How you can profit from Facebook’s new coin (not by buying it!) [ Mark Zuckerberg. Photo: Chip Somodevilla/Getty Images] The Libra/Calibra project is going to work No — regulators won’t shut it down (I will explain) Huge volume is about to flow into digital assets Fancy a punt? Facebook stock and Crypto Exchange Tokens No one likes Facebook’s coin. Not crypto weirdos, not regulators, not banks. Facebook say it’s for financial inclusion and ‘banking the unbanked’. Bold, worthy goals everyone else thus far has failed to deliver. People are real mad a huge centralised company is about to do it (and the ‘worst one of all’). But none of that matters. Only this does: Will they do it? (Spoiler: YES) What’s likely to happen? And how can I profit? Reason 1: Regulators and competitors won’t stop them No …but expect lobbying from the banks, governments and everyone with an axe to grind. Lets go through their complaints. Critique #1: They’ll spy on our spending! In this bleak and nightmarish scenario Facebook has been bad, but gets badder. They use Libra to snoop on every detail of our personal finances and “they must be stopped”. But the company has seen this criticism a mile off. And it can defend itself a bunch of ways. They know there has to be a firewall between the payments system and the social network - and will make sure there is. Without it they are unable to defend accusations they are monetising confidential payments data. They’ll use encryption against themselves. Why? To deny themselves access to user data in a provable way. Like WhatsApp did after the Snowden/NSA wiretapping fiasco. And they have a bunch of big companies validating the transactions so they can’t be blamed for snooping or fraud. Read the docs — their intention is to appear as clear as possible. Remember — they’ve been smacked before by regulators. Facebook would love to spy on your money. But they won’t go there. Critique #2: Terrorists will use Libra to launder money! The best ways of getting Libra derailed are via the twin bogeymen of money laundering and terrorist financing. And this is where Facebook’s design gets clever. At the lowest (protocol) layer — Libra is pseudonymous, meaning you can conceal your identity but your transactions are visible. The big companies that will operate the network (Uber, Vodafone etc) will have some visibility into what’s going where but not who’s doing it. Need to find a launderer? No problem — Libra leaves a trail. The currencies design is a sweet spot with “good enough” privacy for users but allowing bad guys to be tracked down when necessary. Tony Montana predates mandatory KYC regulations. The second clever design element is separating the Libra network from the Calibra wallet. This shifts Know Your Customer (KYC) responsibilities onto the wallet provider. Facebook can comply with local regulation 100% in its implementation of Calibra — but if other providers don’t comply, well… Critique #3: Libra will get too big and overtake the financial system! No sooner was Libra out of the gate then calcified European bureaucrats were laying into it. Here’s the French Finance Minister: Mr Le Maire said it was “out of the question” that Libra be allowed to become a sovereign currency. “It can’t and it must not happen,” he said. Ah Putain! But Libra is not a sovereign currency. It’s a basket of existing sovereign currencies and doesn’t threaten any governments printing press. Libra only fluctuates in response to the monetary policy actions of its constituent currencies — actions it has no control over. There is no seignorage (=money creation). Now it is possible Libra gets so big it starts having real economic impact. But this won’t happen immediately. And by the time it does the genie will be out of the bottle. Libra: Best viewed as a serpentine water monster Facebook’s strategy with Libra is like the Hydra of Greek mythology. That is to say — a beast with many heads. Libra’s approach to regulators will be a many headed monster. Don’t like this head? Here’s another one — ‘Libras still going live! Take this tweet by Libra top brass david marcus: “ …full privacy on custodial wallets, and BTC-like privacy on chain. Enabling shielded transactions on layer 1 at this scale would be totally irresponsible” What is he saying here? “Full privacy on custodial wallets” means that Facebook can use cryptography to prove they know nothing about user’s business. “BTC-like privacy on chain” means criminals and money launderers can’t hide because Libras blockchain leaves a trail for the FBI. It’s private but it’s not. There’s two heads right there. If you’re a central banker: Libra = Facebook + Bitcoin. Except it isn’t — it’s just a bag of foreign exchange. Facebook can’t create money out of thin air and runs on the rails of a conventional, regulated financial system. Commercial banks are paranoid it’s going to be a banking competitor. But how do you make that argument? Libra is fully backed by assets and doesn’t extend loans. It’s a many headed conundrum. And if you stop it, who stops it and where? The most ‘Hydra like’ characteristic relates to regulation — different the world over. Facebook has been careful to reduce the legal attack surface of Libra by structuring the blockchain project as a Swiss based non profit, while requiring the wallet applications using real money to be compliant per jurisdiction. A Libra wallet could be OK in one country and be shut down in another. It doesn’t affect the fact the overall system will go live — irrespective of how many heads it has to grow. Reason 2: The tech is not a problem Most crypto projects start with copying someone else’s code (called a fork). Not the Facebook boffins: Eric Wall — “Of all the things with Libra, what an absolute disaster this is for Hyperledger & IBM… not a single consensus module was relevant enough for Facebook to continue building on.” No, they do it themselves at Facebook. Most conspicuously with the invention of a new programming language called Move. What’s going on with my money here? No idea — but it’s written in “Move” They have borrowed concepts. From Ethereum they’ve used a similar accounting model and gas based transaction costs. The governance model is sufficiently clever some company claimed they stole it. But there’s no better positioned company to build a new global payments system at massive scale. Chance of executional failure is not zero. But it’s close. OK — they probably won’t stop it. What’s likely to happen? The answer is huge usage of the Libra currency — and soon. Here’s why: 1/ The remittance market Money transfer from workers in 3rd work countries sending funds home is a marquee use case for Libra. It’s a business overdue for disruption (terrible term, I know). The competition is slow, lazy and expensive — and it’s a juicy half a trillion dollar market. Facebook have the moral high ground as it’s the worlds poorest who are currently getting screwed over. If they can execute (and they will) it will be a winner take all proposition. 2/ Crypto exchange stablecoin Libra will offer an alternative to Tether. Tether is the unloved and biggest stablecoin. It’s used by big crypto exchanges to change their crypto into USD and has a $20bn-30bn daily volume. Say you’re an exchange and currently use Tether for hedging. If you could replace it with Libra, you would. Tether is not ideal. It has sketchy banking arrangements. It trades in a regulatory fog. It has a very high velocity of circulation, meaning people can’t wait to get rid of it. Libra will offer a lower volatility alternative (it’s a basket). It’s going to be super liquid with paper thin spreads. And the banking relationships will be 100% solid. Tether might well get dumped. 3/ Partner payment funnels Uber, Lyft and Ebay are partners in the Libra consortium. It makes zero sense they would not offer the new coin as a payment option. These companies have gross revenues of $50bn, $8bn and $37bn. This is close to $100bn p.a. available to flow into the ecosystem. Uber, Lyft & Ebay support? Filthy lucre coming Libra’s way! By the way — ever wonder why they never created an Uber coin? The answer is the “velocity of circulation” I mentioned above. The minute the driver got it they would redeem it for local currency, making “UberCoin” pointless. Libra will be different. Drivers (and Ebay vendors) will hang on to Libra as they will be able to use them in all sorts of places. There are lots of ways Facebook can incentivise users to hold onto these coins. One is by paying interest. Currently they have no plans to offer interest payments on the collateral backing the stablecoin, but if rates rise and it affects peoples motivation to hold Libra in the wallet — they can pivot strategy. 4/ 3rd world usage If you live in a country with exchange controls and high inflation you suffer. Your savings erode and you can’t shift it into stable alternative currencies. Venezuela, Turkey, Iran and Zimbabwe are examples. Their citizens try to use Bitcoin to get around these laws but it’s difficult and often illegal. Facebook already has large user bases in these countries. It will want to stay on the side of its users — not an oppressive government. Depriving 3rd world citizens of access would be terrible PR. Expect Facebook to obey local banking laws in respect of wallet access but keep its platform (Libra) open. It’s easy to imagine a strong incentive for local commerce in Libra. For the same reasons people will want to hold their savings in it. If this happens Libra could begin to trade as a proxy sovereign currency in countries with exchange controls and high inflation rates. 5/ Use as a trading currency Libra will be a lower cost, more convenient international trading currency. A basket of currencies will be typically more stable than any of its constituents. It’s possible this stability makes Libra attractive for small/medium scale international trade. Buyers and sellers can price goods and shipping in $Libra. The coin will have low volatility against the local currencies of both buyer and seller. What about fraud and chargeback insurance? This is what makes Credit Card and PayPal transactions so expensive. Expect low cost payment protection, either from Facebook or a marketplace of parties competing to provide it. 6/ The WeChat Pay template (WhatsApp + Libra = $22 trillion?) There is a precedent for Facebook’s move into digital currency: China. WeChat Pay and AliPay are the twin leaders in mobile payment. What happened in China when the dominant messaging platform could make payments? Meteoric growth. Third-party mobile payment transaction volume in Mainland China is $22 trillion. WeChat has a user base of 1bn. Facebook is enabling payments on both Facebook Messenger and WhatsApp. They have a combined user base of 3bn. Oops — I’ve forgotten their plans to add it to Instagram. Another billion users. 7/ More coins are on the way if this works Libra is a mix of currencies — designed as a “world digital currency”. It’s good marketing and good politics to start the ball rolling. It’s trivial though for Facebook to roll out local currency versions backed by US, GBP, Euro, JPY. It starts innocently enough. Global use cases (remittance, trade) and good deeds (financial inclusion of the unbanked). But they can choose to shift gears at any time — enabling the WeChat Pay use case to play out. And it’s one where we know the outcome. In Asia even salaries are paid in the coin and money never leaves the digital sandbox. Will they do this? “Eventually, yes”. 8/ Facebook is the Facebook killer Social networks have accumulated massive value because of network effects. This value has been locked up in the silos of Facebook, Twitter & LinkedIn. And regulators and public opinion are pushing back. The goal eventually is decentralised social networks. A model where users can unlock their own value. Be paid for tweets, likes and compensated for exposing personal information. Crypto micropayments are what enable this endgame. The ideas here are not new — Brave’s Basic Attention Token (BAT) has had some traction. But collectively Facebook, WhatsApp & Instagram control content and distribution at massive scale. Facebook know they need to allow user monetisation before a competitor does. Or regulators force their hand. How can I make money from this? Facebook Stock (FB) The huge Libra opportunity is currently not understood by analysts, who are fixated on the risks of the legacy ad model and user data privacy regulation. Facebook’s stock is currently priced at a compound annual growth rate of 20% and a conservative price earnings multiple ~25x (S&P trades at ~20x). If Libra/Calibra were a standalone company with access to trillions of dollars in payment flow and a monopoly over the Facebook brand family it would be a multi billion dollar startup. The Libra rollout however has not moved the dial with respect to Facebook’s stock. This implies it is priced as if Libra has a zero possibility of success or completely discounts any value it will add. This will not last as analysts begin to price the project as an option on huge upside in user engagement and revenue. Crypto exchange tokens BNB, LEO Cryptocurrency exchanges will serve as an off ramp for Libra and an on ramp to all other digital assets. As such, total crypto market cap will rise dramatically. Profitability of major crypto exchanges will spike as transaction volumes surge. Binance and Bitfinex are large crypto exchanges which offer access to this profitability through “exchange tokens”. These tokens are tradeable cryptocurrencies that offer direct and indirect exposure to the revenue stream of the exchange, and have a diminishing supply due to a token burn process similar to equity buybacks. Exchange tokens BNB, LEO are currently the most effective way to gain exposure to increasing digital asset volumes TLDR; Facebook are going to succeed with Libra. Huge volume is incoming and likely growing monthly at high rates. Libra to be a top 5 token within months of launch. Likely to exceed entire crypto market cap within a 18 months. Assets likely to rise as a result? Facebook Stock and Crypto Exchange Tokens BNB, LEO. Disclaimer: I am not a financial adviser and nothing in this article should be construed as personal financial advice How you can profit from Facebook’s new coin (not by buying it!) [ Mark Zuckerberg. Photo: Chip Somodevilla/Getty Images ] Chip Somodevilla/Getty Images The Libra/Calibra project is going to work No — regulators won’t shut it down (I will explain) Huge volume is about to flow into digital assets Fancy a punt? Facebook stock and Crypto Exchange Tokens The Libra/Calibra project is going to work No — regulators won’t shut it down (I will explain) Huge volume is about to flow into digital assets Fancy a punt? Facebook stock and Crypto Exchange Tokens No one likes Facebook’s coin. Not crypto weirdos, not regulators, not banks. Facebook say it’s for financial inclusion and ‘banking the unbanked’. Bold, worthy goals everyone else thus far has failed to deliver. People are real mad a huge centralised company is about to do it (and the ‘worst one of all’). But none of that matters. But none of that matters. Only this does: Will they do it? (Spoiler: YES) Only this does: Will they do it? (Spoiler: YES) YES) What’s likely to happen? What’s likely to happen? And how can I profit? And how can I profit? Reason 1: Regulators and competitors won’t stop them Reason 1: Regulators and competitors won’t stop them No …but expect lobbying from the banks, governments and everyone with an axe to grind. Lets go through their complaints. Critique #1: They’ll spy on our spending! Critique #1: They’ll spy on our spending! In this bleak and nightmarish scenario Facebook has been bad, but gets badder. They use Libra to snoop on every detail of our personal finances and “they must be stopped”. But the company has seen this criticism a mile off. And it can defend itself a bunch of ways. They know there has to be a firewall between the payments system and the social network - and will make sure there is. Without it they are unable to defend accusations they are monetising confidential payments data. They’ll use encryption against themselves. Why? To deny themselves access to user data in a provable way. Like WhatsApp did after the Snowden/NSA wiretapping fiasco. And they have a bunch of big companies validating the transactions so they can’t be blamed for snooping or fraud. Read the docs — their intention is to appear as clear as possible . Remember — they’ve been smacked before by regulators. Like WhatsApp did as clear as possible Facebook would love to spy on your money. But they won’t go there. Facebook would love to spy on your money. But they won’t go there. Critique #2: Terrorists will use Libra to launder money! The best ways of getting Libra derailed are via the twin bogeymen of money laundering and terrorist financing. And this is where Facebook’s design gets clever. At the lowest (protocol) layer — Libra is pseudonymous, meaning you can conceal your identity but your transactions are visible. The big companies that will operate the network (Uber, Vodafone etc) will have some visibility into what’s going where but not who’s doing it. Need to find a launderer? No problem — Libra leaves a trail. The currencies design is a sweet spot with “good enough” privacy for users but allowing bad guys to be tracked down when necessary. Tony Montana predates mandatory KYC regulations. The second clever design element is separating the Libra network from the Calibra wallet. This shifts Know Your Customer (KYC) responsibilities onto the wallet provider. Facebook can comply with local regulation 100% in its implementation of Calibra — but if other providers don’t comply, well… Libra Calibra Critique #3: Libra will get too big and overtake the financial system! No sooner was Libra out of the gate then calcified European bureaucrats were laying into it. Here’s the French Finance Minister: Mr Le Maire said it was “out of the question” that Libra be allowed to become a sovereign currency. “It can’t and it must not happen,” he said. Mr Le Maire said it was “out of the question” that Libra be allowed to become a sovereign currency. “It can’t and it must not happen,” he said. Ah Putain! But Libra is not a sovereign currency. It’s a basket of existing sovereign currencies and doesn’t threaten any governments printing press. Libra only fluctuates in response to the monetary policy actions of its constituent currencies — actions it has no control over. There is no seignorage (=money creation). Now it is possible Libra gets so big it starts having real economic impact. But this won’t happen immediately. And by the time it does the genie will be out of the bottle. is Libra: Best viewed as a serpentine water monster Facebook’s strategy with Libra is like the Hydra of Greek mythology. That is to say — a beast with many heads. Libra’s approach to regulators will be a many headed monster. Don’t like this head? Here’s another one — ‘Libras still going live! Take this tweet by Libra top brass david marcus: Take this tweet by Libra top brass david marcus : david marcus “ …full privacy on custodial wallets, and BTC-like privacy on chain. Enabling shielded transactions on layer 1 at this scale would be totally irresponsible” “ …full privacy on custodial wallets, and BTC-like privacy on chain. Enabling shielded transactions on layer 1 at this scale would be totally irresponsible” What is he saying here? “Full privacy on custodial wallets” means that Facebook can use cryptography to prove they know nothing about user’s business. “BTC-like privacy on chain” means criminals and money launderers can’t hide because Libras blockchain leaves a trail for the FBI. It’s private but it’s not. There’s two heads right there. “Full privacy on custodial wallets” “BTC-like privacy on chain” If you’re a central banker: Libra = Facebook + Bitcoin. Except it isn’t — it’s just a bag of foreign exchange. Facebook can’t create money out of thin air and runs on the rails of a conventional, regulated financial system. Commercial banks are paranoid it’s going to be a banking competitor. But how do you make that argument? Libra is fully backed by assets and doesn’t extend loans. It’s a many headed conundrum. And if you stop it, who stops it and where? The most ‘Hydra like’ characteristic relates to regulation — different the world over. Facebook has been careful to reduce the legal attack surface of Libra by structuring the blockchain project as a Swiss based non profit, while requiring the wallet applications using real money to be compliant per jurisdiction. A Libra wallet could be OK in one country and be shut down in another. It doesn’t affect the fact the overall system will go live — irrespective of how many heads it has to grow. Reason 2: The tech is not a problem Most crypto projects start with copying someone else’s code (called a fork). Not the Facebook boffins: Eric Wall — “Of all the things with Libra, what an absolute disaster this is for Hyperledger & IBM… not a single consensus module was relevant enough for Facebook to continue building on.” Eric Wall — “Of all the things with Libra, what an absolute disaster this is for Hyperledger & IBM… not a single consensus module was relevant enough for Facebook to continue building on.” Eric Wall No, they do it themselves at Facebook. Most conspicuously with the invention of a new programming language called Move. new programming language What’s going on with my money here? No idea — but it’s written in “Move” They have borrowed concepts. From Ethereum they’ve used a similar accounting model and gas based transaction costs. The governance model is sufficiently clever some company claimed they stole it . have some company claimed they stole it But there’s no better positioned company to build a new global payments system at massive scale. Chance of executional failure is not zero. But it’s close. OK — they probably won’t stop it. What’s likely to happen? The answer is huge usage of the Libra currency — and soon. Here’s why: 1/ The remittance market Money transfer from workers in 3rd work countries sending funds home is a marquee use case for Libra. It’s a business overdue for disruption (terrible term, I know). The competition is slow, lazy and expensive — and it’s a juicy half a trillion dollar market. Facebook have the moral high ground as it’s the worlds poorest who are currently getting screwed over. If they can execute (and they will) it will be a winner take all proposition. 2/ Crypto exchange stablecoin Libra will offer an alternative to Tether. Tether is the unloved and biggest stablecoin. It’s used by big crypto exchanges to change their crypto into USD and has a $20bn-30bn daily volume. Say you’re an exchange and currently use Tether for hedging. If you could replace it with Libra, you would. Tether is not ideal. It has sketchy banking arrangements. It trades in a regulatory fog. It has a very high velocity of circulation, meaning people can’t wait to get rid of it. Libra will offer a lower volatility alternative (it’s a basket). It’s going to be super liquid with paper thin spreads. And the banking relationships will be 100% solid. Tether might well get dumped. 3/ Partner payment funnels Uber, Lyft and Ebay are partners in the Libra consortium. It makes zero sense they would not offer the new coin as a payment option. These companies have gross revenues of $50bn, $8bn and $37bn. This is close to $100bn p.a. available to flow into the ecosystem. Uber, Lyft & Ebay support? Filthy lucre coming Libra’s way! By the way — ever wonder why they never created an Uber coin? The answer is the “velocity of circulation” I mentioned above. The minute the driver got it they would redeem it for local currency, making “UberCoin” pointless. Libra will be different. Drivers (and Ebay vendors) will hang on to Libra as they will be able to use them in all sorts of places. There are lots of ways Facebook can incentivise users to hold onto these coins. One is by paying interest. Currently they have no plans to offer interest payments on the collateral backing the stablecoin, but if rates rise and it affects peoples motivation to hold Libra in the wallet — they can pivot strategy. 4/ 3rd world usage If you live in a country with exchange controls and high inflation you suffer. Your savings erode and you can’t shift it into stable alternative currencies. Venezuela, Turkey, Iran and Zimbabwe are examples. Their citizens try to use Bitcoin to get around these laws but it’s difficult and often illegal. Facebook already has large user bases in these countries. It will want to stay on the side of its users — not an oppressive government. Depriving 3rd world citizens of access would be terrible PR. Expect Facebook to obey local banking laws in respect of wallet access but keep its platform (Libra) open. It’s easy to imagine a strong incentive for local commerce in Libra. For the same reasons people will want to hold their savings in it. If this happens Libra could begin to trade as a proxy sovereign currency in countries with exchange controls and high inflation rates. 5/ Use as a trading currency Libra will be a lower cost, more convenient international trading currency. A basket of currencies will be typically more stable than any of its constituents. It’s possible this stability makes Libra attractive for small/medium scale international trade. Buyers and sellers can price goods and shipping in $Libra. The coin will have low volatility against the local currencies of both buyer and seller. What about fraud and chargeback insurance? This is what makes Credit Card and PayPal transactions so expensive. Expect low cost payment protection, either from Facebook or a marketplace of parties competing to provide it. 6/ The WeChat Pay template (WhatsApp + Libra = $22 trillion?) There is a precedent for Facebook’s move into digital currency: China. WeChat Pay and AliPay are the twin leaders in mobile payment. What happened in China when the dominant messaging platform could make payments? Meteoric growth. Third-party mobile payment transaction volume in Mainland China is $22 trillion. WeChat has a user base of 1bn. Facebook is enabling payments on both Facebook Messenger and WhatsApp. They have a combined user base of 3bn. Oops — I’ve forgotten their plans to add it to Instagram. Another billion users. 7/ More coins are on the way if this works Libra is a mix of currencies — designed as a “world digital currency”. It’s good marketing and good politics to start the ball rolling. It’s trivial though for Facebook to roll out local currency versions backed by US, GBP, Euro, JPY. It starts innocently enough. Global use cases (remittance, trade) and good deeds (financial inclusion of the unbanked). But they can choose to shift gears at any time — enabling the WeChat Pay use case to play out. And it’s one where we know the outcome. In Asia even salaries are paid in the coin and money never leaves the digital sandbox. Will they do this? “Eventually, yes”. 8/ Facebook is the Facebook killer Social networks have accumulated massive value because of network effects. This value has been locked up in the silos of Facebook, Twitter & LinkedIn. And regulators and public opinion are pushing back. The goal eventually is decentralised social networks. A model where users can unlock their own value. Be paid for tweets, likes and compensated for exposing personal information. Crypto micropayments are what enable this endgame. The ideas here are not new — Brave’s Basic Attention Token (BAT) has had some traction. But collectively Facebook, WhatsApp & Instagram control content and distribution at massive scale. Brave’s Basic Attention Token (BAT) Facebook know they need to allow user monetisation before a competitor does. Or regulators force their hand. How can I make money from this? Facebook Stock (FB) The huge Libra opportunity is currently not understood by analysts, who are fixated on the risks of the legacy ad model and user data privacy regulation. Facebook’s stock is currently priced at a compound annual growth rate of 20% and a conservative price earnings multiple ~25x (S&P trades at ~20x). If Libra/Calibra were a standalone company with access to trillions of dollars in payment flow and a monopoly over the Facebook brand family it would be a multi billion dollar startup. If Libra/Calibra were a standalone company with access to trillions of dollars in payment flow and a monopoly over the Facebook brand family it would be a multi billion dollar startup. The Libra rollout however has not moved the dial with respect to Facebook’s stock. This implies it is priced as if Libra has a zero possibility of success or completely discounts any value it will add. This will not last as analysts begin to price the project as an option on huge upside in user engagement and revenue. Crypto exchange tokens BNB, LEO Cryptocurrency exchanges will serve as an off ramp for Libra and an on ramp to all other digital assets. As such, total crypto market cap will rise dramatically. Profitability of major crypto exchanges will spike as transaction volumes surge. Binance and Bitfinex are large crypto exchanges which offer access to this profitability through “exchange tokens”. These tokens are tradeable cryptocurrencies that offer direct and indirect exposure to the revenue stream of the exchange, and have a diminishing supply due to a token burn process similar to equity buybacks. Exchange tokens BNB, LEO are currently the most effective way to gain exposure to increasing digital asset volumes Exchange tokens BNB, LEO are currently the most effective way to gain exposure to increasing digital asset volumes TLDR; Facebook are going to succeed with Libra. Huge volume is incoming and likely growing monthly at high rates. Libra to be a top 5 token within months of launch. Likely to exceed entire crypto market cap within a 18 months. Assets likely to rise as a result? Facebook Stock and Crypto Exchange Tokens BNB, LEO. Disclaimer: I am not a financial adviser and nothing in this article should be construed as personal financial advice Disclaimer: I am not a financial adviser and nothing in this article should be construed as personal financial advice
