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Sam - appreciate how open you have been to feedback and revising your post - but I am concerned you have missed or misunderstood one of the most important pieces of the feedback:
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5) None of this works if you need active permission to do everything: commerce grinds to a halt. If you show up at 7-11 to buy a bagel, and next thing you know you’re pulling out a passport and social security number and taking selfies, something’s gone wrong.
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From your revised blog: “If you host a website aimed at facilitating and encouraging US retail to connect to and trade on a DEX, this may end up falling under something like a broker-dealer/FCM/etc. You may also potentially have KYC obligations…
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…To be clear, this is separate from generalized tooling for on-chain parsing and interfacing, e.g. etherscan.io” This is an improvement but you also seem to be missing the whole point that a DeFi interface and etherscan are doing the same thing!
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If you agree something like etherscan should not require a license or kyc, then how can you still suggest an interface which does the same activity should require license/kyc? What is regulated needs to be specific activity, not just presenting it in a different way.
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I fear you missing this point is a grave error and hope you will consider revising your post such that anything that simply passes information to and from a protocol/contract should not require onerous burdens. A BD takes custody of funds, DeFi interfaces do not.
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Thanks for the reply ! My humble suggestion is that you can draw the line quite clearly like this: (1) those that take custody of funds as an intermediary can arguably be the subject of regs (2) those that do not take custody, should not be the subject of regs
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This allows those that are building free and open self-custodial interfaces to build tools that simply pass data without needing 6-7 figure compliance teams. Yet can still allow to regulate those who build products that take custody (which is fairly much closer to a BD).