How Crux Turned a 6-Month Regulatory Delay Into Their Biggest Competitive Advantage

How Crux Turned a 6-Month Regulatory Delay Into Their Biggest Competitive Advantage

Most founders panic when their market gets delayed. Allen Kramer built infrastructure.

In a recent episode of Category Visionaries, Allen Kramer, Co-Founder and COO of Crux, a sustainable finance platform, explained how his company incorporated in January 2023 to build for a market that legally couldn’t transact until June. The Inflation Reduction Act had created transferable tax credits as a new asset class. But the Treasury Department hadn’t released implementation guidance. Every potential buyer and seller was frozen, waiting.

Most founders would view this as disaster. Allen saw opportunity.

The Liminal Market State

When the Inflation Reduction Act passed in August 2022, it created something unprecedented: a legally defined market that couldn’t yet operate. Transferable tax credits existed on paper but not in practice.

“We incorporated the company January of 2023, but guidance hadn’t been released by the Treasury Department until June of last year,” Allen explains. The gap between law passing and implementation details created an unusual challenge. “No one in this market was transacting because it was that new and guidance hadn’t come out.”

This wasn’t a product development delay or a technical obstacle. The market itself was frozen at the regulatory level. Buyers who wanted to purchase credits couldn’t commit capital without knowing the rules. Sellers couldn’t price their credits without understanding risk frameworks and compliance requirements.

The typical founder response to market delays: pause, wait for clarity, then move fast when the market opens. Allen chose the opposite approach.

The Infrastructure Window

Allen recognized something most founders miss about regulatory delays: they create temporal moats. Everyone faces the same constraint. Nobody can transact. But not everyone uses that time the same way.

“It was this very unique moment in building, where we could lay a lot of foundation, do a lot of customer research upfront, start to build some of the infrastructure and foundations that we’d need,” Allen explains.

While the market remained frozen, Crux hired aggressively. They built product architecture. They conducted extensive customer research with potential buyers, sellers, and intermediaries who all knew opportunity was coming but couldn’t act yet. They established relationships with banks and tax advisors who would become critical distribution partners.

This wasn’t passive waiting. It was compressed infrastructure building without the pressure of immediate revenue needs.

The Competitive Timing Asymmetry

Here’s what matters: when Treasury released guidance in June 2024, every company entering the transferable tax credit market started from the same regulatory baseline. They all got the rules simultaneously. But they weren’t all at the same operational baseline.

Crux had six months of infrastructure already built. Product architecture: complete. Hire plan: executed. Customer research: done. Partnership conversations: advanced. Technical problems that would take competitors months to solve: already solved.

“The market really opened up over the course of mid to late Q three of last year into Q four, and from there, it’s just exploded,” Allen notes. The compressed timeline from market opening to rapid scaling only worked because Crux had already addressed the hard operational challenges during the pre-market period.

Competitors who waited for clarity faced a different reality: guidance dropped, the market opened, and they needed to simultaneously build product, hire team, conduct customer research, and transact revenue. Crux could focus entirely on transaction execution while competitors were still building foundations.

The Customer Research Advantage

The pre-market period enabled a specific type of customer research that becomes harder once markets start transacting. Allen and his team could talk to potential buyers and sellers who were highly motivated to understand the coming market but not yet committed to any platform.

These conversations revealed how different customer segments thought about risk assessment, pricing frameworks, and transaction preferences before anyone had established solutions. This research informed product decisions that would have been harder to validate once customers had already chosen platforms and developed usage patterns.

By the time the market opened, Crux understood customer needs across multiple personas: renewable energy developers, advanced manufacturers, Fortune 100 buyers, family offices, and financial intermediaries. That multi-persona understanding shaped their decision to build for the full transaction range rather than picking one segment.

The Strategic Hiring Timeline

Pre-market periods create unusual hiring advantages. Crux could recruit team members focused entirely on building rather than delivering. There’s no customer escalation pulling engineers off feature work. No urgent client request disrupting product roadmap. No sales pressure demanding features before they’re ready.

Allen brought back Emily Hughes from their previous company Mobilize as one of Crux’s early hires to lead growth. In a normal market launch, growth hires feel pressure to generate leads and pipeline immediately. In a pre-market environment, Emily could focus on building brand foundations, establishing content strategy, and developing market intelligence frameworks without immediate demand generation pressure.

“We were able to attract some of those early employees that worked for us before,” Allen notes about the repeat team members from Mobilize. These hiring decisions happened during the pre-market window when Crux could emphasize mission and opportunity rather than needing to show immediate traction metrics.

The Capital Raising Context

Fundraising during pre-market periods requires different investor positioning. Crux couldn’t show revenue or transaction volume. But they could demonstrate something potentially more valuable: deep understanding of a market that was about to explode and infrastructure ready to capitalize on it.

“Clay at lower Carbon had invested in our last company. Ian Samuels from new system Ventures had invested in our last company, Shamiq Dutta from Overture. But previously higher ground Labs had invested in our last company,” Allen explains about the repeat investors who participated in Crux’s seed round.

These investors already trusted Allen and his co-founder Alfred’s execution capability. That existing trust made it easier to raise capital for a market that wasn’t yet transacting. New investors like Andreessen Horowitz who led the Series A could evaluate Crux’s pre-market positioning and infrastructure readiness rather than needing to see proven revenue metrics.

Strategic investors from the renewable energy sector—”folks like Orsted or LS Power, people that are really large in this industry”—provided domain validation during the pre-market period. Their participation signaled to other potential customers and partners that Crux was building the right infrastructure for the coming market.

The Partnership Development Timeline

Allen’s intermediary-first strategy required partnership development that benefited enormously from the pre-market window. “I think a critical early decision was that we wanted to partner very closely with players like banks, tax advisors, major institutional players, that were going to be on the front lines of advising.”

Building these partnerships in a functioning market means competing for attention with immediate transaction opportunities. During the pre-market period, banks and advisors were preparing for the market opening but not yet serving clients. They needed to understand how transferable tax credits would work and what infrastructure would exist.

Crux could position as that infrastructure before anyone else had established solutions. These early partnership conversations shaped how intermediaries thought about the market and which platforms they’d recommend when transactions started flowing.

The Risk of Early Movement

Pre-market infrastructure building isn’t risk-free. Allen and Alfred incorporated Crux in January 2023 based on the Inflation Reduction Act passing in August 2022. But Treasury guidance could have taken longer than six months. Or it could have changed key assumptions about how the market would function.

“Once that passed and we started doing some research, it became pretty clear pretty quickly that this is where we wanted to build and really leverage marketplace experience, that we had Alfred’s background in policy and also in finance,” Allen explains. Alfred’s policy expertise from his Treasury Department background reduced some of this risk. But they were still building infrastructure for market rules that hadn’t been finalized.

The calculated bet: even if guidance took twelve months instead of six, infrastructure building during that period would still create competitive advantage versus waiting to start.

When Pre-Market Positioning Applies

Not every market delay creates this opportunity. The specific conditions that made Crux’s pre-market strategy work:

A legally defined market that couldn’t yet operate created clarity about what was coming without ability to transact. Regulatory rather than technical blockers meant no amount of customer money could speed up the timeline. Everyone faced the same constraint.

Clear line-of-sight to market opening. Treasury guidance wasn’t a question of if, but when. This created finite delay rather than indefinite uncertainty.

Large enough market opportunity to justify infrastructure investment during non-revenue period. Transferable tax credits represent roughly a third of the capital stack for renewable energy projects. The market size justified building before transacting.

The Compressed Growth Phase

The payoff appeared quickly once the market opened. “The market really opened up over the course of mid to late Q three of last year into Q four, and from there, it’s just exploded,” Allen notes.

That explosion only worked because Crux had already solved the problems that would constrain rapid scaling: product architecture, team in place, customer understanding, partnership relationships, and market intelligence frameworks.

Competitors entering post-guidance faced a different growth curve. They needed to build these foundations while trying to capture market share. Crux could focus entirely on transaction execution and market expansion.

The Principle Behind the Tactic

The deeper lesson: market delays create temporal moats when you use them for infrastructure building rather than passive waiting.

This applies beyond regulatory delays. Product dependencies, technical blockers, or partnership timelines that affect all players equally create windows for asymmetric preparation. The company that uses blocked time to build infrastructure gains operational advantage when constraints lift.

The key insight Allen demonstrates: time is only wasted if you spend it waiting. Crux spent their pre-market period building everything they’d need for rapid scaling. When the starting gun fired, they were already moving.

For founders facing market delays, the question becomes: Are you using this time to build infrastructure competitors will need to build later? Or are you waiting for constraints to lift before starting?