Andreessen Horowitz and the DeFi Education Fund submitted a proposal to the U.S. Securities and Exchange Commission in August, asking for a safe harbor that would exempt certain blockchain-based trading interfaces from broker registration requirements under the Securities Exchange Act of 1934.

The proposal was sent to SEC Commissioner Hester Peirce on August 13, 2025, according to the filing. It seeks a safe harbor specifically for certain applications delivered through websites or apps that let users interact with blockchains and smart contract protocols. The scope is broader than decentralized exchanges alone and includes interfaces tied to DeFi and NFT activity.

The core argument is that some apps function as technical infrastructure rather than traditional brokers. In the filing, a16z and the DeFi Education Fund argue that where an app enables self-directed user activity without taking custody or performing conventional order-taking or order-routing functions, it should not automatically trigger broker registration. They also say that linking to third-party services such as DEX protocols, displaying price comparisons, or identifying a better execution route should not by itself make an interface a broker.

The DeFi Education Fund separately outlined the kinds of apps it believes should qualify. Those applications should be non-custodial, self-operating, and permissionless, and should connect to blockchain networks and smart contract systems that have removed control-based trust dependencies through objective design features or have shown a good-faith intention to decentralize.

No formal SEC adoption, proposed rule, or approval tied to this specific submission was identified in the available materials. The proposal appears to be part of a broader policy push aimed at clarifying how U.S. securities rules apply to DeFi front ends, wallet interfaces, and aggregators, especially as the commission reopens debate over digital-asset market structure.

Why It Matters

This proposal goes to a central issue in U.S. crypto regulation: whether software interfaces that connect users to on-chain protocols should be treated like traditional financial intermediaries. That question affects how DeFi products can be offered in the U.S. and where compliance obligations fall across protocol developers, app operators, wallets, and aggregators.

It also matters because the request is framed around objective product features rather than branding. If regulators eventually adopt that approach, the industry could get a clearer framework for distinguishing neutral infrastructure from regulated brokerage activity. That would be significant for how decentralized trading and related blockchain applications are built and distributed to U.S. users.