Form 6K ING GROEP NV For: 10 March

Risk disclosure: Trading in financial instruments and cryptocurrencies involves high risk, including the potential loss of some or all invested capital and extreme price volatility. Fusion Media warns its published data may not be real-time or accurate and is indicative only; trading on margin amplifies these risks and investors should carefully assess objectives, experience, and seek professional advice.

Analysis

Regulatory tightening or clarified rule-sets are likely to accelerate concentration: compliant, custody-capable incumbents (large exchanges, custodians, asset managers and payments networks) win market share while offshore/gray venues and retail-only OTC desks shrink. Over 6-24 months expect fee pools to compress for high-leverage retail trading but expand for institutional custody, settlement and ETP issuance — a structural shift from trading-volume economics to asset-servicing economics that benefits balance-sheet-rich firms.

Second-order winners include regulated derivatives venues and cleared liquidity providers (higher cleared futures/OTC clearing volumes), plus banks that can offer custody and settlement infrastructure; losers are margin-first retail brokerages, pure-play miners and tokenized-revenue models dependent on high volatility. A key catalytic binary is a major enforcement action or a narrow court ruling within 3-9 months: a harsh ruling could vaporize onshore retail volumes (days-weeks shock), while a clear precedent that legitimizes custody/ETFs will compress volatility and redirect flows to institutional products over 6-12 months.

Monitor two micro-mechanisms: (1) on-ramp/off-ramp banking access — if a tier-1 bank withdraws services to a major exchange it can quickly move liquidity offshore within weeks; (2) custody insurance availability — insurance capacity constraints raise capital costs for custodians and are a 3-9 month brake on institutional adoption. The base-case is consolidation rather than eradication: crypto markets become more like other regulated asset classes, with lower headline volatility but larger, more stable fee annuities accruing to regulated service providers.

Key Decisions for Investors

• Long COIN (6–12 month horizon): accumulate on pullbacks of 15–25% from a recent high or buy into onshore regulatory clarity. Position size 2–4% NAV, target 2.5x upside vs downside (stop at 12% loss). Rationale: consolidation of onshore trading/custody fee pools; tightens revenue multiple if flows re-shift to regulated venues.
• Pair trade — Long CME / Short MARA (3–9 months): buy CME exposure (equity or 3–6 month call spread) vs short high-beta miners (MARA or RIOT) sized to be delta-neutral to BTC price moves. Expect futures/cleared volumes to gain at miners' expense as institutional flows favor regulated venues; target asymmetric payoff ~1.5–3x with downside protection via call/put collars.
• Long V and MA, underweight PYPL (12 months): overweight legacy payments networks (V, MA) to capture tokenized-asset rails and merchant fees, while trimming PYPL which has higher execution/regulatory exposure to crypto product churn. Size 2% each, expected steady 10–25% upside if token rails grow; set 10% stop-loss per name.
• Protective hedge — buy puts on high-leverage crypto proxies (MSTR or GBTC if relevant) for 3–6 months to guard portfolio gamma risk: cost is insurance against an enforcement or court loss that collapses onshore leverage. Hedge cost should be capped at 1–2% NAV for full protection in a 30–50% downside scenario.