DeFi Education Fund and 35 Co-Signatories Petition SEC for Formal Guidance on DeFi Interfaces

The DeFi Education Fund and 35 co-signatories including a16z crypto, Uniswap, Chainlink, Paradigm, and Solana Policy Institute petitioned the SEC to convert its April 13 staff guidance on DeFi interfaces into formal rulemaking. The April 13 guidance exempts certain crypto trading interface operators from broker-dealer registration if users control their own funds and allows these operators to receive transaction-based compensation. The petition seeks to prevent the guidance from being withdrawn after five years or reversed by a future commission, warning that regulatory ambiguity could hinder blockchain development and reduce investor market access. Meanwhile, Ethereum developer Tom Lehman proposed EIP-8182 to embed native private transfers into Ethereum's protocol, which privacy advocates argue would make it harder for regulators to impose broker-dealer requirements on wallets offering privacy features.

DeFi Industry Petition for Formal SEC Rulemaking

• ▪The co-signatories of the DeFi Education Fund petition include a16z crypto, Aptos Labs, Uniswap, Chainlink, Paradigm, Solana Policy Institute, and Phantom.
• ▪The DeFi Education Fund and co-signatories are asking the Atkins SEC to formalize the April 13 guidance through rulemaking so it cannot be undone by a future commission with different policy priorities.
• ▪The DeFi Education Fund and 35 co-signatories petitioned the Securities and Exchange Commission to convert recent staff guidance on DeFi interfaces into formal notice-and-comment rulemaking.
• ▪The Securities and Exchange Commission's April 13 staff guidance on DeFi interfaces is an interim statement that will be considered withdrawn after five years unless the Commission states otherwise or makes it a rule.
• ▪The DeFi Education Fund petition signatories cautioned that regulatory ambiguity could become a drag on blockchain development and reduce market access for investors.

SEC's April Guidance on DeFi Interface Operators

• ▪The Securities and Exchange Commission's April 13 exemption covers operators of front-end interfaces connecting to DeFi protocols through which users control their own funds.
• ▪The Securities and Exchange Commission's April 13 guidance exempts certain crypto trading interface operators from registering as broker-dealers.
• ▪The Securities and Exchange Commission's Division of Trading and Markets issued a staff statement on April 13 regarding DeFi interface operators.
• ▪The Securities and Exchange Commission's April 13 guidance permits covered UI providers to receive transaction-based compensation from users without having to register as broker-dealers.

Ethereum's Privacy Proposal and Regulatory Implications

• ▪Ethereum co-founder Vitalik Buterin proposed in April 2025 that wallets should integrate privacy tools like Railgun so users could manage shielded balances without adding third-party tools.
• ▪The EIP-8182 proposal calls for native private transfers to be embedded into the Ethereum protocol.
• ▪The EIP-8182 proposal would add a shared shielded pool directly into Ethereum as a system contract with a ZK proof-verification precompile.
• ▪The EIP-8182 shielded pool would evolve through Ethereum's hard-fork process.
• ▪The shielded pool proposed in EIP-8182 would carry no admin key, no governance token, and no on-chain upgrade mechanism.
• ▪Ethereum developer Tom Lehman published a draft proposal called EIP-8182 on X.

Perspective of DeFi Education Fund and petition co-signatories

• ▪The DeFi Education Fund and co-signatories believe regulatory ambiguity could reduce market access for investors.
• ▪The DeFi Education Fund and co-signatories seek to prevent a future SEC commission with different policy priorities from undoing the April 13 guidance.
• ▪The DeFi Education Fund and co-signatories view regulatory ambiguity as a potential drag on blockchain development.

Perspective of Privacy advocates in the Ethereum ecosystem

• ▪Privacy advocates believe a shielded pool built into Ethereum would make it harder for future regulators to draw broker-dealer lines around front-end wallets offering private sends.
• ▪Privacy advocates propose that the EIP-8182 shielded pool should carry no admin key, no governance token, and no on-chain upgrade mechanism to ensure decentralization.

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