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This week, Byron is enjoying the holidays and taking a break from newsletterland. Please enjoy this takeover edition from the Forward Guidance newsletter, written by Casey Wagner, Ben Strack and Felix Jauvin.

Merry Christmas and Happy Hanukkah to those who celebrate. Kwanzaa kicks off tomorrow too.

While Santa’s elves worked hard in the holiday lead-up, bitcoin miners were busy raising money for different purposes. 

We touched on this phenomenon earlier this month. Bitdeer noted proceeds from its convertible senior notes offering would go toward datacenter expansion and mining rig development. Marathon and Riot Platforms have signaled the route of using raised capital to buy more BTC.    

More recent announcements from two other segment players continue to highlight that not all BTC miners agree on the best way to spend the capital they secure.

Less than a week ago, Hut 8 touted its purchase of 990 BTC for $100 million (avg. price of ~$101,710). Two days earlier, CleanSpark CFO Gary Vecchiarelli noted his company was choosing not to pay such a price for BTC.

I followed up with Vecchiarelli. He told me the company is "laser focused on producing bitcoin from our mining operations at a significant discount to the spot price." The marginal cost to produce each coin last quarter was roughly $36,250, he explained. 

The company’s main 2025 growth priority is reaching a hash rate of 50 EH/s as soon as possible, while also growing its digital asset management group to manage its bitcoin treasury (9,297 BTC, as of Nov. 30). 

As Hut 8 buys more BTC, Marathon Digital has used capital from convertible notes to boost its BTC holdings to 44,394 BTC, as of Dec. 18. 

"We are happy to be different [from] those companies," Vecchiarelli said, adding that CleanSpark’s healthy margins allow the company to build its balance sheet holdings "in a durable fashion."

 Hut 8 CEO Asher Genoot made clear to me the company’s strategic bitcoin reserve is "a complement, not a substitute, to our core operating strategy, which prioritizes disciplined, fundamentals-driven growth."

The miner doesn’t have explicit price levels at which it would totally rule out buying BTC, Genoot added — but is "extremely sensitive to valuation extremes and [optimizes] for risk-adjusted returns."

— Ben Strack

Starting next year, the SEC will operate with a smaller team of commissioners while we wait for the Senate to approve President-elect Donald Trump’s nominees. 

SEC Commissioners Hester Peirce and Mark Uyeda, both Republicans, are the only sitting commissioners who will remain with the agency after Inauguration Day. After SEC Chair Gary Gensler departs, how the agency approaches the crypto industry should see a big shift, according to Peirce. 

"We have a big toolkit," Peirce said earlier this month during an appearance at the Blockchain Association Policy Summit. 

"We've always gravitated toward enforcement in this area as our tool of choice," she added. "I think when you see new commission changes and the composition changes, then the mix of cases can change as well."

The nature of federal agencies means that some — or most, in the SEC’s case — policy discussions happen behind closed doors, Uyeda added. 

"That's why we have the Administrative Procedure Act, to allow the public to comment on regulation," he said. "That's our accountability for the American public to provide that transparency." 

In cases where agency staff issue guidance that differs from SEC rules (for example SAB 121), there is no public comment period. 

In the case of SAB 121, both chambers of Congress elected to overturn the policy, which states that digital asset custodians should report a liability and "corresponding assets" on their balance sheets. President Biden ultimately vetoed the resolution, however. 

Uyeda looks forward to the agency providing more opportunities for public input. 

"Writing the shift is hard because we are pretty far down this road," Peirce said. 

Addressing the crypto industry directly, she added, "this is going to require a lot of hard work from us and from you to get back on the right foot, but I think we can do it."

— Casey Wagner

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1. Holiday memecoin mayhem!

2. BTC miners spend differently — here’s why 

3. SEC commissioners say agency may move away from enforcement actions 

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