Correspondence 0001628280-23-028985 from Galaxy Digital Inc. (GLXY)
Galaxy Digital Inc.
Date: Aug. 11, 2023 · CIK: 0001859392 · Accession: 0001628280-23-028985
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-262378
Referenced dates: May 12, 2023
Letter
Re: Galaxy Digital Inc. Registration Statement on Form S-4 Filed February 9, 2023 File No. 333-262378
Document
Joseph A. Hall +1 212 450 4565 joseph.hall@davispolk.com Davis Polk & Wardwell LLP 450 Lexington Avenue New York, NY 10017 davispolk.com
CERTAIN PORTIONS OF THIS LETTER HAVE BEEN OMITTED FROM THE VERSION FILED VIA EDGAR. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED WITH RESPECT TO THE OMITTED PORTIONS. INFORMATION THAT WAS OMITTED IN THE EDGAR VERSION HAS BEEN NOTED IN THIS LETTER WITH A PLACEHOLDER IDENTIFIED BY THE MARK “[***]”.
August 11, 2023
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Finance
100 F Street, N.E.
Washington, DC 20549-4631
Attn: David Gessert Matthew Derby Mark Brunhofer Sharon Blume
Ladies and Gentlemen:
On behalf of our clients Galaxy Digital Inc., a Delaware corporation (“GDI” or the “Company”), and Galaxy Digital Holdings Ltd., a Cayman Islands exempted company (“GDHL,” and together with GDI, “Galaxy”), we are responding to comments from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to Galaxy’s Registration Statement on Form S-4 (File No. 333-262378) (the “Registration Statement”) contained in the Staff’s letter dated May 12, 2023. Galaxy has revised the Registration Statement and is filing Amendment No. 2 to the Registration Statement (“Amendment No. 2”) together with this response letter. Amendment No. 2 also contains certain additional updates and revisions. We would be pleased to provide courtesy copies of Amendment No. 2 to the Staff on request.
For convenience, the Staff’s comments are repeated below in italics, followed by Galaxy’s responses to the comments. Where applicable, we have included page numbers to refer to the location in Amendment No. 2 where revised language addressing a particular comment appears. Capitalized terms used but not defined herein are used as defined in Amendment No. 2. Certain confidential information that is relevant to Galaxy’s responses below are included in Annexes to this letter, which will be submitted separately pursuant to a request for confidential treatment.
Galaxy Digital Inc. and Galaxy Digital Holdings Ltd. request that the information contained in this letter, marked by “[***]”, be treated as confidential information pursuant to 17 C.F.R. § 200.83.
U.S. Securities and Exchange Commission
Amendment No. 1 to Registration Statement on Form S-4 Filed February 9, 2023
General
1. Please revise your prospectus summary to specifically address the risks and potential consequences to your business, financial condition and results of operations that you describe in the risk factor on page 52 regarding transactions with digital assets that are securities.
Galaxy has revised the disclosure on page 30 in response to the Staff’s comment.
2. We note your disclosure in the “Securities Regulation Generally” section in which you describe your process and procedures for determining the federal securities law status of digital assets. Please revise to discuss how often you update or reconsider your analysis of each digital asset with which you transact, whether in connection with your policies and procedures or in response to judicial or regulatory developments, including a discussion of whether and to what extent any of your determinations have changed over time.
Galaxy has revised the disclosure on pages 240 – 241 and provided additional information in Annex I in response to the Staff’s comment.
3. We note your disclosure in the first risk factor on page 78, and under the Government Regulation discussion on page 237, that Galaxy Bahamas Ltd., which will serve as extensions of your trading business under Galaxy Trading (“GT”) and your custody and money services operation under GalaxyOne Prime LLC (“GPL”), will also offer market making and staking services. We further note your disclosure on page 24 that you are acquiring the assets of GK8, an institutional digital asset self-custody platform, and that GK8’s website markets its staking services as letting customers earn interest on digital assets by using them to securely validate blockchain transactions. Please expand your disclosure to describe your current and planned activities with respect to staking in greater detail. Without limitation, your disclosure should address program features, whose crypto assets are being staked and who is eligible to participate. Additionally, please provide us with your analysis as to how your staking program is, and will be, executed in compliance with the federal securities laws and provide related risk factor disclosure.
Galaxy has revised the disclosure throughout the Registration Statement to reflect that it does not currently offer staking services to its customers. Galaxy's trading business, formerly referred to as “Galaxy Trading” or “GT”, does not currently hold or custody assets for the benefit of, or on behalf of, its counterparties or third parties, nor does it provide staking services. Galaxy trading's supplemental businesses, GPL and Galaxy Bahamas Ltd., may hold client assets with third-party custodians, but do not currently offer staking services. Galaxy’s self-custody technology solution, which it operates through GDS Crypto Technologies Israel Ltd comprising the assets of GK8 acquired in February 2023, licenses self-custody software technology to customers that allows customers to generate and store the private keys to their digital assets in a secure cold storage vault. For those blockchain protocols that support delegated staking, this software also provides users with the technological ability to delegate their digital assets to third-party validator nodes who provide staking services with respect to such digital assets, while maintaining those digital assets in self-custody. Galaxy advises the Staff that its self-custody software technology does not itself provide a staking service; any such staking services are offered by the validator nodes on the blockchain protocols to which users may elect to delegate their digital assets, and any economic incentives that users may receive for electing to delegate their digital assets in this manner are provided to such users by the validator nodes, not Galaxy or GK8. Galaxy further advises the Staff that it has reviewed GK8’s website to ensure that it accurately describes the functionality of Galaxy’s self-custody software technology solution.
Galaxy advises the Staff that, while it does not currently have a framework in place to offer staking services to its customers, it is currently exploring ways to offer staking services in the future in compliance
August 11, 2023 GLXY-2
Galaxy Digital Inc. and Galaxy Digital Holdings Ltd. request that the information contained in this letter, marked by “[***]”, be treated as confidential information pursuant to 17 C.F.R. § 200.83.
U.S. Securities and Exchange Commission
with applicable securities laws. To this end, Galaxy is currently engaging with outside legal counsel to evaluate one or more structures through which it may in the future legally offer staking services to its customers, taking into account any relevant regulatory enforcement actions, judicial decisions and other developments. Galaxy would intend to structure any such staking services so as to either (i) not constitute securities transactions, or (ii) to the extent they did constitute securities transactions, be structured so as to be exempt from registration under the Securities Act. Galaxy further advises the Staff that, to the extent any such plans to offer staking services to customers are solidified prior to the effectiveness of the Registration Statement, it will revise its disclosure in the Registration Statement to more fully describe any planned staking services, including program features, whose digital assets are being staked, who is eligible to participate and the risks to Galaxy related to offering the services, and will provide the Staff with its analysis as to how any such staking program will be executed in compliance with the federal securities laws at such time.
4. As part of your response to prior comment 1, you state the following:
“Trading. In this business line, the Company, through its subsidiaries, primarily provides spot, derivative and financing liquidity to institutional clients, counterparties and venues that transact in cryptocurrencies and other digital assets. Although the Company does transact in the trading business line in certain digital assets that could potentially be considered investment securities under the Investment Company Act, this business line is not primarily engaged in investment company activity.”
Please explain further how GD LP does not meet the definition of an investment company under section 3(a)(1)(A) of the Investment Company Act, particularly as it is engaged in the business of trading assets that are potentially securities.
Galaxy respectfully submits that while GD LP engages in trading with respect to digital assets, including digital assets that could potentially be considered securities for Investment Company Act testing purposes, as well as bitcoin and ether which are not investment securities,1GD LP is not primarily engaged in the business of investing, reinvesting or trading in securities. GD LP is the holding company for all of the Company’s subsidiaries and therefore, like the Company, GD LP is primarily engaged in all of the Company’s primary business lines, in addition to the Trading business.2 Thus, for the same reasons outlined in our response to prior comment 1 with respect to the Company and the five Tonopah Mining factors—i.e., the historical development of the Company’s business, public representations of the Company’s primary business as a diversified financial services company, activities of its officers and directors, nature of its assets and its sources of income—GD LP is not primarily engaged in the business of investing, reinvesting or trading in securities under Section 3(a)(1)(A).
Furthermore, while the Trading business line involves some trading in digital assets that are potentially securities for Investment Company Act purposes, such trading in securities (in terms of notional value) is primarily attributable to its exempt market intermediary business under Section 3(c)(2) and is otherwise a relatively small portion of GD LP’s overall activities in the Trading business line. In terms of the day-to-day business activities of GD LP and its wholly-owned subsidiaries in the Trading business line throughout 2022, 90% of transactions by notional value were attributable to exempt market intermediary activities under Section 3(c)(2) and trading in bitcoin and ether, which are not securities.3 In addition, trading in bitcoin and ether accounted for approximately 90% of the notional value of trading activity that is not exempt market intermediary activity under Section 3(c)(2) (i.e., client-facing trading, quantitative trading a
1See, e.g., William Hinman, Director, Division of Corporation Finance, SEC, Remarks at the Yahoo Finance All Markets Summit: Digital Asset Transactions: When Howey Met Gary (Plastic) (Jun. 14, 2018), available at: https://www.sec.gov/news/speech/speech-hinman-061418. See also n.11.
2 The Company currently has no material assets or operations. Consistent with our response to prior comment 1, the Investment Company Act analysis set out below is based on the Company’s structure as it will exist at the time the Company succeeds to the businesses of GDHL and commences operations as the issuer and registrant under the Registration Statement.
3 See n.1.
August 11, 2023 GLXY-3
Galaxy Digital Inc. and Galaxy Digital Holdings Ltd. request that the information contained in this letter, marked by “[***]”, be treated as confidential information pursuant to 17 C.F.R. § 200.83.
U.S. Securities and Exchange Commission
nd macro trading) within the Trading business conducted by GD LP and its wholly-owned subsidiaries throughout 2022.4 As such, GD LP’s engagement in the Trading business line, directly and through its wholly owned subsidiaries, is primarily attributable to exempt market intermediary activities under Section 3(c)(2) and assets that are not securities. Thus, GD LP is not and does not hold itself out as being engaged primarily, and does not propose to engage primarily, in the business of investing, reinvesting or trading in securities and therefore is not an investment company under Section 3(a)(1)(A).
We note that starting in the first quarter of 2023, the Company re-segmented its primary business lines into three operating business segments for reporting purposes to be consistent with changes in its operations, from organic growth and recent acquisitions, and its management structure. The new segment structure does not change the fundamental nature of the Company’s primary business activities as described in our response to prior comment 1, which continue to consist of:
1.the Trading and Investment Banking business lines, which are now combined under the Galaxy Global Markets segment;
2.the Asset Management business line, which is under the Galaxy Asset Management segment; and
3.the Mining business line, which is under the Galaxy Digital Infrastructure Solutions segment along with other newly acquired infrastructure services businesses (e.g., GK8).
The Company’s balance sheet venture investments, formerly referred to as the Principal Investments business line, no longer exists as a standalone business line, which more accurately reflects the Company’s focus on its three primary operating segments. For segment reporting purposes, the Company’s balance sheet venture investments now fall under the Galaxy Asset Management segment or within the business segment that is strategically aligned with the particular investment. This re-segmenting of business lines further underscores that the Company is not an investment company under Section 3(a)(1)(A), as it further demonstrates that the Company's principal investments are not its primary business.
5. Please describe the ownership interest of the Company and its affiliates in the funds and other investment vehicles managed by the Asset Management Entities.
Galaxy advises the Staff that it has provided its response within Annex II hereto.
6. You define Primary Company Business as “the business of providing technology-driven diversified financial services, focused on digital asset trading (including market intermediary services for digital asset lending and borrowing), digital asset mining operations, asset management and investment banking…” Given that the Company is “focused on digital asset trading,” and is treating digital assets other than BTC or ETH as securities, please provide additional support for your conclusion that the historical development and public representations of the Company weigh in favor of the Company not falling within the investment company definition under section 3(a)(1)(A).
Galaxy respectfully submits that, as discussed in our response to comment 4 above, the Company is primarily engaged in the Investment Banking, Asset Management and Mining business lines, as well as the Trading business line. The Company’s primary business lines are not investment company activities for the reasons discussed in our response to prior comment 1, including in terms of the five Tonopah Mining factors: i.e., the historical development of the Company’s business, public representations of the Company’s primary business as a diversified financial services company, activities of its officers and directors, nature of its assets and its sources of income. Historically, in public representations of the
4 This percentage does not reflect certain hedging transactions undertaken in connection with the client-facing trading activity. Nonetheless, as such hedging trans
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CORRESP 1 filename1.htm Document Joseph A. Hall +1 212 450 4565 joseph.hall@davispolk.com Davis Polk & Wardwell LLP 450 Lexington Avenue New York, NY 10017 davispolk.com CERTAIN PORTIONS OF THIS LETTER HAVE BEEN OMITTED FROM THE VERSION FILED VIA EDGAR. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED WITH RESPECT TO THE OMITTED PORTIONS. INFORMATION THAT WAS OMITTED IN THE EDGAR VERSION HAS BEEN NOTED IN THIS LETTER WITH A PLACEHOLDER IDENTIFIED BY THE MARK “[***]”. August 11, 2023 Re: Galaxy Digital Inc. Registration Statement on Form S-4 Filed February 9, 2023 File No. 333-262378 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, N.E. Washington, DC 20549-4631 Attn: David Gessert Matthew Derby Mark Brunhofer Sharon Blume Ladies and Gentlemen: On behalf of our clients Galaxy Digital Inc., a Delaware corporation (“GDI” or the “Company”), and Galaxy Digital Holdings Ltd., a Cayman Islands exempted company (“GDHL,” and together with GDI, “Galaxy”), we are responding to comments from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to Galaxy’s Registration Statement on Form S-4 (File No. 333-262378) (the “Registration Statement”) contained in the Staff’s letter dated May 12, 2023. Galaxy has revised the Registration Statement and is filing Amendment No. 2 to the Registration Statement (“Amendment No. 2”) together with this response letter. Amendment No. 2 also contains certain additional updates and revisions. We would be pleased to provide courtesy copies of Amendment No. 2 to the Staff on request. For convenience, the Staff’s comments are repeated below in italics, followed by Galaxy’s responses to the comments. Where applicable, we have included page numbers to refer to the location in Amendment No. 2 where revised language addressing a particular comment appears. Capitalized terms used but not defined herein are used as defined in Amendment No. 2. Certain confidential information that is relevant to Galaxy’s responses below are included in Annexes to this letter, which will be submitted separately pursuant to a request for confidential treatment. Galaxy Digital Inc. and Galaxy Digital Holdings Ltd. request that the information contained in this letter, marked by “[***]”, be treated as confidential information pursuant to 17 C.F.R. § 200.83. U.S. Securities and Exchange Commission Amendment No. 1 to Registration Statement on Form S-4 Filed February 9, 2023 General 1. Please revise your prospectus summary to specifically address the risks and potential consequences to your business, financial condition and results of operations that you describe in the risk factor on page 52 regarding transactions with digital assets that are securities. Galaxy has revised the disclosure on page 30 in response to the Staff’s comment. 2. We note your disclosure in the “Securities Regulation Generally” section in which you describe your process and procedures for determining the federal securities law status of digital assets. Please revise to discuss how often you update or reconsider your analysis of each digital asset with which you transact, whether in connection with your policies and procedures or in response to judicial or regulatory developments, including a discussion of whether and to what extent any of your determinations have changed over time. Galaxy has revised the disclosure on pages 240 – 241 and provided additional information in Annex I in response to the Staff’s comment. 3. We note your disclosure in the first risk factor on page 78, and under the Government Regulation discussion on page 237, that Galaxy Bahamas Ltd., which will serve as extensions of your trading business under Galaxy Trading (“GT”) and your custody and money services operation under GalaxyOne Prime LLC (“GPL”), will also offer market making and staking services. We further note your disclosure on page 24 that you are acquiring the assets of GK8, an institutional digital asset self-custody platform, and that GK8’s website markets its staking services as letting customers earn interest on digital assets by using them to securely validate blockchain transactions. Please expand your disclosure to describe your current and planned activities with respect to staking in greater detail. Without limitation, your disclosure should address program features, whose crypto assets are being staked and who is eligible to participate. Additionally, please provide us with your analysis as to how your staking program is, and will be, executed in compliance with the federal securities laws and provide related risk factor disclosure. Galaxy has revised the disclosure throughout the Registration Statement to reflect that it does not currently offer staking services to its customers. Galaxy's trading business, formerly referred to as “Galaxy Trading” or “GT”, does not currently hold or custody assets for the benefit of, or on behalf of, its counterparties or third parties, nor does it provide staking services. Galaxy trading's supplemental businesses, GPL and Galaxy Bahamas Ltd., may hold client assets with third-party custodians, but do not currently offer staking services. Galaxy’s self-custody technology solution, which it operates through GDS Crypto Technologies Israel Ltd comprising the assets of GK8 acquired in February 2023, licenses self-custody software technology to customers that allows customers to generate and store the private keys to their digital assets in a secure cold storage vault. For those blockchain protocols that support delegated staking, this software also provides users with the technological ability to delegate their digital assets to third-party validator nodes who provide staking services with respect to such digital assets, while maintaining those digital assets in self-custody. Galaxy advises the Staff that its self-custody software technology does not itself provide a staking service; any such staking services are offered by the validator nodes on the blockchain protocols to which users may elect to delegate their digital assets, and any economic incentives that users may receive for electing to delegate their digital assets in this manner are provided to such users by the validator nodes, not Galaxy or GK8. Galaxy further advises the Staff that it has reviewed GK8’s website to ensure that it accurately describes the functionality of Galaxy’s self-custody software technology solution. Galaxy advises the Staff that, while it does not currently have a framework in place to offer staking services to its customers, it is currently exploring ways to offer staking services in the future in compliance August 11, 2023 GLXY-2 Galaxy Digital Inc. and Galaxy Digital Holdings Ltd. request that the information contained in this letter, marked by “[***]”, be treated as confidential information pursuant to 17 C.F.R. § 200.83. U.S. Securities and Exchange Commission with applicable securities laws. To this end, Galaxy is currently engaging with outside legal counsel to evaluate one or more structures through which it may in the future legally offer staking services to its customers, taking into account any relevant regulatory enforcement actions, judicial decisions and other developments. Galaxy would intend to structure any such staking services so as to either (i) not constitute securities transactions, or (ii) to the extent they did constitute securities transactions, be structured so as to be exempt from registration under the Securities Act. Galaxy further advises the Staff that, to the extent any such plans to offer staking services to customers are solidified prior to the effectiveness of the Registration Statement, it will revise its disclosure in the Registration Statement to more fully describe any planned staking services, including program features, whose digital assets are being staked, who is eligible to participate and the risks to Galaxy related to offering the services, and will provide the Staff with its analysis as to how any such staking program will be executed in compliance with the federal securities laws at such time. 4. As part of your response to prior comment 1, you state the following: “Trading. In this business line, the Company, through its subsidiaries, primarily provides spot, derivative and financing liquidity to institutional clients, counterparties and venues that transact in cryptocurrencies and other digital assets. Although the Company does transact in the trading business line in certain digital assets that could potentially be considered investment securities under the Investment Company Act, this business line is not primarily engaged in investment company activity.” Please explain further how GD LP does not meet the definition of an investment company under section 3(a)(1)(A) of the Investment Company Act, particularly as it is engaged in the business of trading assets that are potentially securities. Galaxy respectfully submits that while GD LP engages in trading with respect to digital assets, including digital assets that could potentially be considered securities for Investment Company Act testing purposes, as well as bitcoin and ether which are not investment securities,1GD LP is not primarily engaged in the business of investing, reinvesting or trading in securities. GD LP is the holding company for all of the Company’s subsidiaries and therefore, like the Company, GD LP is primarily engaged in all of the Company’s primary business lines, in addition to the Trading business.2 Thus, for the same reasons outlined in our response to prior comment 1 with respect to the Company and the five Tonopah Mining factors—i.e., the historical development of the Company’s business, public representations of the Company’s primary business as a diversified financial services company, activities of its officers and directors, nature of its assets and its sources of income—GD LP is not primarily engaged in the business of investing, reinvesting or trading in securities under Section 3(a)(1)(A). Furthermore, while the Trading business line involves some trading in digital assets that are potentially securities for Investment Company Act purposes, such trading in securities (in terms of notional value) is primarily attributable to its exempt market intermediary business under Section 3(c)(2) and is otherwise a relatively small portion of GD LP’s overall activities in the Trading business line. In terms of the day-to-day business activities of GD LP and its wholly-owned subsidiaries in the Trading business line throughout 2022, 90% of transactions by notional value were attributable to exempt market intermediary activities under Section 3(c)(2) and trading in bitcoin and ether, which are not securities.3 In addition, trading in bitcoin and ether accounted for approximately 90% of the notional value of trading activity that is not exempt market intermediary activity under Section 3(c)(2) (i.e., client-facing trading, quantitative trading a 1See, e.g., William Hinman, Director, Division of Corporation Finance, SEC, Remarks at the Yahoo Finance All Markets Summit: Digital Asset Transactions: When Howey Met Gary (Plastic) (Jun. 14, 2018), available at: https://www.sec.gov/news/speech/speech-hinman-061418. See also n.11. 2 The Company currently has no material assets or operations. Consistent with our response to prior comment 1, the Investment Company Act analysis set out below is based on the Company’s structure as it will exist at the time the Company succeeds to the businesses of GDHL and commences operations as the issuer and registrant under the Registration Statement. 3 See n.1. August 11, 2023 GLXY-3 Galaxy Digital Inc. and Galaxy Digital Holdings Ltd. request that the information contained in this letter, marked by “[***]”, be treated as confidential information pursuant to 17 C.F.R. § 200.83. U.S. Securities and Exchange Commission nd macro trading) within the Trading business conducted by GD LP and its wholly-owned subsidiaries throughout 2022.4 As such, GD LP’s engagement in the Trading business line, directly and through its wholly owned subsidiaries, is primarily attributable to exempt market intermediary activities under Section 3(c)(2) and assets that are not securities. Thus, GD LP is not and does not hold itself out as being engaged primarily, and does not propose to engage primarily, in the business of investing, reinvesting or trading in securities and therefore is not an investment company under Section 3(a)(1)(A). We note that starting in the first quarter of 2023, the Company re-segmented its primary business lines into three operating business segments for reporting purposes to be consistent with changes in its operations, from organic growth and recent acquisitions, and its management structure. The new segment structure does not change the fundamental nature of the Company’s primary business activities as described in our response to prior comment 1, which continue to consist of: 1.the Trading and Investment Banking business lines, which are now combined under the Galaxy Global Markets segment; 2.the Asset Management business line, which is under the Galaxy Asset Management segment; and 3.the Mining business line, which is under the Galaxy Digital Infrastructure Solutions segment along with other newly acquired infrastructure services businesses (e.g., GK8). The Company’s balance sheet venture investments, formerly referred to as the Principal Investments business line, no longer exists as a standalone business line, which more accurately reflects the Company’s focus on its three primary operating segments. For segment reporting purposes, the Company’s balance sheet venture investments now fall under the Galaxy Asset Management segment or within the business segment that is strategically aligned with the particular investment. This re-segmenting of business lines further underscores that the Company is not an investment company under Section 3(a)(1)(A), as it further demonstrates that the Company's principal investments are not its primary business. 5. Please describe the ownership interest of the Company and its affiliates in the funds and other investment vehicles managed by the Asset Management Entities. Galaxy advises the Staff that it has provided its response within Annex II hereto. 6. You define Primary Company Business as “the business of providing technology-driven diversified financial services, focused on digital asset trading (including market intermediary services for digital asset lending and borrowing), digital asset mining operations, asset management and investment banking…” Given that the Company is “focused on digital asset trading,” and is treating digital assets other than BTC or ETH as securities, please provide additional support for your conclusion that the historical development and public representations of the Company weigh in favor of the Company not falling within the investment company definition under section 3(a)(1)(A). Galaxy respectfully submits that, as discussed in our response to comment 4 above, the Company is primarily engaged in the Investment Banking, Asset Management and Mining business lines, as well as the Trading business line. The Company’s primary business lines are not investment company activities for the reasons discussed in our response to prior comment 1, including in terms of the five Tonopah Mining factors: i.e., the historical development of the Company’s business, public representations of the Company’s primary business as a diversified financial services company, activities of its officers and directors, nature of its assets and its sources of income. Historically, in public representations of the 4 This percentage does not reflect certain hedging transactions undertaken in connection with the client-facing trading activity. Nonetheless, as such hedging trans