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  3. H.R. 3633

H.R. 3633

2 articles

Thought Leadership

The DeFi Decentralization Test Under CLARITY: A Mechanics Guide to Section 309's Control-Surface Analysis

Section 309 protects specified DeFi activities—but the exemption is activity-based, not token-based, and protocols claiming it must survive a seven-control-surface verification their counsel are mostly not building.

May 20, 2026 · 49 min readRead More →
Regulatory Alert

The CLARITY Act Exchange Registration Roadmap: A 180-Day Compliance Calendar for Centralized Exchanges, Brokers, and Dealers

With H.R. 3633 awaiting a Senate cloture vote set for September 15, 2026, U.S. exchanges face two registrations, not one—and a 90-day compliance clock that starts the moment the CFTC adopts its expedited-registration process, after which operating unregistered is barred. Here is the operational calendar.

May 20, 2026 · 47 min readRead More →
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