SEC Commissioner Peirce States No-Action Exemption Not Needed for Unlicensed Smart Contract Peer-to-Peer Trading

SEC Commissioner Hester Peirce stated that investors using intermediaries for peer-to-peer trading with unlicensed smart contracts do not require a no-action exemption. This innovative exemption is unrelated to decentralized finance, as truly decentralized systems driven by automated software do not involve the fundamental concerns of securities regulation. Peirce pointed out that the commission will not presume that entities relying on this exemption constitute exchanges or dealers, and will not make regulatory conclusions before observing usage patterns. She also mentioned that the commission is open to other on-chain trading models, some of which may not require exemptions if they meet the current requirements of the Securities Exchange Act.

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