The two groups submitted a joint proposal to Commissioner Hester Peirce for a safe harbor that would create a rebuttable presumption that decentralized exchange protocols and their front-ends are not exchanges under the Exchange Act. a16z filed a second letter the same day asking the SEC to build a registration regime for centralized crypto trading platforms modeled on the 1998 alternative trading system rules. Both letters are dated Sept. 14, three days before the SEC issued its Innovation Exemption for tokenized stock venues.
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