Crypto Legislation Might Progress Beyond Talk in 2022
Financial regulators have for years attempted to apply existing laws to the multitude of issues created by digital assets. In 2021, leading federal regulators and members of Congress have begun to call for legislation to address these issues. As a result, 2022 may be the year when federal legislation finally addresses digital asset issues that have been growing since the mining of the first Bitcoin block in 2009.
Digital Asset Regulation in the Absence of Legislation
So far, Congress has left the task of addressing issues created by digital assets to regulatory agencies. Although a Congressional Blockchain Caucus formed in 2016, House and Senate members introduced few bills addressing digital assets until 2018. As of October 2021, Congress has not amended federal laws on financial regulation, which were last significantly revised by the Dodd-Frank Act in 2010, to address digital asset issues.
In the absence of legislation, issues that do not fit well into existing statutes have created problems. An example is the legal status of digital assets, which can be considered to be either securities or commodities, and can even shift from one to the other over time. Years after the SEC’s 2017 report applying the definition of a security to digital tokens, the SEC and the CFTC have yet to clarify the distinction between securities and commodities for the thousands of digital assets in existence.
SEC Chair Gary Gensler has called for Congress to act, stating in August, “We need additional Congressional authorities to prevent transactions, products, and platforms from falling between regulatory cracks.” Gensler has reached out to Sen. Elizabeth Warren (D-Ma.), who has expressed her own concerns about the need for legislation.
Legislation on Digital Assets in 2021
While regulators and members of Congress talked about the need for legislation, and the debate over cryptocurrency tax reporting in the 2021 infrastructure bill generated headlines, House and Senate bills proposing specific solutions to various issues quietly started to emerge.
Digital Token Sales
Several House bills attempt to address securities law barriers to digital token sales—some of them by building on ideas proposed by regulators in past years.
Exclusion from the definition of a security. Congressional Blockchain Caucus members have been introducing bills to exclude digital tokens from the definition of a security since 2018, and they have revived those bills in 2021. They include the Token Taxonomy Act of 2021 (H.R. 1628), successor to identically named bills in 2018 and 2019, and the Securities Clarity Act (H.R. 4451), successor to a 2020 namesake.
Safe harbor. SEC Commissioner Hester Peirce proposed a regulatory safe harbor for token sales in 2020, and two 2021 bills have proposed statutory safe harbors. Rep. Patrick McHenry (R-N.C.), Republican leader of the House Financial Services Committee, introduced a Clarity for Digital Tokens Act of 2021 (H.R. 5496) that would amend the Securities Act to create a safe harbor providing a grace period of exemption from Securities Act registration requirements. The Digital Asset Market Structure and Investor Protection Act (H.R. 4741) from Rep. Don Beyer (D-Va.) would amend the Securities Exchange Act to define a new type of security—a “digital asset security”—and add issuers of digital asset securities to an existing provision for delayed registration of securities.
Stablecoins
Stablecoins—digital currencies linked to the value of the U.S. dollar or other fiat currencies—have not yet been the subject of regulatory action, although Treasury Secretary Janet Yellen and Federal Reserve Chair Jerome Powell have each underscored the need to create a regulatory framework for them. The Beyer bill proposes to create a regulatory regime for stablecoins by amending Title 31 of the U.S. Code. Treasury Department approval would be required for any “digital asset fiat-based stablecoin” to be issued or used, under an application process to be established by Treasury in consultation with the Federal Reserve, the SEC, and the CFTC.
Serious consideration for any of these proposals in the current session of Congress may be unlikely. A spate of autumn bills on crypto ransom payments (S. 2666, S. 2923, S. 2926, H.R. 5501) shows that Congress is more inclined to pay attention first to issues that are more spectacular and less arcane. Moreover, the arcaneness of digital asset regulatory issues is likely only to increase further, now that major industry players such as Coinbase and Andreessen Horowitz are starting to roll out their own regulatory proposals.
Digital Dollar vs. Digital Yuan
Impetus to pass legislation on another type of digital asset, a central bank digital currency (CBDC), may come from a different source: rivalry with China.
China established itself as a world leader in developing a CBDC with a pilot project launched in 2020, and in 2021, the People’s Bank of China announced that its CBDC will be used at the Beijing Winter Olympics in February 2022. Republican Senators responded by calling for the U.S. Olympic Committee to forbid use of China’s CBDC by U.S. athletes in Beijing and introducing a bill (S. 2543) to require a study of its national security implications.
The Beijing Olympics could motivate a legislative mandate to accelerate implementation of a U.S. digital dollar, which the Federal Reserve has been in the process of considering in 2021. Antecedents to such legislation already exist. A House bill sponsored by 46 Republicans (H.R. 4792) has a provision that would require the Treasury Department to assess China’s CBDC project and report on the status of Federal Reserve work on a CBDC, and the Beyer bill includes a provision amending the Federal Reserve Act to authorize issuing a digital dollar.
Both parties are likely to support creating a digital dollar. The Covid-19 pandemic made a digital dollar for delivery of relief payments a popular idea in 2020, and House Democrats introduced bills with provisions for creating one in 2020 and 2021. Bipartisan support for a bill on a digital dollar, based on concerns both foreign and domestic in nature, could result.
International rivalry and bipartisan support may make the digital dollar a gateway issue for digital asset legislation in 2022. Legislative work on a digital dollar may open the door for considering further digital asset issues—including the regulatory issues that have been emerging for years—in 2022 and beyond.
(Edited)
More on Web3 & Crypto
:max_bytes(150000):strip_icc():gifv():format(webp)/reiff_headshot-5bfc2a60c9e77c00519a70bd.jpg)
Nathan Reiff
3 years ago
Howey Test and Cryptocurrencies: 'Every ICO Is a Security'
What Is the Howey Test?
To determine whether a transaction qualifies as a "investment contract" and thus qualifies as a security, the Howey Test refers to the U.S. Supreme Court cass: the Securities Act of 1933 and the Securities Exchange Act of 1934. According to the Howey Test, an investment contract exists when "money is invested in a common enterprise with a reasonable expectation of profits from others' efforts."
The test applies to any contract, scheme, or transaction. The Howey Test helps investors and project backers understand blockchain and digital currency projects. ICOs and certain cryptocurrencies may be found to be "investment contracts" under the test.
Understanding the Howey Test
The Howey Test comes from the 1946 Supreme Court case SEC v. W.J. Howey Co. The Howey Company sold citrus groves to Florida buyers who leased them back to Howey. The company would maintain the groves and sell the fruit for the owners. Both parties benefited. Most buyers had no farming experience and were not required to farm the land.
The SEC intervened because Howey failed to register the transactions. The court ruled that the leaseback agreements were investment contracts.
This established four criteria for determining an investment contract. Investing contract:
- An investment of money
- n a common enterprise
- With the expectation of profit
- To be derived from the efforts of others
In the case of Howey, the buyers saw the transactions as valuable because others provided the labor and expertise. An income stream was obtained by only investing capital. As a result of the Howey Test, the transaction had to be registered with the SEC.
Howey Test and Cryptocurrencies
Bitcoin is notoriously difficult to categorize. Decentralized, they evade regulation in many ways. Regardless, the SEC is looking into digital assets and determining when their sale qualifies as an investment contract.
The SEC claims that selling digital assets meets the "investment of money" test because fiat money or other digital assets are being exchanged. Like the "common enterprise" test.
Whether a digital asset qualifies as an investment contract depends on whether there is a "expectation of profit from others' efforts."
For example, buyers of digital assets may be relying on others' efforts if they expect the project's backers to build and maintain the digital network, rather than a dispersed community of unaffiliated users. Also, if the project's backers create scarcity by burning tokens, the test is met. Another way the "efforts of others" test is met is if the project's backers continue to act in a managerial role.
These are just a few examples given by the SEC. If a project's success is dependent on ongoing support from backers, the buyer of the digital asset is likely relying on "others' efforts."
Special Considerations
If the SEC determines a cryptocurrency token is a security, many issues arise. It means the SEC can decide whether a token can be sold to US investors and forces the project to register.
In 2017, the SEC ruled that selling DAO tokens for Ether violated federal securities laws. Instead of enforcing securities laws, the SEC issued a warning to the cryptocurrency industry.
Due to the Howey Test, most ICOs today are likely inaccessible to US investors. After a year of ICOs, then-SEC Chair Jay Clayton declared them all securities.
SEC Chairman Gensler Agrees With Predecessor: 'Every ICO Is a Security'
Howey Test FAQs
How Do You Determine If Something Is a Security?
The Howey Test determines whether certain transactions are "investment contracts." Securities are transactions that qualify as "investment contracts" under the Securities Act of 1933 and the Securities Exchange Act of 1934.
The Howey Test looks for a "investment of money in a common enterprise with a reasonable expectation of profits from others' efforts." If so, the Securities Act of 1933 and the Securities Exchange Act of 1934 require disclosure and registration.
Why Is Bitcoin Not a Security?
Former SEC Chair Jay Clayton clarified in June 2018 that bitcoin is not a security: "Cryptocurrencies: Replace the dollar, euro, and yen with bitcoin. That type of currency is not a security," said Clayton.
Bitcoin, which has never sought public funding to develop its technology, fails the SEC's Howey Test. However, according to Clayton, ICO tokens are securities.
A Security Defined by the SEC
In the public and private markets, securities are fungible and tradeable financial instruments. The SEC regulates public securities sales.
The Supreme Court defined a security offering in SEC v. W.J. Howey Co. In its judgment, the court defines a security using four criteria:
- An investment contract's existence
- The formation of a common enterprise
- The issuer's profit promise
- Third-party promotion of the offering
Read original post.
Percy Bolmér
3 years ago
Ethereum No Longer Consumes A Medium-Sized Country's Electricity To Run
The Merge cut Ethereum's energy use by 99.5%.
The Crypto community celebrated on September 15, 2022. This day, Ethereum Merged. The entire blockchain successfully merged with the Beacon chain, and it was so smooth you barely noticed.
Many have waited, dreaded, and longed for this day.
Some investors feared the network would break down, while others envisioned a seamless merging.
Speculators predict a successful Merge will lead investors to Ethereum. This could boost Ethereum's popularity.
What Has Changed Since The Merge
The merging transitions Ethereum mainnet from PoW to PoS.
PoW sends a mathematical riddle to computers worldwide (miners). First miner to solve puzzle updates blockchain and is rewarded.
The puzzles sent are power-intensive to solve, so mining requires a lot of electricity. It's sent to every miner competing to solve it, requiring duplicate computation.
PoS allows investors to stake their coins to validate a new transaction. Instead of validating a whole block, you validate a transaction and get the fees.
You can validate instead of mine. A validator stakes 32 Ethereum. After staking, the validator can validate future blocks.
Once a validator validates a block, it's sent to a randomly selected group of other validators. This group verifies that a validator is not malicious and doesn't validate fake blocks.
This way, only one computer needs to solve or validate the transaction, instead of all miners. The validated block must be approved by a small group of validators, causing duplicate computation.
PoS is more secure because validating fake blocks results in slashing. You lose your bet tokens. If a validator signs a bad block or double-signs conflicting blocks, their ETH is burned.
Theoretically, Ethereum has one block every 12 seconds, so a validator forging a block risks burning 1 Ethereum for 12 seconds of transactions. This makes mistakes expensive and risky.
What Impact Does This Have On Energy Use?
Cryptocurrency is a natural calamity, sucking electricity and eating away at the earth one transaction at a time.
Many don't know the environmental impact of cryptocurrencies, yet it's tremendous.
A single Ethereum transaction used to use 200 kWh and leave a large carbon imprint. This update reduces global energy use by 0.2%.
Ethereum will submit a challenge to one validator, and that validator will forward it to randomly selected other validators who accept it.
This reduces the needed computing power.
They expect a 99.5% reduction, therefore a single transaction should cost 1 kWh.
Carbon footprint is 0.58 kgCO2, or 1,235 VISA transactions.
This is a big Ethereum blockchain update.
I love cryptocurrency and Mother Earth.
Trent Lapinski
3 years ago
What The Hell Is A Crypto Punk?
We are Crypto Punks, and we are changing your world.
A “Crypto Punk” is a new generation of entrepreneurs who value individual liberty and collective value creation and co-creation through decentralization. While many Crypto Punks were born and raised in a digital world, some of the early pioneers in the crypto space are from the Oregon Trail generation. They were born to an analog world, but grew up simultaneously alongside the birth of home computing, the Internet, and mobile computing.
A Crypto Punk’s world view is not the same as previous generations. By the time most Crypto Punks were born everything from fiat currency, the stock market, pharmaceuticals, the Internet, to advanced operating systems and microprocessing were already present or emerging. Crypto Punks were born into pre-existing conditions and systems of control, not governed by logic or reason but by greed, corporatism, subversion, bureaucracy, censorship, and inefficiency.
All Systems Are Human Made
Crypto Punks understand that all systems were created by people and that previous generations did not have access to information technologies that we have today. This is why Crypto Punks have different values than their parents, and value liberty, decentralization, equality, social justice, and freedom over wealth, money, and power. They understand that the only path forward is to work together to build new and better systems that make the old world order obsolete.
Unlike the original cypher punks and cyber punks, Crypto Punks are a new iteration or evolution of these previous cultures influenced by cryptography, blockchain technology, crypto economics, libertarianism, holographics, democratic socialism, and artificial intelligence. They are tasked with not only undoing the mistakes of previous generations, but also innovating and creating new ways of solving complex problems with advanced technology and solutions.
Where Crypto Punks truly differ is in their understanding that computer systems can exist for more than just engagement and entertainment, but actually improve the human condition by automating bureaucracy and inefficiency by creating more efficient economic incentives and systems.
Crypto Punks Value Transparency and Do Not Trust Flawed, Unequal, and Corrupt Systems
Crypto Punks have a strong distrust for inherently flawed and corrupt systems. This why Crypto Punks value transparency, free speech, privacy, and decentralization. As well as arguably computer systems over human powered systems.
Crypto Punks are the children of the Great Recession, and will never forget the economic corruption that still enslaves younger generations.
Crypto Punks were born to think different, and raised by computers to view reality through an LED looking glass. They will not surrender to the flawed systems of economic wage slavery, inequality, censorship, and subjection. They will literally engineer their own unstoppable financial systems and trade in cryptography over fiat currency merely to prove that belief systems are more powerful than corruption.
Crypto Punks are here to help achieve freedom from world governments, corporations and bankers who monetizine our data to control our lives.
Crypto Punks Decentralize
Despite all the evils of the world today, Crypto Punks know they have the power to create change. This is why Crypto Punks are optimistic about the future despite all the indicators that humanity is destined for failure.
Crypto Punks believe in systems that prioritize people and the planet above profit. Even so, Crypto Punks still believe in capitalistic systems, but only capitalistic systems that incentivize good behaviors that do not violate the common good for the sake of profit.
Cyber Punks Are Co-Creators
We are Crypto Punks, and we will build a better world for all of us. For the true price of creation is not in US dollars, but through working together as equals to replace the unequal and corrupt greedy systems of previous generations.
Where they have failed, Crypto Punks will succeed. Not because we want to, but because we have to. The world we were born into is so corrupt and its systems so flawed and unequal we were never given a choice.
We have to be the change we seek.
We are Crypto Punks.
Either help us, or get out of our way.
Are you a Crypto Punk?
You might also like
Desiree Peralta
3 years ago
Why Now Is Your Chance To Create A Millionaire Career
People don’t believe in influencers anymore; they need people like you.
Social media influencers have dominated for years. We've seen videos, images, and articles of *famous* individuals unwrapping, reviewing, and endorsing things.
This industry generates billions. This year, marketers spent $2.23 billion on Instagram, $1 million on Youtube, and $775 million on Tiktok. This marketing has helped start certain companies.
Influencers are dying, so ordinary people like us may take over this billion-dollar sector. Why?
Why influencers are perishing
Most influencers lie to their fans, especially on Instagram. Influencers' first purpose was to make their lives so flawless that others would want to buy their stuff.
In 2015, an Australian influencer with 600,000 followers went viral for revealing all her photos and everything she did to seem great before deleting her account.
“I dramatically edited the pictures, I manipulated the environements, and made my life look perfect in social media… I remember I obsessively checked the like count for a full week since uploading it, a selfie that now has close to 2,500 likes. It got 5 likes. This was when I was so hungry for social media validation … This was the reason why I quit social media: for me, personally, it consumed me. I wasn’t living in a 3D world.”
Influencers then lost credibility.
Influencers seem to live in a bubble, separate from us. Thanks to self-popularity love's and constant awareness campaigns, people find these people ridiculous.
Influencers are praised more for showing themselves as natural and common than for showing luxuries and lies.
Little by little, they are dying, making room for a new group to take advantage of this multi-million dollar business, which gives us (ordinary people) a big opportunity to grow on any content creation platform we want.
Why this is your chance to develop on any platform for creating content
In 2021, I wrote “Not everyone who talks about money is a Financial Advisor, be careful of who you take advice from,”. In it, I warned that not everyone with a large following is a reputable source of financial advice.
Other writers hated this post and said I was wrong.
People don't want Jeff Bezos or Elon Musk's counsel, they said. They prefer to hear about their neighbor's restroom problems or his closest friend's terrible business.
Real advice from regular folks.
And I found this was true when I returned to my independent YouTube channel and had more than 1000 followers after having abandoned it with fewer than 30 videos in 2021 since there were already many personal finance and travel channels and I thought mine wasn't special.
People appreciated my videos because I was a 20-something girl trying to make money online, and they believed my advice more than that of influencers with thousands of followers.
I think today is the greatest time to grow on any platform as an ordinary person. Normal individuals give honest recommendations about what works for them and look easier to make because they have the same options as us.
Nobody cares how a millionaire acquired a Lamborghini unless it's entertaining. Education works now. Real counsel from average people is replicable.
Many individuals don't appreciate how false influencers seem (unreal bodies and excessive surgery and retouching) since it makes them feel uneasy.
That's why body-positive advertisements have been so effective, but they've lost ground in places like Tiktok, where the audience wants more content from everyday people than influencers living amazing lives. More people will relate to your content if you appear genuine.
Last thoughts
Influencers are dwindling. People want more real people to give real advice and demonstrate an ordinary life.
People will enjoy anything you tell about your daily life as long as you provide value, and you can build a following rapidly if you're honest.
This is a millionaire industry that is getting more expensive and will go with what works, so stand out immediately.
Hunter Walk
2 years ago
Is it bad of me to want our portfolio companies to generate greater returns for outside investors than they did for us as venture capitalists?
Wishing for Lasting Companies, Not Penny Stocks or Goodwill Write-Downs
Get me a NASCAR-style company-logoed cremation urn (notice to the executor of my will, theres gonna be a lot of weird requests). I believe in working on projects that would be on your tombstone. As the Homebrew logo is tattooed on my shoulder, expanding the portfolio to my posthumous commemoration is easy. But this isn't an IRR victory lap; it's a hope that the firms we worked for would last beyond my lifetime.
![a little boy planting a dollar bill in the ground and pouring a watering can out on it, digital art [DALL-E]](https://storage.googleapis.com/int3grity/posts/V62hkReDx56S/images/vMwzqrYeXaYnUIMXAdTY9)
Venture investors too often take credit or distance themselves from startups based on circumstances. Successful companies tell stories of crucial introductions, strategy conversations, and other value. Defeats Even whether our term involves Board service or systematic ethical violations, I'm just a little investment, so there's not much I can do. Since I'm guilty, I'm tossing stones from within the glass home (although we try to own our decisions through the lifecycle).
Post-exit company trajectories are usually unconfounded. Off the cap table, no longer a shareholder (or a diminishing one as you sell off/distribute), eventually leaving the Board. You can cheer for the squad or forget about it, but you've freed the corporation and it's back to portfolio work.
As I look at the downward track of most SPACs and other tarnished IPOs from the last few years, I wonder how I would feel if those were my legacy. Is my job done? Yes. When investing in a business, the odds are against it surviving, let alone thriving and being able to find sunlight. SPAC sponsors, institutional buyers, retail investments. Free trade in an open market is their right. Risking and losing capital is the system working! But
We were lead or co-lead investors in our first three funds, but as additional VCs joined the company, we were pushed down the cap table. Voting your shares rarely matters; supporting the firm when they need it does. Being valuable, consistent, and helping the company improve builds trust with the founders.
I hope every startup we sponsor becomes a successful public company before, during, and after we benefit. My perspective of American capitalism. Well, a stock ticker has a lot of garbage, and I support all types of regulation simplification (in addition to being a person investor in the Long-Term Stock Exchange). Yet being owned by a large group of investors and making actual gains for them is great. Likewise does seeing someone you met when they were just starting out become a public company CEO without losing their voice, leadership, or beliefs.
I'm just thinking about what we can do from the start to realize value from our investments and build companies with bright futures. Maybe seed venture financing shouldn't impact those outcomes, but I'm not comfortable giving up that obligation.
Simon Ash
2 years ago
The Three Most Effective Questions for Ongoing Development
The Traffic Light Approach to Reviewing Personal, Team and Project Development
What needs improvement? If you want to improve, you need to practice your sport, musical instrument, habit, or work project. You need to assess your progress.
Continuous improvement is the foundation of focused practice and a growth mentality. Not just individually. High-performing teams pursue improvement. Right? Why is it hard?
As a leadership coach, senior manager, and high-level athlete, I've found three key questions that may unlock high performance in individuals and teams.
Problems with Reviews
Reviewing and improving performance is crucial, however I hate seeing review sessions in my diary. I rarely respond to questionnaire pop-ups or emails. Why?
Time constrains. Requests to fill out questionnaires often state they will take 10–15 minutes, but I can think of a million other things to do with that time. Next, review overload. Businesses can easily request comments online. No matter what you buy, someone will ask for your opinion. This bombardment might make feedback seem bad, which is bad.
The problem is that we might feel that way about important things like personal growth and work performance. Managers and team leaders face a greater challenge.
When to Conduct a Review
We must be wise about reviewing things that matter to us. Timing and duration matter. Reviewing the experience as quickly as possible preserves information and sentiments. Time must be brief. The review's importance and size will determine its length. We might only take a few seconds to review our morning coffee, but we might require more time for that six-month work project.
These post-event reviews should be supplemented by periodic reflection. Journaling can help with daily reflections, but I also like to undertake personal reviews every six months on vacation or at a retreat.
As an employee or line manager, you don't want to wait a year for a performance assessment. Little and frequently is best, with a more formal and in-depth assessment (typically with a written report) in 6 and 12 months.
The Easiest Method to Conduct a Review Session
I follow Einstein's review process:
“Make things as simple as possible but no simpler.”
Thus, it should be brief but deliver the necessary feedback. Quality critique is hard to receive if the process is overly complicated or long.
I have led or participated in many review processes, from strategic overhauls of big organizations to personal goal coaching. Three key questions guide the process at either end:
What ought to stop being done?
What should we do going forward?
What should we do first?
Following the Rule of 3, I compare it to traffic lights. Red, amber, and green lights:
Red What ought should we stop?
Amber What ought to we keep up?
Green Where should we begin?
This approach is easy to understand and self-explanatory, however below are some examples under each area.
Red What ought should we stop?
As a team or individually, we must stop doing things to improve.
Sometimes they're bad. If we want to lose weight, we should avoid sweets. If a team culture is bad, we may need to stop unpleasant behavior like gossiping instead of having difficult conversations.
Not all things we should stop are wrong. Time matters. Since it is finite, we sometimes have to stop nice things to focus on the most important. Good to Great author Jim Collins famously said:
“Don’t let the good be the enemy of the great.”
Prioritizing requires this idea. Thus, decide what to stop to prioritize.
Amber What ought to we keep up?
Should we continue with the amber light? It helps us decide what to keep doing during review. Many items fall into this category, so focus on those that make the most progress.
Which activities have the most impact? Which behaviors create the best culture? Success-building habits?
Use these questions to find positive momentum. These are the fly-wheel motions, according to Jim Collins. The Compound Effect author Darren Hardy says:
“Consistency is the key to achieving and maintaining momentum.”
What can you do consistently to reach your goal?
Green Where should we begin?
Finally, green lights indicate new beginnings. Red/amber difficulties may be involved. Stopping a red issue may give you more time to do something helpful (in the amber).
This green space inspires creativity. Kolbs learning cycle requires active exploration to progress. Thus, it's crucial to think of new approaches, try them out, and fail if required.
This notion underpins lean start-build, up's measure, learn approach and agile's trying, testing, and reviewing. Try new things until you find what works. Thomas Edison, the lighting legend, exclaimed:
“There is a way to do it better — find it!”
Failure is acceptable, but if you want to fail forward, look back on what you've done.
John Maxwell concurred with Edison:
“Fail early, fail often, but always fail forward”
A good review procedure lets us accomplish that. To avoid failure, we must act, experiment, and reflect.
Use the traffic light system to prioritize queries. Ask:
Red What needs to stop?
Amber What should continue to occur?
Green What might be initiated?
Take a moment to reflect on your day. Check your priorities with these three questions. Even if merely to confirm your direction, it's a terrific exercise!