Apr. 22, 2023
April 22, 2023 I am writing in support of the proposal to approve DeFi protocols as an ATS under the new Rule 3b-16(a) Systems. As stated in the Commission's Reopening Release, such systems may use distributed ledger or blockchain technology and perform a market place function similar to that of an exchange. These systems allow participants to discover prices, find liquidity, locate counterparties, and agree upon terms of a trade for securities, just like traditional exchanges or ATSs. I firmly believe that decentralized finance or \"DeFi\" trading systems have great potential to benefit the financial industry. The exchange regulatory framework would provide transparency, fair and orderly markets, and investor protections that apply to today's registered exchanges or ATSs, promoting capital formation, competition, and market efficiencies. As an organization, association, or group of persons that constitutes, maintains, or provides a market place or facilities for bringing together purchasers and sellers of crypto asset securities or performs with respect to crypto asset securities the functions commonly performed by a stock exchange, these systems should be considered exchanges under section 3(a)(1) of the Exchange Act and be required to register as a national securities exchange or comply with the conditions of Regulation ATS. Therefore, I urge the Securities and Exchange Commission to approve DeFi protocols as an ATS under the new Rule 3b-16(a) Systems, and support the continued growth and development of this innovative technology in the financial industry. Thank you for your consideration.