😵‍💫 Certain uncertainty

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I’m back! Albeit slightly sunburned. 

Bullish seems to be in vogue, if we’re going off of last night’s pricing, at least. The company, which is set to IPO later today, priced at $37 a share last night, which is slightly higher than the range it sought ($32 to $33). 

All in all, it’s looking like Bullish will raise roughly $1.1 billion from selling 30 million shares of BLSH. 

What remains to be seen is just how much actual demand there is for this IPO this morning. Can it follow in the footsteps of Circle or even eToro? 

Time will tell, but this is a good demand gauge.

🛳️ Safe harbors

A16z and the DeFi Education Fund are asking the SEC for a safe harbor for blockchain technology. Simply put, this means that projects wouldn’t have to pursue broker registration for DeFi apps. 

“While decentralized blockchain systems underlying apps are clearly excluded from the SEC’s broker-dealer registration regimes, apps face regulatory uncertainty because they are typically developed and maintained by centralized actors. The SEC has previously taken the position — through enforcement actions and Wells notices — that developers of apps could be deemed brokers if they enabled users to transact in securities,” a16z wrote in a blog post this morning. 

In order for an app to qualify, a16z and DEF proposed four criteria: Underlying protocols have to be decentralized, it has to be non-custodial, there can’t be investment recommendations, and no discretion. 

“The guiding principle of the safe harbor is that only those Apps which do not engenderthe risks that the Exchange Act’s broker-dealer regulatory regime was designed to address should be eligible; in such cases, registration as a broker under the Exchange Act is unwarranted and inappropriate,” the two said in their official proposal to the SEC.

So, all in all, they have to be credibly neutral and permissionless. Makes sense, right? 

Both DEF and a16z have made it pretty clear that they’re looking out for projects in crypto. Heck, if you missed it earlier this week, a16z’s Miles Jenning and Eddy Lazzarin even went on the Empire podcast to discuss safely launching tokens. 

“Developers shouldn’t have to guess whether building public, neutral, and non-custodial software exposes them to the risk of being treated like financial intermediaries,” a16z said. 

The push comes roughly a week after Tornado Cash’s Roman Storm was found guilty of conspiracy to operate an unlicensed money transmitter business by a jury in a trial that’s left all of us wondering about potential implications. This push from a16z and DEF would help to clear some of the current murkiness. 

“This proposal aims to be flexible to account for the ever-evolving nature of early-stage tech development and is grounded in the understanding that most apps are fundamentally non-custodial, passive software tools that allow users to interact directly with public, decentralized network and protocol infrastructure — and, therefore, should not be subject to broker-dealer registration requirements.” DEF’s Amanda Tuminelli said. 

Despite the fact that it’s very clearly a new era at the SEC, there’s work to be done to allow projects and developers in the space to continue to innovate safely. 

Now, to see how the SEC plans to approach this topic.

Brought to you by:

Mantle is building the blockchain for banking — a groundbreaking new category that bridges TradFi and Web3.

To help drive this vision forward, Mantle has recently welcomed Helen Liu, co-CEO of Bybit, and Emily Bao, head of spot trading, to its advisory board.

Known for their leadership in global scaling, compliance, and DeFi innovation, their addition signals a major step in Mantle’s mission to build an institutional-grade on-chain ecosystem.

• Pantera said it invested over $300 million into Digital Asset Treasury companies in a letter explaining why it’s bullish on the value creation of said firms. 

• Paradigm’s Matt Huang is taking on a new role: CEO of Stripe’s L1, Tempo. 

• Closing a chapter in crypto history, Terraform’s Do Kwon pled guilty to conspiracy and wire fraud.

It’s the summer of DATs and the party is going strong. 

But when October rolls around, everyone will be looking to DAS: London to hear from these meta-defining voices on where things stand and where they’re headed.

Get your ticket today with promo code: EMPIRENL

📅 October 13-15 | London