I just reviewed the update recently issued by the SEC’s Division of Trading and Markets, and there are several points that could change the game for crypto exchanges and operators. Although these are not new rules, the agency is being quite clear about what it permits in the digital asset space.



The most interesting part is this: the SEC no longer requires that security tokens be converted into U.S. dollars in order to be traded against Bitcoin or other cryptoassets. Basically, a security token can trade directly against Bitcoin without passing through fiat currency. That simplifies the trading flow quite a bit and opens up possibilities that were previously in a gray area.

As for stablecoins, broker-dealers can now treat them as easily tradable with a 2% discount when calculating net capital under Rule 15c3-1. This gives more flexibility to firms that handle significant volumes of their own stablecoins. In addition, the SEC says that a broker-dealer can combine custody, brokerage, and clearing functions at the same time, as long as each one independently complies with securities laws.

What I think is important is that the SEC also clarified the issue of cryptocurrency ETPs. Under circumstances similar to those for commodity-based products, participants can trade shares of cryptocurrency ETPs if they are listed on a national exchange and avoid conduct that violates Rule M outside of permitted distributions.

For exchanges and alternative trading systems, this means there is more room for complex structures. ATSs can facilitate crypto trading pairs where one is a security token and the other is not. But regulatory obligations don’t go away: recordkeeping, reporting, compliance with ATS regulations—everything still applies.

What I see is the SEC trying to adapt the existing regulatory framework to the realities of today’s crypto market without rewriting the rules. For serious exchanges and operators, this is clarity. For the broader market, it means the institutional crypto space is likely to grow. If you’re closely tracking what’s happening with regulation, this is an important development worth understanding.
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