a16z And DeFi Education Fund Ask SEC To Put DEXs Outside Exchange Registration

Andreessen Horowitz (a16z) and the DeFi Education Fund asked SEC Commissioner Hester Peirce to create a safe harbor that would establish a rebuttable presumption that decentralized exchange protocols and their front-ends are not "exchanges" under the Exchange Act. On the same day they sent that joint proposal, a16z submitted a separate letter proposing a registration regime for centralized crypto trading platforms modeled on the 1998 alternative trading system rules.

By AI Newsroom· Reviewed by Pranav, Founder & Editor-in-ChiefPublished about 2 hours agoUpdated about 2 hours ago0 views

Why It Matters

The requests seek to clarify how existing securities law applies to different types of crypto trading venues, a regulatory question that affects how decentralized protocols and centralized platforms operate and register with the SEC. Both letters were dated Sept. 14, just days before the agency issued an Innovation Exemption for tokenized stock venues, indicating timing tied to ongoing rulemaking activity.

Key Facts

Organizations: a16z (Andreessen Horowitz) and the DeFi Education Fund
Recipient: SEC Commissioner Hester Peirce
Request 1: Safe harbor creating a rebuttable presumption that decentralized exchange protocols and their front-ends are not exchanges under the Exchange Act
Request 2: a16z separately asked the SEC to build a registration regime for centralized crypto trading platforms modeled on 1998 alternative trading system rules
Date of letters: Both letters dated Sept. 14

Andreessen Horowitz (a16z) and the DeFi Education Fund jointly asked SEC Commissioner Hester Peirce to establish a safe harbor that would create a rebuttable presumption that decentralized exchange (DEX) protocols and their front-end interfaces are not "exchanges" under the Securities Exchange Act. The proposal aims to draw a regulatory distinction between decentralized protocol software and entities that operate trading venues.

In a separate filing the same day, a16z urged the SEC to design a registration regime for centralized crypto trading platforms patterned on the alternative trading system (ATS) framework established in 1998. That letter sought a clearer pathway for centralized venues to register and operate under a regime familiar to securities regulators and market participants.

Both letters are dated Sept. 14. The filings were submitted three days before the SEC issued an Innovation Exemption related to tokenized stock trading venues, placing the requests in the context of active agency work on crypto marketplace rules. The joint and individual submissions reflect industry efforts to secure tailored regulatory treatments for differing platform architectures.

The proposals would not automatically exempt any platform; the safe harbor as described would create a rebuttable presumption that could be challenged by regulators. The documents frame the requests as mechanisms to provide legal clarity about when a protocol or front-end should be treated as an exchange under existing securities law, and when a registration pathway modeled on historical ATS rules would better fit centralized crypto platforms.