DEF Submits Comments related to DeFi in Response to Senate Banking's Digital Asset Market Structure RFI

On August 1, 2025, the DeFi Education Fund (DEF) submitted our response to the Senate Banking Committee’s Digital Asset Market Structure Request for Information (RFI) and recently published discussion draft of the Responsible Financial Innovation Act of 2025 (RFIA). We focused on questions directly relevant to DeFi and protecting software developers.

We are honored to have some of the leading DeFi builders, investors & advocates join our submission:  a16z Crypto, Jito Labs, Jump Crypto, Paradigm, Multicoin Capital, Solana Policy Institute, Uniswap Foundation, Uniswap Labs, and Variant Fund.

As a refresher, on July 22, 2025, the Senate Banking Committee — led by Chairman Tim Scott (R-SC) and Senators Cynthia Lummis (R-WY), Bill Hagerty (R-TN), and Bernie Moreno (R-OH) — released draft market structure legislation to establish a regulatory framework for digital assets in the United States, titled the Responsible Financial Innovation Act (RFIA) of 2025. Alongside the discussion draft, the RFI asks for feedback on a wide range of questions focused on establishing a regulatory framework for digital assets in the United States.

We responded to the questions posed that are most critical to DeFi, and we lay out the following principles: 

• Market structure laws should remain technology-neutral;

• DeFi developers and technology should be protected from inappropriate regulation meant for intermediaries; 

• Congress should define criteria to assess “Control” over digital networks; 

• Self-Custody protections for all US persons is essential; 

• Legislation should address illicit finance but not unfairly burden DeFi innovation, and should maintain consumer protections and privacy rights; and 

• Congress should include federal preemption for developer protections.

As we write: “With thoughtful market structure legislation, the United States is poised to establish itself as a global leader in digital asset markets and innovation….A dynamic, forward-looking, and flexible regulatory framework will ensure that builders of decentralized technology can thrive in the United States.” 

Additionally, the Senate’s market structure legislation should should include strong protections for blockchain developers and developers of non-custodial software in addition to including the bipartisan Blockchain Regulatory Certainty Act and explicit, affirmative, and enforceable self-custody protections like Senator Budd and Senator Lee’s Keep Your Coins Act. 

DeFi deserves the opportunity to flourish in the United States. We believe builders should have the clarity and freedom to solve the problems in today’s financial system, and DEF exists to promote and protect these freedoms.

We very much appreciate Senate Banking Leadership and their dedicated staff’s time and  attention to these critical issues. 

Be sure to read our submission at the link.