We (@fund_defi) submitted a letter in response to the SEC’s RFI asking for thoughts on "exchanges" and crypto ATSs. TL;DR: don't misclassify DeFi technology and devs that aren't actually performing "exchange" functions. We urge the Commission to: 1️⃣ Adopt a functional test for an exchange "facility” so only those actually performing exchange functions are in scope, and not disintermediated software, AMMs, smart contracts, or developers. 2️⃣ Avoid an overly broad reading of a “group of persons" constituting an "exchange." Where there’s no shared intent or control over exchange functions, developers/entities shouldn’t be treated as an exchange just because their software is used by one. Bottom line: DeFi tools that provide liquidity or run autonomously aren’t performing exchange functions and neither the tech nor its devs should be regulated as exchanges. Full letter: sec.gov/files/ctf-written-in…

Today, the @SECGov released new FAQs on the application of the federal securities laws to crypto assets. The guidance gives developers and builders greater room to build, develop, and decentralize blockchain networks and DeFi systems in the United States. Q2.3 makes clear that once a crypto system is functional, ongoing maintenance, upgrades, development funding, improvements, and efforts to grow network effects do not constitute “essential managerial efforts” under Howey. Q2.4 goes even further: once a functional crypto system has no central party, statements by the issuer relating to the system likely would not create a new investment contract because no person controls the system in a way that determines its success or failure. This is a MAJOR step forward for builders of blockchain networks and DeFi systems, and a huge validation of arguments talented lawyers have been making for years about decentralization, ongoing development, and the application of the securities laws to decentralized technology. Link to FAQ here: sec.gov/about/divisions-offi…

Exciting to see the @CFTC bring some much-needed clarity for software developers in digital asset markets. This relief recognizes the role passive software providers can play in the ecosystem and is a welcome step for developers building innovative tools. 👏

We @fund_DeFi had the great honor of advocating for DeFi developers and users in the lead up to today's vote on the Clarity Act. DEF's mission is to advocate for good policy for those working on and using decentralized technology, and we take that job seriously - and the work is not done. We are grateful to have had a seat at the table throughout the process, worked closely with members of Congress and their staff, collaborated with so many in the industry, and most of all, to have had the privilege of advocating for software developers who are innovating in ways we couldn't imagine a decade ago. We will continue showing up, pushing for reasonable, tech-neutral policies and supporting the builders creating what comes next. To the members and the staffers who took our calls and pushed for good policy when it was inconvenient to do so: thank you. Some of you fought for developers at moments when there was no reward in it. To everyone across the industry who worked on this alongside us, who helped us understand your work and how the tech functions, and who actually believe in this stuff, you know who you are and you know how we feel about you. Last, but most of all, to the @fund_DeFi team, you are the best team there is. Small but mighty. You worked around the clock to review legislative text from the perspective of protecting developers, most of whom you haven't even met yet. I'm proud to work with you @_ayanadow @glzavatone @jenn_rosenthal @mbernstein6395 @itstaliad

Today, @fund_defi and @SolanaInstitute submitted comments to @FinCENnews on its proposed GENIUS Act customer identification rules. Our main message: CIP obligations should not apply to DeFi, decentralized blockchain infrastructure, or peer-to-peer crypto users. The GENIUS Act should not be implemented in a way that imports the same problems (and unnecessary friction inherent in traditional financial intermediaries) onto decentralized, non-custodial systems. The final rule should preserve clear protections for self-custody, secondary-market activity, validators, protocols, and other non-custodial infrastructure. We will continue to push to ensure GENIUS Act implementation protects decentralized blockchain infrastructure and crypto users.

Thank you to Chairman @SECPaulSAtkins, Commissioner @HesterPeirce, and the SEC for today’s thoughtful proposal. It is encouraging to see the Commission recognize that blockchain networks can become more decentralized over time, and that this evolution matters under the federal securities laws. This is an important step toward a regulatory framework that better reflects how this technology actually works, and we look forward to future guidance on decentralized networks.

DEF’s Senior Counsel @_ayanadow is moderating a policy panel about the future of finance this week at Block Voices’ 2026 Thought Leadership Summit, featuring @KyleBligen from @TheDRC_ and NYS Assemblyman @clydevanel👇

The @GLFOP now supports the Clarity Act! Today's progress didn't happen by accident. It's the result of countless conversations, meaningful engagement, and real changes made to address law enforcement concerns while preserving innovation. Three titles, 25 provisions, numerous thoughtful conversations about how to address illicit finance. Thank you to the Senators, their staffs, and the White House for working together to move this forward.

Thank you to Senator @RonWyden for your continued advocacy for the BRCA! In a letter to Senate leadership, he says: "I write to urge you to ensure that any version of the Digital Asset Market Clarity Act (Clarity Act) that is brought to the Senate floor preserves Section 604 of the bill as passed out of the Senate Banking, Housing, and Urban Affairs Committee." The DEF team wholeheartedly agrees, and we appreciate Senator Wyden and his staff for their leadership on this important, bipartisan provision that protects software developers. A comprehensive market structure bill must include strong software developer protections.

Today, @fund_defi and @SolanaInstitute filed a joint response to @USTreasury 's proposed rule implementing the GENIUS Act’s AML and sanctions compliance framework for stablecoin issuers. Our message is simple: protect DeFi and p2p transactions on public blockchains.

"... we cannot erode more on developer protections if we really want to bring developers back onshore," says @RebeccaRettig1 on @CoinDesk's new show, The Policy Protocol. "If we want to real innovation, and real builders, and people feeling safe building onshore, we have to make sure that the bill that passes and gets signed by President Trump really does protect software developers."

Clarity Act Title III ("Responsible Innovation in Decentralized Finance") was added to the Clarity Act to address concerns related to illicit finance and digital assets. It did not exist in the September draft. It was specifically added in response to concerns raised by prosecutors/law enforcement, to provide even more tools than were already in Title II ("Protecting Against Illicit Finance"). Anyone saying this bill does not give enough tools or runway for law enforcement to go after bad actors should *actually read* read Title II or Title III.

Powerful statement from @SECPaulSAtkins today. In his remarks, the Chairman explains that "our existing framework" does not always organize "neatly" to today's onchain markets. AND, he commits to providing a future-proof framework to clarify how existing regulatory definitions apply to technologies spanning the decentralization spectrum. "But software applications today do not always organize themselves neatly along these categorical lines. A single protocol can execute a trade, manage collateral, route liquidity, execute trading strategies through vault structures, and settle the transaction—all within a unified, automated system, often within seconds." The DEF team, in particular, appreciates that Chair Atkins highlights that DeFi *is* unique and requires different treatment from TradFi: "As the Commission considers these policy initiatives, we should remember that onchain market structures today are often hybrid in nature, combining elements of what are often referred to as “traditional” and “decentralized” finance. We should clarify how the Commission views the spectrum of models that may implicate our statutes through notice and comment rulemaking, using our exemptive authorities where necessary and prudent, all with full participation from innovators, investors, and the public alike."

New op-ed from Democratic Sacramento District Attorney @ThienHoCA on why software developer protections are an essential component to the next era of financial innovation in the United States. More importantly, he explains that as a prosecutor, Section 1960 has been stretched beyond its intended scope to target developers of non-custodial, p2p software. He writes, "Neither the developers nor the software itself controls other people's funds or transfers funds on their behalf. Charging them under a statute built for traditional financial intermediaries is a mistake, because it is misinformed and misdirected." "This approach chills open-source innovation, pushing many U.S. developers offshore. This unfairly saddles some with a criminal conviction and erodes American technological leadership in an area of consequential financial innovation." That's why we need clear developer protections in crypto market structure legislation. coindesk.com/opinion/2026/05…

Completely Agree. DeFi technology should NEVER be subject to the BSA. The BSA is a broken and ineffective regime that is incompatible with decentralized systems. @fund_defi wrote about this in Feb 2025. The ineffectiveness of the BSA warrants a thoughtful discussion on future improvements. The problem with the BSA is nuanced but significant: (1) it is overly burdensome and costly, (2) it has demonstrated minimal success in achieving its key objectives through transaction reporting, review, and investigation, and (3) it creates harmful downstream effects, including arbitrary enforcement, prohibitive compliance costs, and centralization. The inefficiencies and burdens of the AML system highlight the challenges that would arise if DeFi were subjected to the framework. defieducationfund.org/upload…

The SEC took an important step on UIs - and now we’re asking them to lock it in. On April 13, 2026, the SEC published a staff statement with a thoughtful, practical approach for distinguishing non-custodial user interfaces from activities that constitute broker-dealer activity. DEF and 35 industry leaders are now requesting the SEC formalize the principles in the statement in notice-and-comment rulemaking, so we have durable regulatory clarity that lasts.

Walking & listening to @TechnicallyLgl, featuring DEF’s Senior Counsel @_ayanadow. Get to know one of our favorite lawyers, and how she thinks about: ➡️ correlations between crypto policy & playing tennis ➡️ why this is a Dodd-Frank moment for crypto lawyers ➡️ crypto as a tool for financial inclusion

Imagine writing multiple letters insisting tx-based comp is dispositive… And the SEC says it’s just one factor of the broker-dealer analysis. Tough day for the gatekeepers and the moat protectors. Good day for builders.

Thrilled to be part of a team that pairs deep @CFTC expertise with private-sector experience ranging from major law firms, @BlockchainAssn & @fund_defi.

Legacy market infrastructure is slow, expensive, and inaccessible. Moving onchain solves these problems. But capturing that opportunity depends on clear rules for the blockchain apps that enable investors to trade peer-to-peer, without rent-seeking middlemen. The @a16zcrypto and @fund_defi safe harbor proposal for DeFi apps would accomplish exactly that. Today, former SEC Chief Economist and Director of the Division of Economic and Risk Analysis Craig Lewis submitted an economic analysis of that proposal to the Commission. Though scoped to the proposal itself, Lewis' analysis speaks to something larger: the economic costs and benefits of tokenized securities broadly, and what blockchain technology could mean for the future of financial markets. His bottom line: there are real costs, but the overall economic case is compelling and the proposal offers a sound path forward.