Key Takeaways:
Peirce questioned whether securities rules should cover blockchains, validators, developers, and neutral software.Regulators could focus more on custody, control, and discretion than infrastructure alone.Builders may face pressure to improve audits, key management, disclosures, and security safeguards.The SEC’s rulebook relies heavily on intermediaries, according to Peirce. That structure creates pressure to find brokers, dealers, exchanges, and custodians in systems built to reduce reliance on them.
How DeFi, Onchain CeFi, and User Interfaces Face Different RisksHer framework focuses on whether a participant controls assets, exercises discretion, or performs functions traditionally handled by securities intermediaries.
Peirce said:
The speech also urged builders to solve risks before regulators intervene. Peirce pointed to stronger audits, better key management, safeguards against hacks, and clearer disclosures about decentralization trade-offs. She also defended users’ ability to transact without intermediaries. Shared software use alone should not create an exchange registration duty when nobody controls the system.
















