DeFi Debrief: December 12

Week of December 8, 2025: DEF at BA Policy Summit; CFTC Updates; SEC Crypto Task Force Roundtable

DEF’s Amanda Tuminelli Speaks at Blockchain Association Policy Summit 

On December 8-9, 2025, Blockchain Association hosted its annual Policy Summit, featuring crypto discussions with key policymakers, regulators, and industry leaders. DEF’s Executive Director & Chief Legal Officer, Amanda Tuminelli, spoke on the “Rulemaking and the Road Ahead” panel alongside Jason Gottlieb, Judd Littleton, and DEF board member Jake Chervinsky as moderator.

The panel focused on the current and future regulatory rulemaking landscape. Now that the GENIUS Act has been enacted into law as the first comprehensive federal framework for payment stablecoins–a major milestone for digital asset policy–focus is turning to its regulatory implementation. Panelists discussed the path to compliance under GENIUS, including how regulators might translate the requirements for reserves, issuance, and oversight into workable rules for the industry, and the remaining questions around the treatment of existing issuers. Panelists also discussed the potential for clarity from the SEC, including a possible innovation exemption for crypto assets. 

Busy Week at the CFTC 

The Commodity Futures Trading Commission (CFTC) issued several important announcements, highlighting key developments in market and digital asset regulation. 

On December 8, 2025, CFTC Acting Chairman Caroline Pham announced the launch of a digital assets pilot program that will allow certain digital assets to be used as collateral in derivatives markets. Futures commission merchants (FCMs), derivatives clearing organizations (DCOs), and swap entities may now accept limited digital assets as margin, subject to enhanced monitoring, weekly reporting, and risk management requirements. For the first three months of the pilot program, eligible collateral is limited to BTC, ETH, and USDC. The announcement also included new guidance on tokenized collateral to clarify how tokenized assets may be evaluated under the existing CFTC regulatory framework. 

The CFTC Market Participants Division (MPD) simultaneously withdrew its 2020 staff advisory that imposed restrictions on FCMs’ ability to accept virtual currencies as collateral, noting that the advisory is no longer relevant given the enactment of the GENIUS Act. In parallel, MPD issued a no-action letter to Coinbase Financial Markets, a registered FCM, addressing segregation and capital requirements for FCMs that accept non-securities digital assets as customer margin collateral. While the no-action letter applies only to the specific circumstances it addresses, it effectively sets the ground rules for the pilot program and offers insight into how CFTC expects firms to manage risk, custody, valuation, and reporting for tokenized collateral. 

For a deep dive into no-action letters, check out DEF’s previous blog breaking down how they work and why they matter. 

On December 10, 2025, Acting Chairman Pham announced the first round of participants for the CFTC’s new CEO Innovation Council, which will engage in public discussions on market structure developments in derivatives markets such as tokenization, crypto assets, 24/7 trading, perpetual contracts, prediction markets and blockchain market infrastructure. So far the list of Council participants includes executives from crypto exchanges, prediction markets, and traditional futures exchanges, but the CFTC is continuing to review submissions for the council.

On December 11, 2025, Acting Chair Pham announced the withdrawal of outdated guidance related to actual delivery of digital assets. The guidance was issued in 2020 and sought to clarify the meaning of “actual delivery” for margined, leveraged or financed retail digital asset transactions. The announcement notes that the withdrawal is in line with recommendations made in the President’s Working Group on Digital Asset Markets report. 

On December 11, 2025, the House Agriculture Committee held a hearing entitled “CFTC Reauthorization: Stakeholder Perspectives.” Chairman GT Thompson (R-PA) opened the hearing by congratulating Michael Selig on his nomination to chair the CFTC and stated that he expects Selig to testify before the House Agriculture Committee “early next year.” 

Upcoming Crypto Task Force Roundtable

On December 15, 2025, the SEC Crypto Task Force will host a roundtable on financial surveillance and privacy, bringing together regulators and industry experts to discuss how privacy-preserving technologies can strengthen privacy and security in today’s financial landscape.

DeFi Dictionary

As debates around market structure continue, we approach the end of 2026 with a reminder: it is critical that we treat software providers differently than traditional intermediaries in all policy conversations. Here comes our word of this week: 

Notable and Quotable

“We can’t criminalize people who write code, for crying out loud.” — Senator Cory Booker, Blockchain Association Policy Summit, Dec. 9, 2025.