Our comments to financial regulators
In October 2026 our co-founder Sushant Kumar filed formal comments on four of the rules being written for crypto markets in the US and UK, drawing on what we see running market making and market surveillance for token issuers. Each letter discloses our commercial interest in the markets those rules cover. 2 consultations are still open for comment.
The recommendations and the evidence behind them are set out in What should crypto market rules require?
Filings
- SEC · File No. S7-2026-27 · filed 2026-10Proposed Regulation Crypto Assets
A proposed rule, whose Rule 103 asks issuers to disclose total supply, allocations, lockups, vesting and who controls minting, upgrades and pausing. We recommended that issuers identify the addresses or contracts holding each allocation category and the addresses holding privileged roles, so a stated vesting schedule can be checked by someone outside the issuer.
- SEC · File No. 4-927 · filed 2026-10Innovation Exemption order for tokenized securities venues
A temporary conditional exemptive order the SEC describes as a bridge to rulemaking. We recommended that venues publish the gap between the last pool price before the primary market opens and the opening price, describe how they price pools while the underlying is closed, and that liquidity providers be assessed against a gap at the reopen.
- CFTC · RIN 3038-AF80 · filed 2026-10 · open until 14 December 2026Advance Notice of Proposed Rulemaking on Regulation Crypto Asset Transactions and Markets
An advance notice of proposed rulemaking, open for comment until 14 December 2026. We recommended that surveillance test order book depth and trade quality rather than volume alone, that venues publish a periodic depth measure, and that any compensation linked to traded volume be disclosed.
- FCA · GC26/7 · filed 2026-10 · open until 18 November 2026Guidance consultation on decentralised finance
A guidance consultation on decentralised finance, open until 18 November 2026. Our response covered liquidity provider concentration, so buyers can see when a few linked wallets supply most of a pool, and detection of wash trading between wallets controlled by the same party.
The FCA does not publish individual responses; this links to the consultation.