Yesterday,
@Uniswap filed our comment on the SEC’s proposed Reg Crypto Assets. The Reg is a good first step that gets a lot right, but it needs tailored fixes to work in practice.
Chief among these: crypto assets need an explicit ability to trade in the secondary market.
As an example, we profiled our Continuous Clearing Auction (CCA) to show what an optimal market structure for these assets looks like. CCA is immutable, open-source code that runs a uniform-price token sale block by block. Eligibility checks can be built into the auction, and upon close, a Uniswap v4 pool is automatically seeded at the clearing price.
Our asks to the
@SECGov are straightforward: let the covered asset trade as a non-security during the disclosure period, affirm that non-custodial interfaces and protocols are not brokers or exchanges, and give the market a control-based test for decentralization that can be verified onchain.
Our full letter:
drive.google.com/file/d/1u8h…