CTF Written Submission

Re: Tokenized U.S. Equity Securities & DeFi Trading Protocols

Dec. 31, 2025
  • The SEC should apply existing statutory definitions of “exchange,” “broker,” and “dealer” to DeFi participants and assess compliance under the Securities Exchange Act of 1934.
  • The SEC lacks authority and policy basis to grant broad exemptive relief from these definitions, as doing so would undermine investor protections and market resiliency measures.
  • Instead of disapplying the regulatory framework, the SEC should conduct rule-by-rule analysis and address impediments through notice-and-comment rulemaking to preserve investor protections.

Last Reviewed or Updated: Jan. 5, 2026