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Dwayne “The Rock” Johnson hit theaters last weekend as DC’s latest comic book hero, Black Adam. But before millions of flesh-and-blood moviegoers watched him tear up the big screen, millions of fans had the chance to interact with an avatar of his character in Roblox. 
 
It’s a sign of the times. As much of Hollywood cools to blockchain-related projects during the current crypto downturn, the digital platform whose number of daily users tops the population of South Korea is increasingly providing a safe space for stars keen to experiment with the metaverse. 
 
“Roblox is definitely a huge area of interest for a lot of the clients we are working with across our company’s roster,” said digital strategy agent Kate Lonczak of WME, a top Hollywood talent agency which counts Johnson as one of its top clients. Roblox is gaining ground as a low risk metaverse play,  Lonczak said, noting that many Hollywood stars have cooled to the web3 space since crypto prices crashed and some celebrity endorsements went belly up. 
 
“You can expect to see some more traditional talent getting into Roblox in the near future,” she said. 
 
And for younger consumers, especially the all-important Gen Z demographic, “Roblox is the metaverse,” said Reza Izad, co-founder of Underscore Talent, which represents professional gamers and digital celebrities like YouTubers who have tens of millions of fans. Izad said his firm is eager to partner his clients with established Roblox creators. “There’s thousands of Roblox servers … where somebody has built an entire world,” he said, adding that some of the games and worlds that exist on the platform have attracted billions of visits. 

Across the board, major corporations are fishing for ways to engage with the metaverse. But sinking crypto prices and values for NFTs, when coupled with a string of celebrity endorsements gone wrong, have ratcheted up the level of scrutiny and hesitancy surrounding new projects, causing investment into blockchain-related ventures to shrink. Meanwhile digital platforms like Fortnite, Minecraft and Roblox — with tens of millions of daily users that serve as functioning versions of the metaverse in many people’s eyes — are viewed as relatively innocuous virtual spaces, where companies can safely experiment with the commercial possibilities of web3, a market analysts have projected to be worth trillions of dollars in the years to come.

Legacy Hollywood studio Warner Bros. promoted “Black Adam” in Roblox leading up to its debut. On the platform, fans could unlock “exclusive avatar items” plus interact with a Roblox-avatar version of Johnson’s character. Roblox’s “Black Adam” experience has been visited more than 5 million times. 
 
“We’re at a stage where we’re seeing a lot of really exciting experimentation, whether that be from experiences that complement IRL [in real life] events, create social spaces for watch/listening parties, or extend the reach of beloved IP to new audiences in as yet unimagined environments,” said Todd Lichten, Roblox’s head of entertainment partnerships. Lichten added that Roblox offers the entertainment industry a chance to learn more about consumers while augmenting traditional avenues for interacting with fans. 
 
Roblox has worked with other Hollywood giants including Universal Pictures and Paramount Global. Crypto booster Paris Hilton has her own personalized Roblox game, which recently announced a Halloween-themed event called Cryptoween.  

Roblox said it had nearly 58 million daily active users in September, a 23% increase from the previous year. During the second quarter of 2022 users spent more than 11 billion hours on the platform, a 16% increase year-on-year, the company also said. 

The best comparisons of what Roblox has been able to accomplish are Fortnite and Minecraft. While Roblox shares similarities with both gaming platforms, including attracting millions of users each day, Roblox stands apart because of the combined level of socialization and freedom to create that it offers. This is why, for many people, Roblox is considered to be the closest thing to a working metaverse. 
 
Meta, on the other hand, is far behind. Despite investing billions of dollars in its version of the metaverse, the company formerly known as Facebook has struggled to gain traction, according to a recent report in The Wall Street Journal. The Journal said that Meta’s flagship platform, called Horizon Worlds, hosts less than 200,000 users each month.

Crypto turmoil

While Roblox has established itself as a safe space for Hollywood studios and stars to experiment, elsewhere in the nascent metaverse, particularly among blockchain-powered assets and ventures, times have been exceedingly difficult since the onset of crypto winter. 
 
Blockchain-enabled platforms like The Sandbox and Decentraland, which have arguably attracted an inordinate amount of attention from investors and the media, are, for now, only achieving daily user numbers in the thousands. 
 
Other metaverse-related projects are struggling, in part, because prices for key cryptocurrencies like bitcoin and ethereum have both nosedived by more than 60% in the last year. NFT trading volumes, as measured by corresponding U.S. dollar values, are also down more than 80% year-to-date. The widespread market turmoil also has caused the values of many gaming tokens, like those used by play-to-earn games such as Axie Infinity, to plummet.

Celebrity endorsements gone awry

With falling prices, some high-profile celebrity endorsements, made during the bull market, have not aged particularly well, including A-list actor Matt Damon shilling for cryptocurrency investment platform Crypto.com during the Super Bowl, and actress Reese Witherspoon’s company Hello Sunshine helping to launch an NFT collection that has seen its average sales price fall by more than 80%.

In perhaps the most publicized example, reality TV star-turned-business mogul Kim Kardashian agreed to pay the Securities and Exchange Commission $1.26 million in penalties after unlawfully promoting the EthereumMax token on social media.

The public scrutiny of crypto and NFTs coupled with the more bearish market has triggered a major shift across Hollywood.

In general, Hollywood stars once eager to take advantage of skyrocketing prices for crypto and NFTs have gone silent, according to several people familiar with dealmaking across the entertainment industry. “Obviously there was more excitement around the bull market,” said one top Hollywood agent, adding that now it often feels like his team spends more time telling clients what not to do. “You don’t want to go and do something that is going to jeopardize your credibility in the space.”  
 
Keeping the faith 
 
While many traditional Hollywood stars are erring on the side of caution, the entertainment industry’s top talent agencies are forging ahead, looking at the downturn as a “time to build,” as one agent put it. 
 
So far this year WME has added to its roster NFT creators like CryptoKitties co-founder Mack Flavelle, Bright Moments and Boss Beauties.

United Talent Agency, or UTA, one of Hollywood’s big three talent agencies —and perhaps the first big Hollywood agency to mobilize around crypto-related projects— has this year signed the Deadfellaz NFT collection as well as the web3 visual artist Diana Sinclair. The agency also aided Sinclair in securing a partnership with the legacy auction house Christie’s. 

Part of Anthony Hopkins’ NFT collection

Besides signing creators, Creative Artists Agency, or CAA, has also invested in OpenSea, the world’s largest NFT marketplace and MoonPay, a start-up that helps people buy and sell crypto using traditional payment methods. CAA’s web3 client list includes Jenkins the Valet, Nyla Hayes and Cool Cats. Earlier this month, actor Anthony Hopkins —a client of CAA’s since March — launched a 1,000-piece NFT collection, created in partnership with production company Orange Comet, The collection sold out in seven minutes.

CAA’s Chief Metaverse Officer Joanna Popper recently waxed optimistically about web3’s potential, citing the commercial possibilities that exist in digital spaces like Roblox.   

However, by some people’s estimation Roblox is both underestimated and misunderstood. 
 
“Roblox is perceived to be a monolithic game that everyone plays. The reality is there’s all these servers set up with all these different technical worlds built into them,” said Izad, the Underscore Talent co-founder. “All of these servers are communities where there are business opportunities.” 
 
Roblox not only allows players to create their own games or experiences within the game, it also facilitates creators’ ability to earn money by charging other users an internal currency known as Robux. In February, Roblox said, last year, it had nearly 3 million creators earn money and paid them about $540 million. Games and worlds like Brookhaven RP and Piggy, created on Roblox, have been visited billions of times.

The Chainsmokers Concert Experience in Roblox

As full of potential as Roblox is for companies and talent to engage with fans, UTA Head of Emerging Platforms Sarah Early said she advises proceeding with caution. “We find that the Roblox audience is generally very young,” said Early. “So you have to be thoughtful of that demographic.” 
 
Nearly a quarter of Roblox’s more than 50 million daily active users are under the age of 13, the company has said. 
 
Maybe for that reason, virtual music concerts have so far been one of the more popular ways for stars to interact with Roblox’s young audience. WME client Kane Brown recently held a concert in Roblox’s Walmart Land and Paramount’s MTV used the platform to help promote its Video Music Awards. The Chainsmokers and Lil Nas X have also staged virtual performances on Roblox. 

What’s next for Roblox? 
 
WME’s Lonczak imagines a not-too-distant future where the platform evolves into much more than supplying an additional space for showcasing traditional talent. It will become a breeding ground for a new generation of digital stars, she said. 
 
“If somebody creates a great experience, or virtual concert, with their own original music there’s a chance they can make their avatar famous,” said Lonczak. “This whole new concept of meta-celebrities and meta-stars, I’m sure we’ll start to see some meta-influencers come out of Roblox.”  

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

 Huobi Global will delist the U.S. dollar-pegged stablecoin HUSD on Oct. 28 and convert users’ assets to Tether (USDT).

“As part of our continuous efforts to promote the healthy development of the blockchain ecosystem, Huobi Global will be ceasing the HUSD trading service and delisting HUSD in compliance with Article 11 of Huobi Global Token Management Rules,” the exchange said.

Huobi said the delisting will start at 8:00 UTC on Oct. 28. At that time it will cease HUSD deposits and withdrawals and cancel any open orders related to the stablecoin. Meanwhile, the exchange will convert users’ HUSD to USDT at a 1:1 ratio, it said, noting that it plans to complete this conversion before Nov. 4. 

HUSD, a centralized stablecoin built on the Ethereum ERC-20 token standard, lost its dollar peg on Oct. 11 and fell as low as $0.90. The stablecoin, which has a market capitalization of nearly $187 million, is controlled and issued by Hong Kong-based Stable Universal despite sharing the same name as the exchange known as Huobi. 

Huobi Global made two key announcements in the days before HUSD lost its peg, although the extent to which they may have influenced the stablecoin’s loss of parity and ultimate delisting on the Huobi exchange remains unclear.

First, Huobi Global said on Oct. 8 that it would sell its majority stake in the company to Hong Kong-based About Capital Management. News publication Wu Blockchain reported that Tron founder Justin Sun was the “real” buyer behind Huobi Global’s stake sale, a claim that Sun denied in an exclusive interview with The Block. Sun said he is “only an advisor” to Huobi. 

Secondly, the exchange announced on Oct. 10 that it would delist 21 HUSD trading pairs the same day, only saying the move was part of its continuous efforts to offer customers a “better trading experience.” 

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

Quick Take

• Searching for Alpha is a series that summarizes under-the-radar protocols that The Block Research team finds interesting. 
• This week’s finding will look at Voyage Finance and NFTPerp.
• Disclaimer: The Block Research team has, is, and will be experimenting with the various protocols, projects, and applications mentioned in this series. The projects mentioned in our reports are not recommendations from our team and should not be misconstrued as investment advice. Many projects that appear in this series are highly experimental and, as such, will come with risks. Readers should evaluate their own risk tolerance before experimenting with these projects.

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A European Union pilot program will allow market participants to use stablecoins for trades and settlements before the legal framework for crypto is enforced in at least two years, EU Commissioner Rok Zvelc said.

The plan, known as the DLT Pilot Regime, allows players from both traditional and digital finance to experiment using tokenized securities within a regulated environment.

So-called e-money tokens, which are single fiat currency-denominated stablecoins, are defined in the EU’s comprehensive Markets in Crypto-Asset regulation, known as MiCA. Those rules will only come into application in 2024 at the earliest, but the pilot participants will already be able to start using e-money tokens in trading and settlements within the DLT pilot.

“This is not something we need to wait for the adoption of MiCA for and its entry into force, but we can already use it. It is not defined in the DLT Pilot Regime but it is defined in MiCA, so it can already be interpreted in this way,” said Zvelc, who is a commissioner on the digital finance unit. He spoke during an online webinar hosted by the European Commission.

The DLT pilot allows players from both traditional and digital finance to experiment using tokenized securities within a regulated environment. The project, set to roll out in March 2023, will inform EU policy on DLT use in capital markets in the future.

Participants in the DLT project will be exempt from targeted parts of financial service legislation, such as the Markets in Financial Instruments Directive and The Central Securities Depositories Regulation, as part of the blockchain experiment.

Financial newcomers who are not licensed under MiFID and the CSDR will be able to apply to the DLT pilot by receiving a specific permission from financial supervisors. This means that crypto exchanges and service providers will have access to the sandbox without the requirement of complying to broader EU financial obligations that traditional institutions must follow.

There are no confirmed participants yet, but financial organizations like BNY Mellon and Binance have expressed interest.

After three years of the project running, one the European financial watchdogs, European Securities and Markets Authority, will produce a report that will decide whether the project will be terminated or continued.

ESMA cleared the way for the DLT Pilot Regime in September, when the financial supervisor decided it would not amend the existing rules on data reporting and transparency for the project.

MiCA and the DLT Pilot Regime are both part of the EU’s Digital Finance Strategy dating from September 2020.

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

Martian, a crypto wallet for the recently launched Aptos blockchain, has closed a $3 million pre-seed round led by Race Capital. 

Other backers include FTX Ventures, Superscrypt, Jump Capital and Aptos itself, according to a company release. It didn’t give any information on Martian’s valuation.

Martian is a web3 wallet that helps users manage their crypto assets within the Aptos ecosystem. The startup formed out of the first Aptos hackathon earlier this year and was founded by Utkarsh Sinha and Siddharth Jain, who are both still in their final year of graduate school at Columbia University. 

The round was a combination of equity and a simple agreement for future tokens (SAFT), Sinha told The Block. 

What is Aptos?

Aptos is a new blockchain co-founded by Avery Ching and Mo Shaikh, both of whom previously worked on Meta’s Diem project. The blockchain launched on mainnet only last week alongside the public trading of its native token APT. It’s raised $350 million from venture investors just this year, including FTX, Andreessen Horowitz and Multicoin Capital. 

The chain uses Move, a programming language that builds on top of Rust — the language used on the Solana blockchain. The Move language is part of the reason Sinha and Jain were excited to develop on Aptos. 

“As a network, it has all the other characteristics that Solana can offer like high speed, transaction processing, low gas fees but Move is a great way for more and more developers to build in this ecosystem and make more composable to blockchain programs,” Sinha said. 

Making waves in the ecosystem

Martian is already making waves within the Aptos ecosystem, having secured partnerships with applications including Topaz, Souffl3 and Aptos Name Service. The wallet has had nearly 1 million total installs, according to data from the Google Chrome web store provided by the founders. 

Sinha said Martian is focused on user feedback as it competes with other Aptos wallets like Rise Wallet, which was founded by the team behind the Solflare wallet on Solana. 

“It’s very important for us to take user feedback and work on it,” Sinha said. “Most of our priorities on like product are based on the feedback that we receive. Our Discord server right now has more than 100,000 members and all of them are still adding feedback and were like hearing them out, we are making those changes.” 

“I think build a great community, ship fast, take user feedback as very important advice, these are a recipe for a great product,” he added. 

Another advantage is that Martian team work closely with the core Aptos engineering team, which means they can quickly ship products and features whenever a large change happens, Jain said. Martian has secured a grant from Aptos, he added. 

The funds from the raise will be used to accelerate the hiring process and develop new wallet features. Martian currently has a team of eight people. 

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

Senator Elizabeth Warren, D-Mass, is calling for U.S. consumer finance regulators to beef up their oversight of Zelle.

Specifically, Warren wants the Consumer Financial Protection Bureau to make banks pay more customers defrauded on Zelle, as the Massachusetts Democrat wrote in a letter to the CFPB.

The letter focuses on an investigation Warren’s office has been conducting into Zelle, a platform that many of the largest U.S. banks use to facilitate peer-to-peer payments among their account holders. 

Warren’s findings say the CFPB “must update and strengthen regulations governing the obligations of banks to repay customers who are defrauded on Zelle and other peer-to-peer payment platforms.” Warren was instrumental in creating the CFPB as part of the 2010 Dodd-Frank Act prior to her time in the Senate.

Zelle was the subject of a heated exchange between the Senate Banking Committee and the CEOs of several banks behind it in July. A core dispute is the nature of the frauds at play, with the banks saying they reimburse customers who did not make the payments from their accounts. Banks don’t reimburse customers who are themselves tricked into sending money. 

But the CFPB is under fire following a Fifth District Court ruling last week saying that its funding mechanism — direct from the Federal Reserve rather than standard appropriations — is unconstitutional. 

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

The developers of decentralized storage project Filecoin have launched a content delivery network called Saturn. The goal is to help the network meet content bandwidth for decentralized apps and make it cheaper to run Filecoin nodes. 

Content delivery networks make up a substantial portion of the internet helping websites quickly retrieve information. Specifically, Saturn is a series of interlinked servers that will help in pulling or retrieving content for decentralized apps. It complements the main data storage layer on Filecoin, said Protocol Labs, the development firm behind Filecoin, which started building it in the first half of 2022.

With the launch of its Saturn, the firm has not just provided a content delivery layer, it’s also attempted to lower the cost of being a contributor to Filecoin. Protocol Labs says it’s made the network more accessible to public contributors.

Up until now, the only way to contribute to the Filecoin network was to become a Storage Provider (SP), a participant who provides their excess storage space to others. However, becoming an SP requires access to significant amounts of storage capacity and can be expensive, meaning the barrier to entry is high for individuals. Storage providers have to meet a minimum of 10 terabytes (TB) in committed storage to join the Filecoin Network. 

On the other hand, running a Saturn CDN node needs just 1 terabyte (TB) of storage; it’s less expensive than running a Filecoin Storage Provider node. It will let more people contribute to the network bandwidth and earn the protocol’s native currency, which is also called filecoin, said Protocol Labs.

“The launch of Saturn, Filecoin’s content delivery network delivers on two key goals of Filecoin: fast, open access to humanity’s most important information and to let anyone, anywhere participate in Filecoin’s ecosystem,” said Filecoin Saturn Lead Ansgar Grunseid. “And with a lower barrier of entry for network participants and faster, more robust retrievals from IPFS and Filecoin, Saturn unlocks the next generation of Filecoin’s growth and impact.”

The Filecoin main data storage layer offers cheaper and censorship-resistant cloud storage with a capacity of 18.9 billion gigabytes (GB). It shares ideas from the InterPlanetary File System (IPFS), also developed by Protocol Labs, and allows users to rent unused hard drive space. 

All three products from Protocol Labs: Filecoin, Saturn and IPFS offer a more censorship-resistant alternative to centralized cloud services offered by Google or Amazon. Protocol Labs claims that hundreds of projects use Filecoin, including Fleek, Web3.Storage, PowerLoom, Secured Finance, Ocean Protocol, LivePeer, NFT.storage, Voodfy, among others.

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

LooksRare joined the growing list of NFT marketplaces opting to drop creator royalties, joining SudoSwap, X2Y2 and, most recently, Magic Eden.  

LooksRare said it will instead distribute a quarter of its protocol fee to creators in an attempt to find a middle ground in the running debate over royalties. The marketplace is now allocating 25% of its 2% protocol fee with creators, according to a statement. This results in an effective 0.5% royalty fee on trades for all collections, which is a lot lower than most were previously seeing. 

“With this change, LooksRare wants to buck the trend with our solution that actually enforces income for creators, while still remaining attractive to traders with an effectively zero-fee offering. It’s a way to turn all that zero-royalty volume into something that still benefits the creators,” said the pseudonymous LooksRare co-founder known as Guts.

Royalties are fees that are designed to be paid on every NFT trade and are typically sent to the creator of the collection at the point of sale. Depending on the success of a collection, they are a way for NFT creators to earn regular income. However, with royalties ranging from 2.5% to 10%, they can be a source of friction for NFT traders. 

The LooksRare changes will effect all users. The marketplace shares its protocol fee with stakers of its native LOOKS token. With a quarter of that fee going to creators, stakers will see their revenues drop. 

LooksRare is trying to mitigate the impact of this knock-on effect. It has rejiggered how the trading rewards will be handed out. Instead of splitting them 50:50 between buyers and sellers, it’s now giving 95% to sellers. LooksRare claims that this should account for the drop in revenue. 

While all the other changes are already live, the change to the trading rewards will take effect on Oct. 28 at 9:00 AM (UTC).

The marketplace has also changed how the listing rewards are calculated. These are rewards given to NFT holders putting their NFTs up for sale. The leaderboard will now be ranked by OpenSea volume — instead of LooksRare volume — in the preceding 24 hours. This is over fears that wash trading may increase with the removal of royalties.

NFT royalties are fading away

Since NFT royalties are not enforced on-chain, they are down to the whim of NFT marketplaces. While OpenSea, the dominant NFT marketplace on Ethereum, continues to support royalties for creators, other newer NFT marketplaces have pivoted away from doing so. This has seen these plucky marketplaces pick up greater volumes.

NFT marketplaces like X2Y2 and SudoSwap on Ethereum operate without creator royalties, and recently Solana’s dominant NFT marketplace Magic Eden followed suit. Magic Eden co-founder and COO Zhuoxun “Zedd” Yin likened the issue to a “prisoner’s dilemma.”

“We felt that in the absence of [a] technically enforceable solution at the protocol level, things would continue to trend basically toward optional royalties anyway,” Yin said at the time.

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

Former Goldman Sachs partner Adam Dell is finding that navigating the crypto bear market is a challenge as Domain Money struggles to find users and keep staff. 

Domain Money offered clients five portfolios with a minimum investment threshold between $100 and $500. The portfolios had a mix of crypto and stock exposure and charged a 1% annual management fee.

As of March, this year, Domain Money had just 398 accounts with around $400,000 in customer money, according to a filing seen by The Information.

According to a recent ADV filing, Domain Money stopped offering its managed portfolios in August and plans to pivot the business operations.

The firm said it had 15,000 users on a LinkedIn post in July. This figure more likely represents the number of people who have signed up, not necessarily the number who have linked their financial information to the app or had actively invested, a source told The Information.

Goldman Sachs acquired founder Adam Dell’s last project, Clarity Money, in 2018, which led him to work on Goldman’s move into main street banking. Clarity Money was eventually shuttered, with Marcus by Goldman Sachs assuming its business. 

Dell worked as a partner at the investment bank until 2021, when he left to start Domain Money, bringing a slew of Goldman employees with him. However, many of these employees who followed Dell have since left, according to The Information — 28 to be precise.

Of the 28 exits from the firm, 11 of those were employees that joined directly from Goldman when Dell left to set up his latest venture. Andrew Pesco, former head of investment management at Domain Money was one of them, and he returned to Goldman in August, according to his LinkedIn.

Domain Money’s launch coincided with a crash in crypto prices. Bitcoin and ether have tumbled over 50% since January, while the crypto market cap has more than halved from $2.31 trillion to $1.04 trillion today. 

Dell appeared on The Scoop in July, saying the firm would differentiate itself through quality portfolio managers. Domain Money brought teams from Goldman Sachs and Bridgewater to help construct and manage portfolios. However, it appears there wasn’t an appetite for Dell’s latest offering as the firm now looks to pivot the business model.

Domain Money did not immediately respond to a request for comment from The Block.

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

Blockchain nodes are getting more space in the cloud.

Google Cloud is opening up a blockchain node engine that will, the company says, streamline the process of setting up a brand new node, as well as the complications of hosting it on your own hardware. 

Google’s first supported blockchain is Ethereum, per the post.  “Blockchain Node Engine is a fully managed service, which can mean you don’t have to worry about availability.”

Such a service appeared to be in the offing when Google began assembling a web3-focused team earlier this year. At the time, it was reported that Google was eyeing the development of hosted services for blockchain developers. 

Earlier this month, Google began to natively support data for Ethereum wallet balances. 

© 2022 The Block Crypto, Inc. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.