Apr. 19, 2023
Dear, Sir/madam, Thank you for taking the time to read my comment. Section 3(a)(1) of the Exchange Act and Rule 3b-16 state that an exchange is any organization, association, or group of persons which constitutes, maintains, or provides a market place or facilities for bringing together purchasers and sellers of securities or for otherwise performing with respect to securities the functions commonly performed by a stock exchange as that term is generally understood. An organization, association, or group of persons that meets the criteria of existing Exchange Act Rule 3b-16(a), and Rule 3b-16(a), as proposed to be amended, and makes available for trading a security and a non-security would meet the definition of “exchange” notwithstanding the fact that the entity traded non-securities. For its securities activities, the organization, association, or group of person must register as a national securities exchange or comply with the conditions of Regulation ATS. I support the amended rule to regulate these "DeFi" systems and have them register as a national securities exchange or broker-dealer to comply with regulations. This rule can shutdown avenues currently being used to skirt around regulations. These benefits promote capital formation, competition, and market efficiencies. NS