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Bullish and Gemini IPO docs use new GAAP rules to boost income

On August 21, 2025 by voice

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Crypto exchanges Gemini and Bullish recently filed IPO documents, and they weren’t pretty.

Despite the market for crypto IPOs being particularly hot in the wake of the blockbuster offering by Circle, these two filings reveal dismal profitability for even major incumbents of the industry.

Bullish priced its IPO at $37 per share and it seemed initially like a roaring success. Shares opened for trading above $95 and rallied to $118 within minutes.

Unfortunately, every day since its debut has been a disappointment. After a week of sobering decline, Bullish now trades below $64 — about half its peak value on the day of its debut.

Undeterred, Gemini filed its S-1 IPO form two days after Bullish started trading. Despite a polished slide deck boasting vanity metrics like $285 billion in lifetime trading volume by 1.5 million lifetime transacting users, the company buried its net income far below its colorful opener.

Like Bullish, Gemini utilized newly revised GAAP accounting policies to boost income figures.

On Bullish’s recent F-1, for example, its last two fiscal years would have been negative had it not availed itself of crypto lobbyists’ new allowance per FASB’s ASU 2023-08 for placing gains from simply holding digital assets on its income statement.

Claiming that non-recurring asset appreciation is somehow relevant to recurring income is counterintuitive. However, exchanges like Bullish and Gemini are happy to sell IPO shares using those flattering accounting updates.

Bullish and Gemini get a crypto boost on IPO filings

Gemini, for its part, lost $158.5 million last year despite availing itself of substantial “unrealized gains and losses from investment fair value adjustments” that it relabeled to an eminently vague, “Other Income (Expense).”

In particular, Gemini reported a net loss of $282.5 million for the first six months of 2025 despite offsetting even bigger losses “by realized and unrealized gains on crypto assets and receivable, crypto assets pledged as well as crypto assets received as revenue.”

Specifically, it admitted to boosting its still decidedly negative net loss for the first six months of 2025 with “realized and unrealized gain on crypto assets and receivable, crypto assets pledged” worth $37.8 million.

Using this same category in reporting results of operations for 2023 and 2024, Gemini posted $368.1 million and $253.8 million, worth 375% and 341% of its revenue during those years, respectively.

Read more: ANALYSIS: Does the Circle IPO value Tether at $316B?

In general, both Gemini and Bullish have taken advantage of new accounting rule changes led by crypto lobbyists to boost numbers on their IPO documents.

Despite the changes complying with GAAP rules, critics call the new practice misleading.

Andy Constan, for example, called Strategy’s use of capital gains from its bitcoin holdings in calculating earnings “completely, 100% fraudulent,” despite Lyn Alden’s immediate disagreement with that characterization.

What is indisputable is that using non-recurring capital gains to boost income figures is a brand new tool to make IPO numbers look better than ever.

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