Form 13G Zenvia Inc. For: 23 March

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Analysis

Regulatory waves and heightened disclosure regimes create a two-speed market: firms that already run institutional-grade compliance (regulated exchanges, CME/ICE, custody incumbents) stand to capture flows that leave noncompliant venues over 3–12 months. Expect fee and volume migration from unregulated on‑ramps to products that offer auditability and margining; that dynamic can add 10–30% incremental revenue to regulated derivatives venues in a stressed regulatory pivot, compressing growth multiples for pure-play retail platforms.

Near-term tail risk is headline-driven and very fast: enforcement actions, asset-class bans, or stablecoin rulings can trigger cascading deleveraging and on‑chain liquidations within 48–96 hours; however, policy implementations (rulemaking, bank custody pathway creation) take quarters to years, producing a multi-stage trade window. Reversal catalysts include clear regulatory carve-outs for custody/OTC plumbing or central bank digital currency (CBDC) interoperability standards that favor banks and custodians, which would re-rate incumbents and restore funding to exchanges.

Consensus positions appear directionally cautious but underweight the winners of regulatory consolidation. The regime favors marginable, centrally cleared instruments and audited custody — a structural tailwind for CME/ICE and traditional custodians, and a structural headwind for advertising-driven retail exchanges and native DeFi primitives without compliant rails. Tactical positioning should be short-duration around headlines and long-duration around incumbent infrastructure exposure.

Key Decisions for Investors

• Pair trade (3-month): short COIN via buying 3-month ATM puts sized 1–2% NAV / long CME 6-month calls sized 0.5–1% NAV. Rationale: capture downside from headline risk at consumer-exchange while owning regulated derivatives venue that should gain market share; target asymmetric 2–4x payoff if regulatory clarity shifts flows.
• Long custody/clearing exposure (12–24 months): initiate 1–2% NAV long in ICE or CME equity or long-term call spread on CME to express structural fee capture. Risk: rulemaking that equally burdens incumbents; reward: multiple expansion if 10–30% revenue migration occurs.
• Hedge miners (30–90 days): short miner equities (RIOT/MARA) via 1–2% NAV puts or pair short vs long BITO/GBTC exposure to protect vs rapid BTC drawdowns caused by forced deleveraging. Rationale: miners are high-leverage to price & funding stress; hedging reduces convexity risk.
• Volatility play (1–3 months): buy implied-volatility on crypto-native equities and options (COIN, MSTR) ahead of expected regulatory announcements — size 0.5–1% NAV. Reward is capture of realized > implied vol spikes; loss limited to premium.
• Contrarian long (6–12 months): if policy language pivots to regulated custody pathways, add 1% NAV to Coinbase or similar on weakness and rotate out of OTC-focused platforms — this assumes rule clarity that advantages compliant on‑ramps and can generate 2–3x total return from troughs.