May. 11th, 2019

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Matt Levine talks a bit about TurnKey Jet asking the SEC if it was okay to handle its rewards system in a particular way, because it involves a crypto token of some sort, and those are suffering from a bad reputation and the company would like to not get in trouble. The SEC issued a letter about this saying, this is okay.

https://www.bloomberg.com/opinion/articles/2019-05-10/the-unicorn-worriers-weren-t-wrong

This is not a particularly humorous column, but it was informative. One effect of the letter and the way it was worded was:

“But Peirce’s point is that, before the TurnKey Jet ruling, nobody was going around worrying that gift cards were securities. Now they might have to, and they might have to check with the SEC to make sure that all of the features of their gift-card program are compliant.”

Meanwhile, over at the NYT, there is an article about rewards programs being hacked and points being spent:

https://www.nytimes.com/2019/05/11/business/rewards-loyalty-program-fraud-security.html

We have a lot of regulation around creating new dollars (and other currencies have similar). We have a lot less regulation around creating new airline miles (altho more than their used to be) and even less around rewards involving cups of coffee, donuts, stays in hotels.

Perhaps we are about to enter an era in which we recognize that there is an awful lot of stored value here, and it is inadequately audited and monitored. Perhaps.

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