The DeFi Education Fund, together with more than 30 crypto industry organizations, on April 21 submitted a joint letter to the U.S. Securities and Exchange Commission (SEC), urging the SEC to adopt a formal rulemaking process under the “notice-and-comment” framework, converting the current staff statements regarding decentralized tools into official rules with lasting effect.
Key demands of the joint letter
(Source: DeFi Education Fund)
According to the joint letter submitted by the DeFi Education Fund on April 21, the coalition asks the SEC, based on the existing staff statements, to adopt a principles-based framework and set clear, objective standards for how the definition of “broker” applies in decentralized markets.
The letter directly quotes: “Therefore, we hereby urge the Commission to adopt a rulemaking process under the ‘notice-and-comment’ framework, further refining the applicable rules based on the statement.”
The letter further adds: “Specifically, the Commission should consider adopting a principles-based framework to provide clear, objective standards on what activities fall within the scope of the ‘broker’ definition, and to further refine the standards mentioned in the statement.”
At the conclusion of the letter, the coalition calls on the SEC to establish a “durable and technically neutral” regulatory framework, and warns in the letter that current regulatory ambiguity will stifle blockchain innovation and reduce the efficiency with which investors enter the market.
Relevant regulatory framework: Dispute over the “broker” definition and the regulatory subject
According to the joint letter, the core of the dispute is the boundary of how the term “broker” in the Securities Exchange Act applies in decentralized markets. The coalition argues that infrastructure providers—such as validators, data service providers, and communications network providers—should be clearly distinguished in the regulatory sense from intermediary entities that actively participate in trade matching.
In the letter, the coalition emphasizes that the current staff guidance lacks the lasting force of formal rules. The SEC should provide long-term regulatory certainty to the industry through a formal rulemaking process and limit the scope for reinterpreting the relevant provisions in the future.
SEC Commissioner Peirce’s public stance
Based on the SEC Commissioner Hester Peirce’s public statement, she is calling for permanent reform of the “broker” rules to reflect the market structure realities of decentralized technology. Commissioner Peirce noted that the current traditional “broker” definition may lead to the misclassification of software providers and participants in blockchain infrastructure.
Frequently asked questions
What is the specific date of the DeFi Education Fund’s letter to the SEC, and how many organizations signed on?
According to the letter, the DeFi Education Fund (DeFi Education Fund) submitted a joint letter to the SEC on April 21, 2026. More than 30 organizations signed on, covering businesses and organizations in the crypto industry, while the remaining organizations signed as independent supporters.
What procedure does the letter ask the SEC to use to convert DeFi guidance into formal rules?
According to the joint letter, the coalition explicitly requires the SEC to adopt a formal rulemaking process under “notice-and-comment,” to replace the current statements that are only advisory in nature and lack lasting effect.
What is Commissioner Peirce’s public position on the DeFi regulatory framework?
According to Commissioner Peirce’s public statement, she supports permanent reform of the “broker” definition to better adapt to decentralized technology, and指出 that the current definition may lead to incorrect regulatory classifications of software providers and blockchain infrastructure providers.
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