Bullish

Phase A — Understand the business

Lens 1 · Company Overview

Bullish is an institutionally-focused, regulated digital-asset platform operating two pillars under two brands:

1. Market Infrastructure ("Bullish") — a regulated spot + derivatives exchange built on a single global central-limit order book fused with automated market making (AMMI) for deep, predictable liquidity. Revenue is captured via "a combination of volumes, spreads, and transaction fees." It added crypto options (Q3 2025) and US spot trading (Q4 2025). A fast-growing Liquidity Services product sells subscription-based AMM liquidity provisioning to stablecoin / RWA / token issuers (e.g., Solana) — described as one of the fastest-growing offerings in 2025.
2. Information Services ("CoinDesk") — Indices (CoinDesk 20, the XBX Bitcoin reference rate, FCA-authorized CCIX via the CCData acquisition; mandates for 15 new ETFs in Q4 2025 incl. ARK and ProShares, plus an ICE partnership for 7 index-futures contracts), Data (10+ yrs, 270K+ trading pairs), and Insights (CoinDesk.com media + the Consensus conference franchise).

How it actually makes money (de-grossed): FY2025 adjusted revenue was $288.5M, adjusted EBITDA $94.3M, adjusted net income +$38.8M; of that, adjusted transaction revenue was $130.7M (the exchange spread/fee engine) and the remainder is subscription/services/data/events + investment income. Contrast the IFRS statutory result: a $785.5M net loss for FY2025. The gap is the crypto-treasury mark and the gross-up — see Lens 5/10.

Customers / suppliers / contract structure: Customer base is institutional-first — fund managers, market makers, prop traders, prime brokers, retail aggregators (it explicitly does not compete with its own retail-broker customers — the "unconflicted" pitch), plus stablecoin / RWA / digital-asset issuers who buy Liquidity Services subscriptions. customers.csv is empty on the shelf, and the filing discloses no named single customer — but flags that "a relatively small number of institutional market makers, arbitrageurs, and high-transaction-volume customers account for a significant amount of the trading volume … and our net revenue from the Bullish Exchange". Concentration is real but unquantified.

Lens 2 · Supply Chain

A trading venue's "supply chain" is its liquidity, settlement, custody, and data stack. Mapped upstream → platform → end customer, with named stakeholders where disclosed:

• Liquidity inputs (upstream): the company's own ~$2.78B digital-asset treasury is the raw material for AMMI market-making + DeFi liquidity provision; third-party market makers / arbitrageurs supply incremental order-book depth (and are a concentration chokepoint, per Lens 1); stablecoin issuers (USDC/Circle, USDG/Paxos-Global Dollar, PYUSD/PayPal) supply the settlement medium and are also Liquidity-Services customers — a two-sided relationship.
• Funding input (a chokepoint): the platform's balance sheet is levered by a $514.4M related-party loan from SPV KY Limited (60M USDC + $40M + 9,600 BTC drawn; 7% coupon; principal $505.6M + $8.8M accrued) — SPV KY is majority beneficially owned by Bullish's own directors and shareholders. This is single-source, insider-controlled financing.
• Custody (single-source dependency + transition risk): Bullish custodies customer assets in-house across the US/Germany/HK/Gibraltar via hot+cold wallets and a private blockchain, transitioning to an in-house custody solution — the filing flags this transition as an operational/execution risk, and notes omnibus-account structures where a sub-custodian failure could leave Bullish's claim unsecured.
• Data/index inputs: CoinDesk Data's own L1/L2 order-book + on-chain feeds power CoinDesk Indices (vertically integrated, end-to-end owned).
• Distribution (downstream): ICE (Intercontinental Exchange) now lists 7 CoinDesk index-futures contracts; ARK / ProShares and 15 ETF issuers license the indices — these are the distribution OEMs.

Chokepoints: (1) concentrated market-maker liquidity; (2) the insider SPV KY funding line; (3) the unproven in-house custody migration; (4) stablecoin counterparties that are simultaneously customers and settlement rails.

Lens 3 · Competitive Advantages (moats)

Where the moat is real:

• Regulatory stack — the genuine differentiator. NYDFS BitLicense + FinCEN MSB (US), full MiCAR CASP license via BaFin (Germany, uplift completed Sept 2025), SFC Type 1/7 + VATP (Hong Kong), Gibraltar DLT, FCA benchmark-administrator status (UK, via CCData), SEC transfer-agent registration (Dec 2025). Few competitors hold this breadth of top-tier licenses; it is slow and expensive to replicate and is the basis of the institutional pitch.
• AMMI / single global order book — proprietary automated market-making delivering tight spreads (disclosed 2.23 bps average spread, May 2026) and top-5 spot ranking in BTC/ETH.
• CoinDesk brand + Consensus — the most recognized editorial/events franchise in crypto, creating a top-of-funnel and "unconflicted" trust narrative that pure exchanges lack.
• "Unconflicted" model — does not run a competing retail app against its retail-aggregator customers; powers multiple stablecoins rather than issuing one. Genuinely differentiated positioning vs. Coinbase/Binance.

Where the moat is thin:

• Spreads are compressing (2.23 bps in May 2026) and the exchange business has negative statutory "net spread related income" ($(7.2)M FY2025). Liquidity is a commodity; DeFi venues like Hyperliquid are taking institutional flow with no licensing overhead.
• Bargaining power is weak on both sides — concentrated market makers can move size elsewhere; index/data customers have credible substitutes (CF Benchmarks, Bloomberg, S&P, MSCI). Bullish needs its institutional whales more than they need Bullish.

Net: the moat is regulatory + brand, not network-effect or switching-cost. That is a defensible-but-not-dominant position — closer to a regulated-broker moat than a true exchange-network moat.

Lens 4 · Segments

Bullish reports as a single operating and reportable segment, so segments.csv is empty and there is no audited product/geographic EBITDA split. What is disclosed:

• Other revenues (the non-gross-up line, IFRS): $158.9M FY2025 vs $62.0M FY2024 (+156%), split into Subscription & services $155.5M (+160%) and Transaction income $3.4M. This is the fastest-growing, highest-quality revenue and the structural story — Liquidity Services + CoinDesk subscriptions scaling hard off a small base.
• Digital-asset sales by venue: On-Exchange $244.4B (98%+) vs On-other-venues $0.4B; on-exchange sales fell −2% YoY on softer spot volume + tighter spreads. Remember this is gross-up, not revenue.
• Adjusted transaction revenue (the real exchange take): $130.7M FY2025.
• Geography: the filing points to Note 4 for a revenue-by-geography breakdown but the disaggregation is not reproduced in the on-shelf extract — n/a at the segment level.

Trend read: the mix is shifting from pure trading-spread toward recurring subscription/services + index/data, which is exactly the de-risking management wants investors to underwrite. The Equiniti deal (Lens 8/12) accelerates this.

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Phase B — Measure performance

Lens 5 · Earnings Result (latest print: Q1 2026, 6-K)

The latest reported quarter is Q1 2026 (ended 2026-03-31):

• Digital-asset sales $51.8B (gross-up).
• Adjusted revenue $92.8M; adjusted EBITDA $35.1M — i.e., the underlying business stayed profitable on an adjusted basis.
• IFRS net loss $(604.9)M; diluted EPS $(3.85) — again driven by crypto-treasury mark-to-market, not operating cash burn.
• Options volume $11.6B in the quarter; reached 14% open-interest market share in April 2026 — the bright spot and a genuine share gain in a product launched only in Q3 2025.
• Stock fell ~8% on the print (revenue below estimates).

FY2025 anchor (audited + adjusted):

• IFRS net loss $(785.5)M; basic EPS $(5.99).
• Adjusted revenue $288.5M, adjusted EBITDA $94.3M, adjusted net income +$38.8M.
• First-ever positive operating cash flow: +$28.6M (vs −$30.0M FY2024, −$126.7M FY2023) — a real inflection.

What drove the statutory loss (decompose it): the FY2025 net loss is almost entirely non-operating:

• Impairment of digital assets held (intangibles): $(497.4)M — a one-way IFRS impairment on BTC/crypto held as IAS-38 intangibles.
• Change in FV of digital assets held, net: $(675.0)M total.
• These swamp the +$130.7M adjusted transaction revenue and +$155.5M subscription/services revenue. Strip the treasury and the operating business made money.

Balance-sheet flags: Total assets $3.96B; digital assets held $2.78B (BTC $1.60B / stablecoins $1.06B / ETH $0.04B / other $0.09B); cash & equivalents only $87.9M; $505.6M related-party debt; total equity $3.30B; accumulated deficit $(2.67)B. The treasury is the balance sheet — and it is mostly BTC, so book value is a leveraged BTC bet.

Guidance (FY2026): subscription/services/other revenue $220–250M, adjusted opex $210–230M, finance expense $52–60M. Note: they guide the recurring line + costs, not total adjusted revenue (which depends on volatile trading spreads).

Lens 6 · Earnings Calls (sentiment trend)

No transcripts on the shelf. From web coverage of the available calls (Q4-2025 and Q1-2026):

• Management focus has shifted decisively to tokenization — CEO Tom Farley framed Q1 2026 around the proposed Equiniti acquisition and "end-to-end tokenization services". In Q4-2025 the focus was options-launch traction + adjusted-EBITDA growth.
• Recurring phrases: "institutional," "regulated/regulatory-first," "unconflicted," "adjusted revenue/adjusted EBITDA" (management actively coaching the Street to look past IFRS), "full-reserve / 1:1 segregated."
• Tone shift: from "we IPO'd, here's our profitable-on-an-adjusted-basis exchange" (H2 2025) to "we are becoming tokenization infrastructure" (H1 2026) — an ambitious re-framing that conveniently changes the subject from a falling stock and BTC-driven statutory losses. As a foreign private issuer with only ~2 quarters of public reporting, the call history is short; treat sentiment as preliminary.

Lens 7 · Comps

Crypto-exchange comps are treacherous because reporting bases differ (Bullish's IFRS gross-up vs Coinbase's US-GAAP net revenue). Use adjusted revenue for Bullish, GAAP revenue for Coinbase, and flag the apples-to-oranges explicitly. Multiples are `` or n/a; none fabricated.

Read: On a P/adjusted-revenue basis (~12x) Bullish screens richer than Coinbase (~6.6x EV/GAAP-sales) despite being far smaller, less liquid, and more BTC-treasury-exposed. BUT the comparison flatters Coinbase and punishes Bullish unfairly because the bases differ, and Bullish's enterprise value is heavily offset by a ~$2.78B crypto treasury + net cash — on an ex-treasury basis the operating business is valued at well under $1B, i.e., ~3x adjusted revenue. The valuation question is really "what is the crypto treasury worth, and do you want to own levered BTC plus a sub-scale regulated exchange?" Pending the Equiniti close, treat the multiple as not cleanly sourceable — n/a on a like-for-like basis.

Lens 8 · Stock-Price Catalysts

BLSH has only ~10 months of trading history (IPO Aug 13, 2025), so the >5% moves are the catalyst history:

• IPO day (Aug 13, 2025): priced $37 (above the $32–33 range), opened $90, intraday high $118 (+215%), closed $68 (+83%); day-end market value ~$10.25B vs $5.4B IPO valuation. Underwriters JPMorgan/Jefferies/Citi; BlackRock + ARK indicated up to $200M; Peter Thiel-backed.
• Post-IPO de-rate: from the ~$118 peak to ~$23 (2026-06-29) — roughly −80% from peak, −38% from the IPO price. 52-wk range ~$21.76–$118.
• Lock-up expiry (Feb 9, 2026): 180-day lock-up release; Rosenblatt had flagged it as an overhang and cut its target to $52 on lock-up concerns.
• Q1 2026 print (May 14, 2026): −8% on a revenue miss / $(3.85) EPS.
• Equiniti deal (May 5, 2026): $4.2B tokenization acquisition — analysts split on whether it's transformative or dilutive (Lens 12).
• JPMorgan cut to $26 / Neutral (Jun 16, 2026).

What the tape reveals: the market reacts to (1) BTC price / crypto beta (the treasury), (2) lock-up + insider-supply dynamics, and (3) adjusted-revenue/EBITDA misses. The IPO pop was a momentum/scarcity event that fully unwound; the stock now trades like a levered, sub-scale crypto-beta name with a governance discount, not like a premium exchange.

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Phase C — Judge people & books

Lens 9 · Management

• Tom Farley, CEO & Chairman (age 50, since 2023). The marquee asset. Former President of NYSE Group (2014–2018) and COO of NYSE; ex-ICE (President/COO of ICE Futures US); ran Far Peak / Far Point SPACs; CFA. This is a genuine, top-tier exchange operator — exactly the credibility an institutional crypto venue needs, and the reason the regulatory-first strategy is believable. Base salary $1.75M; received a $2.37M retention bonus (Aug 2024); cash comp for all directors+officers was only $3.37M + $1.6M SBC in FY2025 — modest, not promotional cash comp.
• David Bonanno, CFO (age 44, since 2022/CFO 2024). Ex-Third Point MD (2008–2020), ex-Cerberus PE, ex-Rothschild restructuring; Harvard. A capital-markets/investing CFO, well-suited to a balance-sheet-heavy treasury model. Base $1.25M.
• Skin in the game (high, but concentrated in the block.one orbit): Insiders + directors own ~58% of shares. The dominant holders are block.one heritage: co-founder Brendan Blumer 25.9% (block.one co-founder, EOSIO originator), Kokuei Yuan 24.1% (ex-block.one Executive Chairman), Andrew Bliss 3.3% (ex-block.one CSO). Farley holds 3.45% / Bonanno 1.23% via BMC1 incentive units (vesting; exchangeable for 5.21M / 1.86M shares).
• Capital-allocation history: Mixed and aggressive on related-party lines. The group paid out a $1.98B dividend in 2023 (pre-IPO, to then-owners) and repaid $714.6M of preference shares — a large pre-IPO extraction. M&A track record: CoinDesk (Nov 2023) and CCData (Oct 2024) — both look strategically coherent and are now the growth engine. The pending $4.2B Equiniti deal is the biggest allocation bet yet (Lens 12). ROE/ROIC is not meaningful given the crypto-mark volatility — n/a on a clean basis.
• Red flags: the SPV KY related-party loan ($514.4M, 7%, lender majority-owned by Bullish's own directors/shareholders) is the single biggest governance concern — the company pays ~$35M/yr interest to its own insiders. Plus office-lease/condo assignments to Blumer-controlled entities (Buttonwood, Step Back). None are illegal or undisclosed, but the related-party density is high.
• Founder vs professional manager: a hybrid — block.one founders control the cap table and board; Farley/Bonanno are the professional operators. For this stage (newly-public, scaling, regulatory-intensive) Farley's operator profile is a strong fit; the founder-controlled super-ownership is the offsetting governance risk.

Lens 10 · Forensic Red Flags

Acting as a forensic analyst. Bullish is an unusually high-judgment set of books — IFRS, crypto fair-value, principal accounting, FPI exemptions. Risks, by statement:

Income statement / revenue recognition (HIGH attention):

• The gross-up "Digital assets sales" ($244.8B) is the dominant forensic issue. It is technically correct under IFRS principal accounting but is economically meaningless and inflates apparent scale ~1,500x vs the real take — exactly the kind of presentation that can mislead retail screens (and arguably already does; many data vendors mis-state Bullish "revenue" as hundreds of billions). Management's non-IFRS adjusted revenue is the honest number; verify the bridge every quarter.
• Non-IFRS adjusted metrics exclude other-venue sales/cost and treasury remeasurement. Reasonable, but it is management's own construct — adjusted net income +$38.8M vs IFRS −$785.5M is a $824M gap. Watch for adjusted-metric definition creep.

Balance sheet (HIGH):

• $2.78B crypto treasury, ~57% BTC, held partly as IAS-38 intangibles at the revaluation model. The Jan-1-2024 reclassification of non-market-making crypto from IAS-2 inventory to IAS-38 indefinite-life intangibles routes gains through OCI (equity) but impairments through P&L — an asymmetric treatment that produced the $497.4M FY2025 P&L impairment while $409.6M of revaluation gain sat in OCI. This is the structural reason statutory earnings will look terrible in down-quarters and fine in up-quarters regardless of operations. Not a fraud flag — a volatility/optics flag, but it makes GAAP EPS nearly useless for this name.
• Stablecoin concentration: $1.06B in stablecoins — USDC $464.9M, USDG $204.3M, PYUSD $161.1M. (One web source cited USDC $613.9M — a discrepancy vs the filing's $464.9M; trust the 20-F figure over.) Stablecoin de-peg or issuer failure is a direct balance-sheet hit.
• Customer-asset custody / omnibus accounts — segregated and "full-reserve 1:1" per the company, but the in-house custody migration + omnibus structure are disclosed legal/insolvency risks.

Cash flow (MODERATE / actually reassuring):

• Operating cash flow turned +$28.6M positive in FY2025 — cash generation diverged favorably from the IFRS net loss, confirming the loss is non-cash (impairment). Healthy direction. But the cash-flow statement is cluttered with enormous non-cash digital-asset gross-ups ($103.5B purchases / $103.2B disposals) that again obscure the real flows.

Internal control / governance (MODERATE):

• Emerging-growth / FPI status: non-accelerated filer; not subject to SOX 404(b) auditor attestation; as an FPI it has elected not to have fully-independent compensation or nominating committees. Lower governance bar than a domestic large-cap.
• Dual brand / MNPI risk: the filing itself flags that owning CoinDesk (news) + an exchange creates insider-trading / market-manipulation exposure if material non-public exchange data leaks into editorial.

Regulatory findings (required sub-section):

• SEC Litigation Releases: 0 naming Bullish (verified via EDGAR EFTS, LR forms, 2021-06-30→2026-06-30).
• SEC AAERs: 0.
• Non-SEC enforcement (FTC/DOJ/FDA/CFPB/CFTC): web search returned no Bullish-specific enforcement actions; results surfaced only the March-2026 SEC/CFTC joint interpretation on crypto-asset classification (an industry-wide tailwind, not an action against Bullish).
• 10-K Item 3 / Legal Proceedings: as an FPI there is no "Item 3"; the 20-F states that outside the ordinary course and the disclosed related-party items, no material contracts/litigation in the prior two years.
• Conclusion: No material regulatory or legal enforcement findings — verified via SEC EDGAR EFTS (LR, AAER), web search, and the 20-F's own disclosures as of 2026-06-30. The forensic risk here is accounting-optics + related-party density, not enforcement.

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Phase D — Project & stress-test

Lens 11 · Forward Projection (FY2026–FY2028)

Built bottom-up off the FY2025 adjusted base + management guidance. Statutory EPS is un-modelable (it's a BTC-price function), so I project adjusted revenue + adjusted EBITDA — the only operating-meaningful lines — and treat statutory EPS as "= adjusted ± treasury mark, undeterminable." Standalone Bullish (pre-Equiniti close, expected Jan 2027):

Inputs (all labeled):

• Recurring subscription/services/other: FY2026 guide $220–250M (midpoint $235M); FY2025 actual $158.9M IFRS "other revenue" → implies ~+48% growth.
• Adjusted transaction revenue (trading): FY2025 $130.7M; assume flat-to-modest in a soft-volume tape (±). Total adjusted revenue FY2025 $288.5M.
• Adjusted opex FY2026 guide $210–230M (midpoint $220M); finance expense $52–60M.

Statutory EPS: n/a — undeterminable; will print large GAAP losses in any BTC-down quarter (e.g., the $(5.99) FY2025 / $(3.85) Q1-2026 pattern) and positive in BTC-up quarters, independent of operations.

Equiniti pro-forma (if it closes Jan 2027): management guides the combined entity to ~$1.3B adjusted revenue and >$500M adjusted EBITDA-less-capex for 2026, 6–8% annual growth through 2029 + 20% from tokenization/blockchain services. This roughly 4–5x's the revenue base and adds a real, cash-generative legacy transfer-agent business (~3,000 issuers, 20M shareholders, $500B annual payments) — but also $1.85B of assumed debt and $2.35B of stock issued at $38.48 (well above the current ~$23, so accretive vs. issuing at market, dilutive vs. the prior count).

Brier forecast: skipped per --watchlist rules (no forecast.ts create in the breadth loop). If logged later, the scoreable binary would be "BLSH FY2026 adjusted EBITDA ≥ $90M, p≈0.60" — the durability-through-the-cycle test.

Lens 12 · Bull vs Bear

Bull case. Bullish is the regulated, institutional, unconflicted crypto venue with a genuine NYSE-caliber operator (Farley), a top-5 BTC/ETH spot book, a fast-growing recurring revenue mix (subscription/services +156%), a profitable adjusted-EBITDA base ($94.3M FY2025) that just turned operating-cash-flow positive, and a ~$2.78B treasury (mostly BTC) that gives it war-chest optionality. The Equiniti acquisition is the contrarian re-rate catalyst: it converts Bullish from "another crypto exchange" into the transfer-agent backbone for tokenized securities — issuer access + transfer-agent authority is the missing layer of the tokenization stack, and tokenization of real-world assets is the credible next leg of crypto's institutionalization (tailwinded by the GENIUS Act + the March-2026 SEC/CFTC clarity). If tokenization compounds, BLSH owns regulated rails at every layer (exchange + index + data + transfer agent) at a sub-$1B ex-treasury enterprise value — deeply mispriced.

Bear case (the impairers). (1) It's a levered BTC treasury wearing an exchange costume — book value and statutory earnings are a leveraged bet on one asset, and the $514M insider loan amplifies it. (2) The exchange economics are thin and compressing — 2.23 bps spreads, negative statutory net-spread income, commoditized liquidity, and credible share loss to DeFi (Hyperliquid) and scaled incumbents (Coinbase/Binance). (3) Governance discount — 58% insider control via the block.one orbit, related-party financing, FPI-reduced committee independence, and a CoinDesk/exchange MNPI conflict. Pre-mortem (18 months out, thesis broke): crypto entered a down-cycle, trading volumes and spreads fell together, the recurring line missed the low end of guide, the Equiniti deal closed and saddled BLSH with $1.85B of debt into a softening tape, the treasury impaired again, and the market — which never trusted the governance — re-rated it toward ex-treasury book. Multiples too high? On adjusted revenue (~12x) yes vs Coinbase; ex-treasury (~3–4x) no — the honest answer is the multiple is dominated by your BTC view, not your exchange view. Contrarian view the market refuses to see: the Street is debating BLSH as a crypto-exchange comp; the real question is whether Equiniti makes it a tokenization-infrastructure utility — and almost no one is underwriting that correctly in either direction.

Lens 13 · Devil's Advocate (short-seller)

Dismantling the bull case. What structurally breaks the money machine: trading spread + volume are correlated and both crypto-cyclical, so revenue and the treasury draw down together — there is no counter-cyclical ballast. Revenue concentration: a "relatively small number" of market makers/whales drive exchange net revenue, and CoinDesk customer concentration is "more pronounced in recent periods" — lose two or three and the recurring growth story stalls. Why the moat is weaker than bulls think: licenses are necessary but not sufficient — Coinbase has them too and is 14x bigger; AMMI liquidity is replicable; DeFi venues bypass the licensing moat entirely. Most dangerous competitor bulls underestimate: Hyperliquid (and on-chain perps generally) — taking exactly the sophisticated derivatives flow Bullish just launched options into. Worst capital-allocation/governance moves: the $514M loan from an insider-owned SPV at 7% (paying ~$35M/yr to its own shareholders), the $1.98B pre-IPO dividend extraction, and condo/office deals with founder entities — a pattern of value flowing to the block.one orbit. Assumptions that must hold for ~$23: crypto doesn't enter a multi-quarter drawdown; the Equiniti deal closes and integrates a legacy UK transfer agent without execution disaster; tokenization actually scales on Bullish's rails (not a competitor's). If growth disappoints 20–30%: adjusted EBITDA falls toward the ~$40–55M bear case, the ~12x adjusted-revenue multiple compresses, and with the treasury marked down the stock trades toward ex-treasury book — material downside from here. Single scenario that permanently impairs: a custody/security breach during the unproven in-house custody migration (the filing flags it; for an "institutional, full-reserve" brand, a hack is existential to the entire trust-based pitch). Plausibility: low-probability, catastrophic-severity — the textbook tail risk for any exchange.

Lens 14 · Management Questions (ordered by information value)

1. Post-Equiniti, what is your bridge from FY2025 standalone adjusted revenue ($288.5M) to the combined ~$1.3B, and how much is recurring vs. trading-spread vs. new tokenization revenue that doesn't yet exist?
2. Walk through the SPV KY Limited related-party loan: why finance the company with a 7% insider line rather than third-party debt, and what is the plan to refinance or extinguish the $514M as a public company?
3. What is your net-spread / take-rate trajectory given 2.23 bps in May 2026 — at what spread does the exchange stop covering its cost of liquidity provision?
4. Quantify customer concentration: what share of exchange net revenue comes from your top 10 market makers, and top 5 CoinDesk customers, and how has it trended?
5. On the in-house custody migration — timeline, third-party attestation/proof-of-reserves cadence, and insurance coverage against a hot-wallet breach?
6. The Jan-2024 reclassification to IAS-38 intangibles routes gains to OCI but impairments to P&L — will you ever hold crypto at fair-value-through-P&L so investors get a symmetric, comparable number?
7. What is the strategic intent of the $2.78B treasury — is it working capital for AMMI, or a deliberate corporate-BTC position, and would you ever hedge the BTC?
8. Equiniti adds $1.85B of debt at a time your stock trades below the $38.48 deal price — what leverage ceiling are you comfortable with through a crypto down-cycle?
9. How do you wall off CoinDesk editorial from exchange MNPI, and would you divest CoinDesk if the conflict became a regulatory liability?
10. With options at 14% OI share after two quarters — what is the realistic ceiling vs. Deribit/CME/Coinbase, and what's the unit economics vs. spot?
11. As an FPI you've opted out of fully-independent comp/nominating committees — will you voluntarily adopt domestic-issuer governance standards given 58% insider control?
12. What share of FY2026 subscription/services growth is organic vs. acquired (CCData), and what's net revenue retention on Liquidity Services subscriptions?
13. How exposed is the balance sheet to a stablecoin de-peg across the $1.06B USDC/USDG/PYUSD position, and what counterparty limits apply?
14. What is the capital-return policy once Equiniti closes — given the 2023 dividend history, should public shareholders expect buybacks, or continued reinvestment/M&A?
15. What single operating metric (not adjusted EBITDA) would you have investors judge you on over the next three years?

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