Andreessen Horowitz, DeFi Education Fund ask SEC to exempt DEXs from registration

Andreessen Horowitz and the DeFi Education Fund have fired off a joint letter to SEC Commissioner Hester Peirce, making the case that certain decentralized exchanges shouldn’t have to register as traditional securities exchanges. The September 14 submission lays out a detailed framework for what they’re calling a “safe harbor” for qualifying DEX protocols and the apps built on top of them. The core argument is straightforward: protocols that don’t custody user funds, execute trades automatically, and let anyone participate without gatekeepers aren’t really doing the same thing as the New York Stock Exchange. Regulating them identically, the letter suggests, creates a mismatch between rules designed for centralized intermediaries and software that operates more like public infrastructure. What the safe harbor would actually look like The proposed framework rests on four criteria that a DEX protocol must satisfy to qualify for the exemption. First, the protocol must be non-custodial, meaning no single party holds or controls user assets during the trading process. Second, trade execution must be automated rather than dependent on human discretion. Third, access must be permissionless...