Deeper review of the Amend Reg ATS release re "Communication Protocol System" (sooo not done). @HesterPeirce is right to signal its future ramifications for #digitalassets /1 @JSelway3 @ChrisGrobbel
Deep concerns re HOW #SEC can even apply exchange regulation to digital assets (e.g., Customer Protection Rule??), but TL. Square peg, round hole. IMHO, this release turns that peg into a block. /2
I agree w @lex_node that this expanded def'n of "Communication Protocol System" will be used in the SEC's push to regulate AMMs and defi generally as exchanges...with ambiguous terms permitting an expansive definition /3
FN 109 is esp. concerning: "a group of persons, who may each perform a part of the 3b-16 system, can together constitute, or maintain a market place or facilities for bringing together purchasers and sellers of securities together and meet the definition of an exchange" /4
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