1/ Big news: phantom has received first-of-its-kind no action relief from the CFTC. We can now connect users to regulated derivatives markets and event contracts without registering as an introducing broker.
1/ We've been waiting for this. The SEC proposed "Regulation Crypto Assets," which relates to token offerings. If you ship token products, this is the framework that's been missing. A few thoughts from the product counsel perspective.
2/ What jumps out for builders: two exemption tiers ($5M/4yr "startup," $75M/yr "fundraising"), a safe harbor from "investment contract" status, AND airdrops and network rewards written directly into the startup exemption. Disclosure is principles-based.
Great thread + graphic larryflorio on Hester's statement regarding crypto vaults/onchain lending, which is informative not only for creators or curators, but also for front-end devs providing access to these products. Key point: discretion matters.
Clarity passing out of committee is a huge moment for finance. Thank you to the committee staff who worked (and will continue to work) tirelessly to get this over the finish line. And thank you to BlockchainAssn fund_defi crypto_council for serving as key industry voices 🙏
1/ Today phantom filed a comment letter with the USOCC on its proposed rulemaking implementing the GENIUS Act — specifically taking issue with a provision that we think goes further than Congress intended on stablecoin yield. 🧵
2/ The GENIUS Act prohibits permitted payment stablecoin issuers (PPSIs) from paying yield to holders. Makes sense — it's designed to prevent stablecoins from functioning as uninsured deposit products.
Always love joining thinkingcrypto on his podcast! This time, my first as a member of phantom’s legal team, we chatted about our CFTC no action letter and what’s on the horizon.
Thanks, Tony!
Extremely well thought out paper that begins a much-needed conversation. Delving into why systems that don’t depend on intermediaries fundamentally cannot be regulated in the same way given that our current laws depend on the existence of an intermediary.
👏👏👏
2/ We support FinCEN's aim to combat illicit finance and our input is geared toward helping this effort.
Bottom line: the Proposal's definition of “CVC mixing” is FAR too broad and does not provide sufficient evidence backing up such a broad definition.