Annotated: Sam Bankman-Fried's "FTX Pre-Mortem Overview"

By Sam Bankman-Fried, originally published on his Substack blog on January 12, 2023
Annotations by Molly White. Published January 23, 2023.

Sam Bankman-Fried has apparently decided to fill his time spent confined to his parents' Palo Alto home with blogging, perhaps in the hopes that he can just blog his way out of the massive criminal and civil penalties he's facing.

Although many of his statements here repeat things he's said elsewhere, I think it is useful to be able to analyze some of the story he's trying to spin all in one place, rather than cobbling his narrative together from multiple sources.

It's remarkable the extent to which SBF outright lies, or at the very least twists his version of events to distort reality in his favor. I don't intend to annotate further posts from him—which I suspect will be many—but instead hope that this will be sufficient to give some idea of just how thoroughly misleading his statements are.

In mid November, FTX International became effectively insolvent. The FTX saga, at the end of the day, is somewhere between that of Voyager and Celsius.

Three things combined together to cause the implosion:

  1. Over the course of 2021, Alameda's balance sheet grew to roughly $100b of Net Asset Value, $8b of net borrowing (leverage), and $7b of liquidity on hand.
  2. Alameda failed to sufficiently hedge its market exposure. Over the course of 2022, a series of large broad market crashes came–in stocks and in crypto–leading to a ~80% decrease in the market value of its assets.
  3. In November 2022, an extreme, quick, targeted crash precipitated by the CEO of Binance made Alameda insolvent.
And then Alameda's contagion spread to FTX and other places, similarly to how Three Arrows etc. ultimately impacted Voyager, Genesis, Celsius, BlockFi, Gemini, and others.
Despite this, very substantial recovery remains potentially available.
FTX US remains fully solvent and should be able to return all customers' funds.
FTX International has many billions of dollars of assets, and I am dedicating nearly all of my personal assets to customers.

Notes

This post is about FTX International's (in)solvency.

It's not about FTX US, because FTX US is fully solvent and always has been

When I passed FTX US off to Mr. Ray and the Chapter 11 team, it had around +$350m net cash on hand beyond customer balances. Its funds and customers were segregated from FTX International.

It's ridiculous that FTX US users haven't been made whole and gotten their funds back yet.

Here is my record of FTX US's balance sheet as of when I handed it off:

(I believe that the same likely applies to purely spot customers of FTX International.)
FTX International was a non-US exchange. It was run outside the US, regulated outside the US, incorporated outside the US, and took non-US customers.

(In fact, it was primarily headquartered, run from, and incorporated in The Bahamas, as FTX Digital Markets LTD.)

US customers were onboarded to the (still solvent) FTX US exchange.

Senators have raised concerns about a potential conflict of interest from Sullivan & Crowell (S&C). Contrary to S&C's statement that they "had a limited and largely transactional relationship with FTX", S&C was one of FTX International's two primary law firms prior to bankruptcy, and were FTX US's primary law firm. FTX US' GC came from S&C, they worked with FTX US in its most important regulatory application, they worked with FTX International on some of its most important regulatory concerns, and they worked with FTX US on its most important transaction. When I would visit NYC, I would sometimes work out of S&C's office.

S&C and the GC were the primary parties strong-arming and threatening me into naming the candidate they themselves chose as CEO of FTX--including for a solvent entity in FTX US--who then filed for Chapter 11 and chose S&C as counsel to the debtor entities.
Despite its insolvency, and despite processing roughly $5b of withdrawals over its last few days of operation, FTX International retains significant assets–roughly $8b of assets of varying liquidity as of when Mr. Ray took over.
In addition to that, there were numerous potential funding offers–including signed LOIs post chapter 11 filing totaling over $4b. I believe that, had FTX International been given a few weeks, it could likely have utilized its illiquid assets and equity to raise enough financing to make customers substantially whole.
Since S&C pressured FTX into Chapter 11 filings, however, I worry that those pathways may have been abandoned. Even now, I believe that if FTX International were to reboot, there would be a real possibility of customers being made substantially whole. And, further, I believe that all customers with purely spot trading activity should, and easily could, be made fully whole, with assets already on hand.

While FTX's liquidity had started off in 2019 as largely dependent on Alameda, by 2022 it had greatly diversified, with Alameda falling to around 2% of volume on FTX.

I didn't steal funds, and I certainly didn't stash billions away. Nearly all of my assets were and still are utilizable to backstop FTX customers. I have, for instance, offered to contribute nearly all of my personal shares in Robinhood to customers–or 100%, if the Chapter 11 team would honor my D&O legal expense indemnification.

FTX International and Alameda were both legitimately and independently profitable businesses in 2021, each making billions.

My personal consumption was a tiny fraction of my earnings, and my consumption, donations, and investments combined were less than—and came from—earnings. Furthermore, FTX's sponsorships and company real estate were way less than its revenue, and way less than the amount it raised. Nonetheless, nearly all of my personal investments are going to customers. FTX, as a profitable private company, spent a small fraction of its revenue and the amount it had raised on branding and marketing; by contrast, Fanduels, Draft Kings, Coinbase, and Robinhood–all publicly listed, unprofitable companies–each spent far more than FTX did on marketing and branding. And the totality of the real estate purchases made by FTX–purchases made to entice a highly competitive workforce to move from the Bay Area and New York–represent roughly 10% of the amount Coinbase spends every year on its workforce..
And then Alameda lost about 80 percent of its assets' value over the course of 2022, due to a series of market crashes–as did Three Arrows Capital (3AC) and other crypto firms last year–and after that its assets fell even more from a targeted attack. FTX was impacted by Alameda's decline, as Voyager and others were earlier by 3AC and others.
Employees–both current and former–have been caught up in what happened, and that's not fair to them. A huge number of them did nothing but what they thought was right, and were–and still are–fighting for FTX's customers every day. And even many of those who are not–who are instead fighting against what I think the interest of customers is–are caught up in a shitstorm they didn't ask for or create, doing what they think is right; and I wish nothing but the best for them.
There are a large number of regulators and administrators who have put in a huge amount of work over the past few months trying to understand FTX and figure out what is in the best interest of customers/creditors. My hat goes off to them. Someday, maybe someone will tell their story, even if they insist they don't care about public recognition of the amount of energy they've put into doing what's right.
Note that, in many places here, I'm still forced to make approximations. Many of my personal passwords are still being held by the Chapter 11 team–to say nothing about data. If the Chapter 11 team wants to add their data to the conversation, I would welcome that.
Also–I haven't run Alameda for the past few years.

So much of this is pieced together post-hoc, coming from models and approximations, generally based on data that I had prior to resigning as CEO and modeling and estimations based on that data.

Overview of what happened

2021

Over the course of 2021, Alameda's Net Asset Value skyrocketed, to roughly $100b marked to market by the end of the year by my model. Even if you ignore assets like SRM that had much larger fully diluted than circulating supplies, I think it was still roughly $50b.

And over the course of 2021, Alameda's positions grew, too.

In particular, I think it had about $8b of net borrowing, which I believe was spent on:

  1. ~$1b interest payments to lenders
  2. ~$3b buying out Binance from FTX's cap table
  3. ~$4b venture investments

(By 'net borrowing', I mean, basically, borrowing minus liquid assets on hand that could be used to return the loans. This net borrowing in 2021 came primarily from third party borrow-lending desks–Genesis, Celsius, Voyager, etc., rather than from margin trading on FTX.)

So by the start of 2022, I believe that Alameda's balance sheet looked roughly like the following:

  1. ~$100b NAV
  2. ~$12b liquidity from 3rd party desks (Genesis, etc.)
  3. ~$10b more liquidity it likely could have gotten from them
  4. ~1.06x leverage

In that context, the ~$8b illiquid position (with tens of billions of dollars of available credit/margin from third party lenders) seemed reasonable and not very risky.

I think that Alameda's SOL alone was enough to cover the net borrowing. And it was coming from third party borrow-lending desks, who were all–I was told–sent accurate balance sheets from Alameda.

I think its position on FTX International was reasonable at the time–about $1.3b by my model, collateralized with tens of billions of dollars of assets–and FTX successfully passed a GAAP audit as of then.

Independent Auditor's Report To the Board of Directors and Shareholders of FTX Trading Ltd. Opinion We have audited the accompanying consolidated financial statements of FTX Trading Ltd. and subsidiaries, which comprise the consolidated balance sheets as of December 31, 2021 and 2020, and the related consolidated statements of comprehensive income, shareholders' equity, and cash flows for the years then ended, and the related notes to the financial statements, collectively referred to as 'the financial statements'. In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of FTX Trading Ltd. and subsidiaries as of December 31, 2021 and 2020, and the results of their operations and their cash flows for the years then ended in accordance with accounting principles generally accepted in the United States of America.

As of the end of 2021, then, it would have taken a ~94% market crash to drag Alameda underwater! And not just in SRM and assets like it–Alameda was still massively overcollateralized if you ignore those. I think that its SOL position alone was larger than its leverage.

But Alameda failed to sufficiently hedge against the risk of an extreme market crash: the hundred billion of assets had only a few billion dollars of hedges. It had a net leverage–[net position - hedges]/NAV–of roughly 1.06x; it was long the market.

As a result, Alameda was in theory exposed to an extreme market crash–but it would take something like a 94% crash to bankrupt it.

2022 Market Crashes

Alameda, then, entered 2022 with roughly:

  1. $100b NAV
  2. $8b net borrow
  3. 1.06x leverage
  4. Tens of billions of dollars of liquidity

Then, over the course of the year, markets crash–again and again and again. And Alameda repeatedly fails to sufficiently hedge its position until mid summer.

  • BTC crashed 30%
  • BTC crashed another 30%
  • BTC crashed another 30%
  • rising interest rates curtailed global financial liquidity
  • Luna went to $0
  • 3AC blew out
  • Alameda's co-CEO quit
  • Voyager blew out
  • BlockFi almost blew out
  • Celsius blew out
  • Genesis started shutting down
  • Alameda's borrow/lending liquidity went from ~$20b in late 2021 to ~$2b by late 2022
And so Alameda's assets get hit, again and again and again. But this part isn't specific to Alameda's assets. Bitcoin, Ethereum, Tesla, and Facebook are all down more than 60% on the year; Coinbase and Robinhood are down about 85% from their peaks last year.

SBF goes on for a while about Alameda's assets, does some whataboutism about the general downturn in crypto and stock markets, and suggests that a year-long period was apparently not enough time to discover that Alameda had become more highly leveraged then he realized.

It's ultimately unimportant given that it's not Alameda's specific trades that were the big problem, and I've already discussed the issues with how SBF estimates Alameda's assets' value, so I've omitted it.

Margin Trading

Over the course of 2022, a number of crypto platforms became insolvent due to margin positions blowing out, likely including Voyager, Celsius, BlockFi, Genesis, Gemini, and ultimately FTX.

This is a fairly common on margin platforms; among others, it's happened on:

Traditional Finance:

Crypto:

  • OKEx
  • OKEx again, and basically every week for a year
  • CoinFlex
  • EMX
  • Voyager, Celsius, BlockFi, Genesis, Gemini, etc.

The November Crash

Then came CZ's fateful tweet, following an extremely effective months-long PR campaign against FTX–and the crash.

Up until that final crash in November, QQQ had moved roughly half as much as Alameda's portfolio, and BTC/ETH had moved roughly 80% as much–meaning that Alameda's hedges (QQQ/BTC/ETH), to the extent they existed, had worked. Unfortunately the hedges hadn't been sufficiently large until after the 3AC crash–but as of October 2022, they finally were.

But the November crash was a targeted attack on assets held by Alameda, not a broad market move. Over the few days in November, Alameda's assets fell roughly 50%; BTC fell about 15%--only 30% as much as Alameda's assets–and QQQ didn't move at all. As a result, the larger hedge that Alameda had finally put on that summer didn't end up helping. It would have for every previous crash that year–but not for this one.

Over the course of November 7th and 8th, things went from stressful but mostly under control to clearly insolvent.

By November 10th, 2022, Alameda's balance sheet had only ~$8b of (only semi-liquid) assets left, versus roughly the same ~$8b of liquid liabilities:

And a run on the bank required immediate liquidity—liquidity that Alameda no longer had.

Credit Suisse fell nearly 50% this autumn on the threat of a run on the bank. At the end of the day, its run on the bank fell short. FTX's didn't.

And so, as Alameda became illiquid, FTX International did as well, because Alameda had a margin position open on FTX; and the run on the bank turned that illiquidity into insolvency.

Meaning that FTX joined Voyager, Celsius, BlockFi, Genesis, Gemini, and others that experienced collateral damage from the liquidity crunch of their borrowers.

All of which is to say: no funds were stolen. Alameda lost money due to a market crash it was not adequately hedged for–as Three Arrows and others have this year. And FTX was impacted, as Voyager and others were earlier.

Coda

Even then, I think it's likely that FTX could have made all customers whole if a concerted effort had been made to raise liquidity.

There were billions of dollars of funding offers when Mr. Ray took over, and more than $4b that came in after.

If FTX had been given a few weeks to raise the necessary liquidity, I believe it would have been able to make customers substantially whole. I didn't realize at the time that Sullivan & Cromwell—via pressure to instate Mr. Ray and file Chapter 11, including for solvent companies like FTX US–would potentially quash those efforts. I still think that, if FTX International were to reboot today, there would be a real possibility of making customers substantially whole. And even without that, there are significant assets available for customers.

I've been, regrettably, slow to respond to public misperceptions and material misstatements. It took me some time to piece together what I could–I don't have access to much of the relevant data, much of which is for a company (Alameda) I wasn't running at the time.

I had been planning to give my first substantive account of what happened in testimony to the US House Financial Services Committee on December 13th. Unfortunately, the DOJ moved to arrest me the night before, preempting my testimony with an entirely different news cycle. For what it's worth, a draft of the testimony I planned to give leaked out here.

I have a lot more to say–about why Alameda failed to hedge, what happened with FTX US, what led to the Chapter 11 process, S&C, and more. But at least this is a start.

Footnotes

  1. Complaint ¶ 73, Commodity Futures Trading Commission v. Bankman-Fried et al., No. 1:22-cv-10503 (SDNY Dec. 13, 2022). ECF No. 1.
  2. Complaint ¶ 4, Securities and Exchange Commission v. Bankman-Fried et al., No. 1:22-cv-10501 (SDNY Dec. 13, 2022). ECF No. 1. ("When prices of crypto assets plummeted in May 2022, Alameda's lenders demanded repayment on billions of dollars of loans. Despite the fact that Alameda had, by this point, already taken billions of dollars of FTX customer assets, it was unable to satisfy its loan obligations. Bankman-Fried directed FTX to divert billions more in customer assets to Alameda to ensure that Alameda maintained its lending relationships, and that money could continue to flow in from lenders and other investors.")
  3. According to a statement by FTX attorney Andrew Dietderich in the bankruptcy court hearing on January 13, 2023.
  4. Kadhim Shubber, Celsius Network reveals $1.2bn shortfall in bankruptcy filing, Fin. Times, July 14, 2022.
  5. Declaration of Stephen Ehrlich in Support of Chapter 11 Petitions and First Day Motions Ex. G, In re Voyager Digital Holdings, Inc. et al., No. 22-10943-MEW (Bankr. SDNY Jul. 6, 2022). ECF No. 15.
  6. Matthew Goldstein & David Yaffe-Bellany, In Hunt for FTX Assets, Lawyers Locate Billions in Cash and Crypto, N.Y. Times, Jan. 17, 2023.
  7. Jeff Kauflin, Despite Boasting Of Big Profits, FTX And Alameda Lost $3.7 Billion Before 2022, Forbes, Nov. 21, 2022; source document Motion of Debtors for Entry of Interim and Final Orders (I) Establishing Notice and Objection Procedures for Transfers of Equity Securities and Claims of Worthless Stock Deductions and (II) Granting Certain Related Relief, In re FTX Trading Ltd. et al., No. 22-11068-JTD (Bankr. D. Del. Nov. 19, 2022). ECF No. 49.
  8. Complaint, supra note 1, ¶ 60. ("Alameda relied on its significant holdings of FTT and similar illiquid tokens, valued at the market value of the asset without discount, as collateral to support a number of large loans from various digital asset lending platforms.")
  9. Complaint, supra note 2, ¶ 29. ("[T]he collateral Alameda deposited on FTX consisted largely of illiquid, FTX-affiliated tokens, including FTT.")
  10. Press release, Securities Commission of The Bahamas, Securities Commission of The Bahamas Seeks Court Direction Regarding Disclosure of Information (Dec. 29, 2022).
  11. Debtors' Objection to Emergency Motion of the Joint Provisional Liquidators of FTX Digital Markets Ltd. (I) for Relief from Automatic Stay and (II) to Compel Turnover of Electronic Records Under Sections 542, 1519(a)(3), 1521(a)(7) and 1522 of the Bankruptcy Code at 6 n. 9, In re FTX Trading Ltd. et al., No. 22-11068-JTD (Bankr. D. Del. Dec. 30, 2022). ECF No. 335.
  12. Investigating the Collapse of FTX, Part I: Hearing Before the H. Comm. on Fin. Services, 117th Cong. (2022) (statement of John J. Ray III, Chief Executive Officer, FTX Group at 2:19:17).
  13. Complaint, supra note 1, ¶ 95.
  14. Opposition to FTX Debtors' Motion To Enforce The Automatic Stay Or, In The Alternative, Extend The Automatic Stay, In re FTX Trading Ltd. et al., No. 22-11068-JTD (Bankr. D. Del. Jan. 5, 2023). ECF No. 387.
  15. Emergency Motion for Extension of Time to Respond to Complaint and Turnover Motion and for Continuance of Hearing and Pretrial Conference, Exhibit 5 at 3 ¶ 9, BlockFi Inc. v. Emergent Fidelity Technologies Ltd. (In re BlockFi Inc. et al.), No. 22-01382-MBK (Bankr. D.N.J. Nov. 28, 2022). ECF No. 19-7.
  16. Lucinda Shen, Exclusive: Sam Bankman-Fried says he's down to $100,000, Axios, Nov. 29, 2022.
  17. Ray, supra note 12, at 1:17:17.
  18. Audio interview by Stephen "Coffeezilla" Findeisen with Sam Bankman-Fried, at 9:44. (December 1, 2022).
  19. Complaint, supra note 1, ¶ 94–95. ("The FTX executives ultimately identified a shortfall they did not understand and were unable to quantify on FTX US. Bankman-Fried quickly indicated that he would fill the hole at FTX US from liquidation of Alameda assets. On November 8, Bankman-Fried directed Alameda traders to prioritize meeting FTX US capital requirements and to send excess capital to FTX US. On information and belief, Alameda sent in excess of $185 million to FTX US to fill its shortfall.")
  20. Ray, supra note 12, at 1:15:32.
  21. Debtors' Objection to Emergency Motion of the Joint Provisional Liquidators of FTX Digital Markets, supra note 11, ¶ 4.
  22. Id., ¶ 74.
  23. Order Authorizing the Retention and Employment of Sullivan & Cromwell LLP as Counsel to the Debtors and Debtors-in-Possession Nunc Pro Tunc to the Petition Date, In re FTX Trading Ltd. et al., No. 22-11068-JTD (Bankr. D. Del. Jan. 20, 2023). ECF No. 553.
  24. Sam Bankman-Fried, written draft of testimony for Investigating the Collapse of FTX, Part I: Hearing Before the H. Comm. on Fin. Services, 117th Cong. (December 13, 2022) (not delivered, published by Forbes).
  25. Enron case legal tab: $700 million, L.A. Times, Nov. 22, 2007.
  26. Complaint ¶ 74, Securities and Exchange Commission v. Ellison and Wang, No. 1:22-cv-10794 (SDNY Dec. 21, 2022). ECF No. 1. ("Ellison, at Bankman-Fried's direction, caused Alameda to manipulate the price of FTT by purchasing large quantities of FTT on the open market to prop up its price.")
  27. FTX balance sheet, revealed, Fin. Times, Nov. 12, 2022.
  28. Binance (@binance), Twitter (Nov. 9, 2022, 4:00PM). ("As a result of corporate due diligence, as well as the latest news reports regarding mishandled customer funds and alleged US agency investigations, we have decided that we will not pursue the potential acquisition of FTX.com.")
  29. Bennett Tomlin, SBF is being deceitful again, Protos, Jan. 13, 2023.
  30. Debtors' Motion to Enforce the Automatic Stay or, in the Alternative, Extend the Automatic Stay ¶ 4, In re FTX Trading Ltd., No. 22-11068-JTD (Bankr. D. Del. Dec. 22, 2022). ECF No. 291. ("With news of FTX's imminent collapse making headlines worldwide, just two days before the Debtors (including FTX Trading and Alameda) filed for bankruptcy, BlockFi scrambled to protect itself from impending losses on antecedent loans by threatening to seek remedies against Alameda if Alameda did not pledge additional collateral for those loans. In response to those threats, and despite the perilous financial position of Alameda and the other Debtors, Alameda's then-CEO Caroline Ellison, with knowledge and encouragement from Mr. Bankman-Fried, purportedly agreed to pledge over $1 billion worth of additional Alameda assets to secure Alameda's outstanding loan obligations to BlockFi. The Robinhood Shares were included in these pledged assets by Alameda's then-CEO, despite the fact that the Robinhood Shares were nominally held by Emergent, because Alameda had then, and continues to have, a property interest in the Robinhood Shares.")
  31. Motion to Dismiss Case Filed by Joint Provisional Liquidators of FTX Digital Markets Ltd., ¶ 14, In re FTX Trading Ltd., No. 22-11068-JTD (Bankr. D. Del. Dec. 12, 2022). ECF No. 213. ("The total amount recorded as owed by FTX Property Holdings to FTX Digital was, as of October 5, 2022, at least $256.3 million.")
  32. Sam Bankman-Fried (@SBF_FTX), Twitter (Aug. 9, 2022, 5:15PM). ("b) $4.4b of employee comp").
  33. Declan Harty, A tale of two crypto strategies: While Coinbase added thousands of jobs, Sam Bankman-Fried's FTX stayed lean with just 300 employees—and now plans to capitalize on the carnage, Fortune, June 18, 2022.
  34. Muyao Shen & Jeremy Hill, Three Arrows Capital Liquidators Demand Documents Via Twitter, Bloomberg, Jan. 5, 2023. ("[T]he pair's whereabouts are unknown and they are not fully cooperating with 3AC's unwinding, the advisers have said.")
  35. Kelsey Piper, Sam Bankman-Fried tries to explain himself, Vox, Nov. 16, 2022.
  36. Complaint, supra note 1, ¶ 29.
  37. Complaint, supra note 2, ¶ 18.
  38. Is Alameda Research Insolvent?, Dirty Bubble Media, Nov. 4, 2022.
  39. Chris Prentice, U.S. securities regulator probes FTX investors' due diligence -sources, Reuters, Jan. 6, 2022.
  40. Complaint, ¶ 2, 61, People of the State of New York, by Letitia James, Attorney General of the State of New York v. Alex Mashinsky, Index No. 450040/2023, NYSCEF No. 2 (NY Sup. Ct. NY Cnty. Jan. 5, 2023).
  41. CFTC Complaint, supra note 1, ¶ 104.
  42. Francine McKenna, 'A Complete Failure of Corporate Controls': What Investors and Accountants Missed in FTX's Audits, CoinDesk, Nov. 18, 2022.
  43. Emily Mason, FTX.US Accounting Firm Armanino Ends Crypto Audit Practice, Forbes, Dec. 15, 2022.
  44. Complaint, supra note 2, ¶ 71–72.
  45. Emily Flitter, David Yaffe-Bellany & Matthew Goldstein, FTX Founder Sam Bankman-Fried Is Said to Face Market Manipulation Inquiry, N.Y. Times, Dec. 7, 2022.
  46. FTX Terms of Service, FTX (May 13, 2022).
  47. Complaint, supra note 2, ¶ 3. ("[Bankman-Fried] repeatedly cast FTX as an innovative and conservative trailblazer in the crypto markets. He told investors and prospective investors that FTX had top-notch, sophisticated automated risk measures in place to protect customer assets, that those assets were safe and secure, and that Alameda was just another platform customer with no special privileges. These statements were false and misleading.")
  48. Ian Allison, Divisions in Sam Bankman-Fried's Crypto Empire Blur on His Trading Titan Alameda's Balance Sheet, CoinDesk, Nov. 2, 2022.
  49. Jonathan Stempel, Corzine in $5 million settlement with US CFTC over MF Global collapse, Reuters, January 5, 2017.
  50. Sam Bankman-Fried (@SBF_FTX), Twitter (Oct. 30, 3:49am) (deleted, archived at Rebellion Research). ("@rsalame7926 @cz_binance excited to see him repping the industry in DC going forward! uh, he is allowed to go to DC, right?")
  51. Matt Levine, JPMorgan Says Frank Was Fraud, Bloomberg, Jan. 12, 2023.
  52. Marc Rubinstein, Bank Runs Just Aren't What They Used to Be, Washington Post, Dec. 8, 2022.

Copyright to the original Substack post belongs to Sam Bankman-Fried, and the article can be read in its original form in full at sambf.substack.com. It is republished here for the purposes of critical commentary.

Molly White has a cryptocurrency disclosure.

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