Bullish Global first earnings report; SEC unleashes crypto ETFs

America now has two U.S.-listed digital asset exchanges filing detailed activity reports and is about to have another 100 or more digital asset-based exchange-traded funds (ETFs).

On Wednesday, the Bullish Global (NASDAQ: BLSH) exchange released its first quarterly earnings report as a public company following its listing on the Nasdaq on August 13. Until now, Coinbase (NASDAQ: COIN) was the only U.S. exchange that disclosed detailed information on both its financial performance and its customers’ activities.

For the three months ending June 30, Bullish booked an ‘adjusted net loss’ of $6 million from revenue of $57 million. Breaking down the latter figure, $24.1 million came from ‘adjusted’ transaction revenue, $31.9 million from subscription & services revenue—which includes the CoinDesk media/events/indices/data business—and $1 million from the ‘revaluation of digital assets held as investments.’

Bullish defines ‘adjusted transaction revenue’ as a formula of ‘volume x spread + fees.” However you slice it, the Q2 transaction total was a far cry from Q1’s $42 million, as BTC trading volume decreased dramatically as the quarter came to a close.

Bullish doesn’t yet provide as granular a look at its operations as Coinbase, but its overall average daily spot volume was $1.79 billion in Q2, down from $2.55 billion in Q1. The lowest monthly spot volume in Q1 was $74.8 billion. By contrast, April was Q2’s best month at $65.5 billion, but May slipped to $57.6 billion and June slid to $39.9 billion.

BTC was the main culprit of this decline, as monthly volume fell from $39.2 billion in April to $32.8 billion in May to $19.9 billion in June. Trading of the Ethereum network’s native token, ETH, was $10.9 billion in April, rising to $12 billion in May before sliding to $9.5 billion in June.

Stablecoin trading was a one-way affair, with three-month volume falling from $13.3 billion to $10.3 billion to $8.1 billion. Trading in ‘other’ tokens was an afterthought, hitting a quarterly low of $2.2 billion in April and a high of $2.6 billion in May before splitting the difference at $2.4 billion in June.

In terms of derivatives, perpetual futures trading volume was similarly impacted, with Q2’s total of $16.7 billion comparing unfavorably with Q1’s $22.4 billion.

The overall situation perked up somewhat in July and August, although BTC spot volume hit a 2025 low in August at $18.2 billion. ETH fared better, rising to $12.8 billion in August. ‘Other’ tokens also rebounded, notching a two-month total of $8.6 billion, better than Q2’s three-month total of $7.7 billion.

Despite its IPO preparations, Bullish kept a lid on its Q2 expenses, coming in less than 1% off Q1’s $49.2 million. Legal and professional fees were up around 20% to $6.6 million, while IT and software spending was up a similar percentage to $5.4 million. Advertising, promotion, and production posted the largest increase, up by one-half to $7.4 million, as marketing activity rose.

For Q3, Bullish expects total trading volume to continue to fall, possibly as low as $133 billion, but transaction revenue is expected to rise slightly from Q2. Larger gains are expected from the subscription and services segment, and the company expects to be firmly back in the ‘adjusted’ black by the quarter’s close.

Before publishing its results, Bullish announced that it had received a BitLicense from the New York Department of Financial Services (NYDFS), allowing it to provide New York-based institutions and advanced traders with spot trading and custody services.

Bullish CEO Tom Farley, a former president of the New York Stock Exchange (NYSE), called the company’s new diploma “a testament to Bullish’s commitment to regulatory compliance and our dedication to building trusted, institutional-grade digital asset infrastructure in key global markets.” Bullish President Chris Tyrer called the event “a significant regulatory milestone for our growth in the U.S.”

Bullish investors seemed relatively pleased with the day’s developments, pushing the shares up nearly 6% to close at $54.35 (and up another 3.5% in after-hours trading). However, that remains well below its opening day closing price of $74.63.

Market structure legislation going backward

Over on Capitol Hill, members of the Senate Banking Committee met with top crypto execs on September 17 to discuss how best to proceed with the committee’s digital asset market structure bill, the Responsible Financial Innovation Act of 2025 (RFIA).

Among the crypto firms represented at the meeting were the Coinbase and Kraken exchanges, USDC stablecoin-issuer Circle (NASDAQ: CRCL), XRP-issuer Ripple Labs, venture capital groups Andreessen Horowitz (a16z) (NASDAQ: ZADIHX), Paradigm, and Multicoin Capital, plus a few others.

The meeting reportedly centered on how best to refine language in the RFIA before it comes up for a committee vote. Committee leaders previously stated their desire to mark up the 182-page bill by the end of September, although some prominent GOP members aren’t sure that’s doable.

The House of Representatives approved its market structure bill (CLARITY Act) in July, and House leaders continue to press the Senate to ditch the RFIA deliberations and simply vote to approve CLARITY. Rep. French Hill (R-AR), CLARITY’s chief architect, went on CNBC.

On Wednesday, the Senate urged to “take prompt action” and “use the CLARITY Act that got 78 votes from Democrats in the House as their base text for passing their own bill for market framework.”

On September 10, Coinbase took out a full-page ad in the Washington Post depicting a mock eye chart in which the letters spell out “America voted for Clarity,” with a line at the bottom declaring that “It’s time for the Senate to ACT.” Coinbase CEO Brian Armstrong tweeted a directive to his followers to “[t]ell your member of congress to vote YES.”

Following Wednesday’s committee confab, Armstrong urged crypto fans to visit the website of Coinbase’s faux-grassroots advocacy group Stand With Crypto to fill out a form letter that will inform your local senator to “Support the CLARITY Act in the Senate.”

And yet the House itself isn’t actually done with CLARITY just yet. On Tuesday, the House Rules Committee offered up a procedural move to add the chamber’s anti-CBDC (central bank digital currency) measure (HR 1919), which was approved by a 219-210 vote in July, to CLARITY’s text.

The House originally opted against adding the anti-CBDC language to CLARITY due to the CBDC issue being far less popular with House Democrats. A new strategy emerged in which the anti-CBDC language would be included in a must-pass defense authorization bill. However, the measure’s lack of popularity among Senate Dems suggested that the Senate would strip this language ahead of their defense budget vote.

So a revised CLARITY is heading back to the Senate, but does the Senate care? The RFIA as yet contains no references to CBDCs, again, reflecting the subject’s relative unpopularity with Democrats (who have put forward their own market structure wish list).

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Coinbase v state’s rights

The letter then gets to the meat of Coinbase’s complaint, namely, the April lawsuit filed by Oregon’s Attorney General Dan Rayfield, who accused Coinbase of selling unregistered securities to Oregon residents. Rayfield stated at the time that it was up to states to “fill the enforcement vacuum” left by the current leadership of the Securities and Exchange Commission (SEC), which has dropped numerous suits against crypto firms, including one against Coinbase.

Coinbase responded to the Oregon suit by attempting to move it to federal court, where the exchange presumably expects a more favorable outcome given the pro-crypto stance of the current federal government. Coinbase also filed a countersuit in Oregon seeking access to public records that might illuminate Rayfield’s motives for going after Coinbase.

However, Coinbase also has a bone to pick with New York State, where the Attorney General wants to regulate tokens on decentralized finance (DeFi) platforms as securities. Then there’s Illinois, which approved two new laws governing exchanges and crypto ATMs last month. No less than four states—California, Maryland, New Jersey, and Wisconsin—have slapped Coinbase with cease-and-desist orders regarding its token staking services, while other regulatory indignities are being endured in other states.

Coinbase wants the DoJ to “fix these pressing problems by urging Congress to step in and enact broad preemption provisions.” The DoJ “should submit a views letter urging Congress to adopt broad preemption provisions in any market structure legislation.” Coinbase also suggests that the DoJ “make clear that new state licensing and other state regulatory requirements do not apply to crypto intermediaries, and apply retroactively.”

Coinbase’s Chief Legal Officer Paul Grewal, who authored the letter, tweeted that Oregon’s lawsuit “isn’t federalism—this is government run amok.” Grewal warned that “the executive branch and Congress need to act now” to “remedy” this alleged legal injustice.

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Coinbase v Gensler

Meanwhile, Coinbase’s fight with the SEC’s former Chairman, Gary Gensler, got a boost from a new report that really doesn’t paint the agency in a flattering light.

On September 3, the SEC’s Office of Inspector General (OIG) released a report on the “poorly understood and automated policy” implemented by the SEC’s Office of Information Technology (OIT) in August 2023 “that caused an enterprise wipe of Gensler’s government-issued mobile device.”

Said device was “erroneously thought to be inactive and no longer in use” after it “stopped communication with the SEC’s mobile device management system.” In reality, the device was functioning normally, but the new policy led the OIT to disconnect the device remotely.

On September 6, 2023, Gensler found that his device no longer showed SEC applications. Gensler sought help from OIT personnel, who performed the factory reset, permanently deleting “nearly a year’s worth of text messages” as well as operating system logs. OIT didn’t collect/maintain log data, leaving the agency “unable to collect or determine the entire universe, including some federal records.”

The alleged cockup rendered unrecoverable all of Gensler’s texts between October 18, 2022, and September 6, 2023. The OIG report notes that the loss of these texts “may impact the SEC’s response to certain Freedom of Information Act [FOIA] requests.”

Enter Coinbase, which had hired Maryland research/discovery firm History Associates Inc. to obtain Gensler’s digital communications related to digital assets. When it seemed that the SEC was stonewalling this request, History Associates filed a lawsuit with the U.S. District Court for the District of Columbia in June 2024.

Following the release of the OIG report, History Associates asked the Court to convene a hearing at which the SEC is compelled to explain its actions on the record. History Associates suggests the Court order expedited discovery, including depositions, to get to the bottom of things. Only once this info is disclosed and the SEC’s explanations/excuses are weighed can the Court determine “the appropriate additional remedial measures.”

That same day, Grewal slammed Gensler’s “double-standards,” adding that it was “not surprising that the same agency that fined firms billions for record-keeping failures committed the exact same violations.”

As if on cue, Gensler appeared on CBNC on Wednesday to defend his SEC legacy, saying the agency was “consistently trying to ensure for investor protection and in the midst of it we had a lot of fraudsters.” Gensler also weighed in on the overall state of crypto, calling the sector “highly speculative, very risky,” with most tokens—Bitcoin got a pass—“not tied to any fundamentals.”

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SEC unties a sack full of ETF monkeys

Gensler’s successor, Paul Atkins, has continually reduced or eliminated many of the guardrails that kept crypto from occasionally driving off a cliff. The SEC dropped yet another bomb on September 17 by dramatically reducing the process by which it approves token-based ETFs (or exchange-traded products, aka ETPs).

The SEC announced that it had approved “generic listing standards for exchange-traded products that hold spot commodities, including digital assets.” Three national securities exchanges—Nasdaq, NYSE Arca, and the Chicago Board Options Exchange (CBOE BZX)—have been okayed to list and trade Commodity-Based Trust Shares that meet these generic standards “without first submitting a proposed rule change” to the SEC.

Atkins said the approval “helps to maximize investor choice and foster innovation by streamlining the listing process and reducing barriers to access digital asset products within America’s trusted capital markets.”

SEC Commissioner Hester Peirce issued her own statement specifying that an ETP’s underlying commodity “may trade on a market that is an Intermarket Surveillance Group member, or underly a futures contract traded for at least six months on a [Commodity Futures Trading Commission]-regulated designated contract market.”

“Alternatively, if an [ETF] designed to provide economic exposure of no less than 40% of its net asset value to a commodity lists and trades on a national securities exchange, ETPs that provide exposure to the same commodity also can list and trade on the exchanges under today’s approved generic listing standards.”

Bloomberg ETF analyst James Seyffart underscored the seismic change afoot by tweeting, “WOW … This is the crypto ETP framework we’ve been waiting for. Get ready for a wave of spot crypto ETP launches in coming weeks and months.” Seyffart’s colleague Eric Balchunas said there is a “[g]ood chance we see north of 100 crypto ETFs launched in the next 12mo.” Seyffart replied that he’ll “take the over on 100 in 12 months.”

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