CTF Written Submission

Solana Policy Institute

April 1, 2026
  • The letter argues that existing exchange and ATS regulations cannot be automatically applied to disintermediated protocols because these systems lack core intermediary functions such as custody, order‑book operation, discretion, or agency on behalf of users.
  • It urges the Commission to distinguish between true intermediaries and neutral software or protocol developers, emphasizing that misclassification would impose technologically impossible obligations and effectively prohibit DeFi activity in the U.S.
  • The submission advocates for a function‑based, technology‑neutral regulatory framework—mirroring the Commission’s historic approach to emerging technologies—that maintains investor protection without forcing decentralized systems into legacy market‑structure models.

Last Reviewed or Updated: April 1, 2026