess a lot of that information from my day job, but there’s so much more that goes into launching and operating a fund. And wise though I may be, my area of expertise doesn’t cover it all. So I’m going to bring in some friends to share...


Episode 63: Hedge Fund Offering Terms, Part 2: Liquidity
#63
06/18/2025

Episode 63: Hedge Fund Offering Terms, Part 2: Liquidity

 

Today is the second in a series of Tokens of Wisdom episodes walking through the main offering terms for an open-ended fund, aka a hedge fund. 

 

One of the first things I do with new fund clients is take them through a fund questionnaire to determine the offering terms for their new fund. This is usually a one hour conversation, at the end of which I have most of what I need to draft the fund’s offering documents. Since I know ToW l...


Episode 62: Fund Audits with Salman Ali, CBIZ
#62
06/03/2025

Episode 62: Fund Audits with Salman Ali, CBIZ

 

When I set out to do this show, my goal was to arm aspiring fund managers with the information they need to launch and operate a fund.

 

In the legal realm, I happen to possess a lot of that information from my day job, but there’s so much more that goes into launching and operating a fund. And wise though I may be, my area of expertise doesn’t cover it all. So I’m going to bring in some friends to share...


Episode 61: Hedge Fund Offering Terms, Part 1: Compensation
05/20/2025

Episode 61: Hedge Fund Offering Terms, Part 1: Compensation

 

Today is the first in a series of Tokens of Wisdom episodes walking through the main offering terms for an open-ended fund, aka a hedge fund. 

 

One of the first things I do with new fund clients is take them through a fund questionnaire to determine the offering terms for their new fund. This is usually a one hour conversation, at the end of which I have most of what I need to draft the fund’s offering documents. Since I know ToW l...


Episode 60: Fund Administration with Bert McCooey, Ascent
#60
04/30/2025

Episode 60: Fund Administration with Bert McCooey, Ascent

This is an exciting day in Tokens of Wisdom history! Not only do you get to see my real-life face, but you also get the unparalleled wisdom of Bert McCooey from Ascent Fund Services.

When I set out to do this show, my goal was to arm aspiring fund managers with the information they need to launch and operate a fund.

In the legal realm, I happen to possess a lot of that information from my day job, but there’s so much more th...


Episode 59: Peeling Layers
#59
04/21/2025

Episode 59: Peeling Layers

At the federal level, the tables are turning faster than at a vintage Tiesto performance: it’s honestly hard to keep up with how quickly the federal government has done a total 180 on crypto.

Key Points From This Episode:

What was the now-disbanded National Cryptocurrency Enforcement Team?How is the United States similar to an onion?What’s happening beneath the federal layer, at various state regulators?NY, CA and OR flexing their enforcement muscle to the collective groan of the crypto industry.

Disclaimer:


Episode 58: Yet Another CTA Update (Yawn)
#58
03/25/2025

Episode 58: Yet Another CTA Update (Yawn)

 Last time I spoke to you about the CTA, I said I wanted to discuss it about as much as I wanted a hole in the head. A little over a month later, nothing has changed. In my mood that is.

But alas, much has changed in the world of required BO reporting, so here I am standing in front my mic and talking about it again.

 Key Points From This Episode:

 FinCEN’s New Interim Final Rule.

Who’s in scop...


Episode 57: Fixing the Hole in Your Net (And More!)
03/25/2025

Episode 57: Fixing the Hole in Your Net (And More!)

If you thought the kinder, gentler SEC was only going to be kinder and gentler to the crypto community, you thought wrong. Today I’m going to briefly summarize two recent SEC actions that relaxed marketing-related rules: clarifying requirements for marketing materials and elements of 506(c).

 Key Points From This Episode:

What is the SEC’s marketing rule?What are case studies?SEC FAQ from early 2023 muddies the waters.The trouble in calculating case studies net of fees and expenses.SEC FAQ f...


Episode 56: Interpretive Clarity
#56
03/06/2025

Episode 56: Interpretive Clarity.

By now, you’ve probably heard the latest news from the sunshine and rainbows SEC: Meme coins are not securities!  This is great news for the crypto community, which has a little more clarity today on how the SEC will interpret securities laws as they apply to digital assets.

 

But is this the regulatory clarity we’ve long clamored for? Not quite…

 

Key Points From This Episode:

 

What does the SEC’s Meme Coin Statement say?Reasons to be excited.Reas...


Episode 55: Sunshine and Rainbows…from the SEC
#55
02/27/2025

Episode 55: Sunshine and Rainbows…from the SEC.

 

Just a couple short weeks ago I told you all about President Trump’s executive order on crypto, which was heavy on happy speak and light on substance.  

 

Of course, literally as I was recording that episode, the SEC started putting its money where its mouth is. Indeed, since I started speaking into that mic a couple weeks ago the SEC has: Repealed SAB 121, restarted its crypto task force, paused the suit against Binance, and straight-up dropped lawsuits or investigations into Coinbase, RobinHo...


Episode 54: Guess Who's Back
#54
02/20/2025

Guess Who’s Back

 

Episode 54: Show Notes.

 

It’s true that I wanted to release this episode about as much as I want a hole in the head. But, I did promise you multiple times that I would keep you updated on the dumpster fire of the Corporate Transparency Act and…a liar I am not.

 

Here’s the TL;DL(“listen”): The CTA is back on, and initial BO reports are due on March 21, 2025 for most entities.

  

Key Points From T...


Episode 53: A New Sheriff
#53
01/24/2025

A New Sheriff 


Episode 53: Show Notes.

 

We went three whole days into Trump Administration 2.0 without the creation of a strategic bitcoin reserve, an announcement ending all federal lawsuits against crypto industry participants, and without any major crypto news. In fact, well into day 4 of the administration, the scoreboard looked like this: Trump Meme coins: 2; Executive action supporting crypto: 0.

 

Then on January 23, 2025, Trump issued an Executive Order titled, “STRENGTHENING AMERICAN LEADERSHIP IN DIGITAL FINANCIAL TECHNOLOGY”.

  

Key Points From This Epis...


Episode 52: AI Policies for Investment Advisers
#52
01/09/2025

Everyone wants in on the AI craze – in addition to being the latest buzzy trend, AI is a technology that can actually think for you (or at least, trick people into thinking it’s thinking). Given the potential time and money savings AI can generate, a business owner like you might be negligent for not exploring how it could help their business. But before you go too hog wild, listen to today’s episode for a boring dose of caution. How’s that for a tag line?!

  

Key Points From This Episode:

Quick Corp...


Episode 51: 2024 Year-End Overview
#51
12/19/2024

As you all prepare to hunker down by the fire, sip your egg nog and enjoy the company of your dearest friends and family members, throw in your earbuds, turn up the volume and unwrap this auditory gift recapping the year that was in fund and cryptoland 2024!

  

Key Points From This Episode:

Recapping the rosiest crypto developments from 2024.
 

Bitcoin’s meteoric rise.Clearer regulatory skies. Judiciary ascendant.

 

Guessing at what the future holds in 2025.
 

Strategic Bitcoin reserve?Future of the Safeguarding Rule proposal?Legislation??

 

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