The four-prong non-custodial carve-out — validators, compute providers, UI operators, protocol writers — is a direct legislative patch for the Storm conviction and the Samourai Wallet case, locking in that writing code isn't money transmission before DOJ charges another dev. Coinbase and Stripe pushing back on the stablecoin yield ban tracks: BUIDL and BENJI already pay 4%+ via tokenized MMFs, and banning USDC yield just cements that arbitrage while passive holders eat zero. Twelve-month SEC/CFTC/Treasury rulemaking window means even with late-April markup, permissible activity doesn't crystallize until 2027.

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