DEF’s June Recap

Here’s what the DeFi Education Fund (DEF) has been up to in June 2024. If you have any questions or would like to learn more about a specific activity, please do not hesitate to reach out at contact@defieducationfund.org.

Hosting First Annual DEF “State of the Union”

On June 11, DEF hosted our first ever “State of the Union” via an X space. The event took stock of where things were on DeFi policy in the US, including how things developed in the last few years and the outstanding major legislative, regulatory, and legal issues. We also discussed how the community can engage with us to help make DeFi and crypto thrive.

DEF will continue to host “State of the Union” events, so please stay tuned for updates for round two. 

Listen to part one of the event here and part two here.

Submitting Another Comment on the IRS’s Proposed “Broker” Rulemaking

On June 21, DEF submitted a comment letter arguing the IRS's proposed broker rule violates the Paperwork Reduction Act. This comment letter follows our first letter on the proposed rulemaking from November 2023. 

In this letter, we make the following arguments: 

• The proposed regulations’ definitions for “broker” and “digital asset middlemen” are not clear, coherent, and unambiguous, preventing the public from gauging whether or not they are required to comply with the proposed collection requirements. 

• The proposed collection would impose an undue burden on covered persons involved with DeFi by failing to both minimize the burdens and establish differing compliance or reporting requirements that take into account the resources available to those who are to respond. 

• The IRS fails to efficiently and effectively increase taxpayer compliance with the proposed collection, leading to unnecessary burdens for both taxpayers and the government.

Be sure to check out the full comment letter here. 

Discussing the Perils of the SEC’s Consolidated Audit Trail 

In an op-ed appearing in CoinDesk, DEF’s Amanda Tuminelli, joined by the Blockchain Association’s Marisa Coppel, discussed the SEC’s Consolidated Audit Trail (“CAT”), focusing on how the new program will impact crypto and why it represents another step toward making "massive unchecked government surveillance a reality."

The two write that not only will “the CAT will be the largest database of securities transactions ever built,” but that “for digital asset market participants, this information could end up including transaction identifiers and wallet addresses, giving those with access to the database insight into users’ forward- and backward-looking transaction information for all time.”

You can read the entire op-ed here. 

June Financial Disclosures

As in May 2024, we are continuing to share a more detailed look into our financial disclosures. You can find the June 2024 breakdown below. If you would like to look at our 2024 financial breakdowns, please click here. 

Donations Received	$101
Grants
Lobbyists	$40,000
Public Relations	$16,714
Policy Litigation
Marketing
Merchandise	$7,467
Operating Expense	$7,683
Payroll and Associated Taxes	$127,130
Professional Fees	$125
Accounting	$9,410
Legal	$2,680
Other Consultants	$8,222
Transacting Fees	$2,520
Insurance	$4,647
Tax & Licenses	$6
Other Overhead	$19,660

May Media

Op-Eds & Journals

• CoinDesk: Crypto’s Latest Privacy Battle

• Authored by Amanda Tuminelli and Marisa Coppel 

Print/Online

• CoinDesk: Crypto Insiders Hope for Possible Mention in Biden-Trump Debate
  

•  "We appreciate that candidates recognize the importance of not only debating how to regulate digital assets but also how to create responsible regulation that does not stifle innovation in the United States," said a spokesperson for the DeFi Education Fund.

• The Block: US Supreme Court ruling to overturn Chevron gives crypto industry a win, sources say
  

•  The Supreme Court's decision gives the crypto industry an advantage, said Amanda Tuminelli, chief legal officer at the DeFi Education Fund…"This ruling means that executive agencies, like the SEC and CFTC, will need to be more cautious in extending their regulatory reach without clear statutory authorization, especially in novel and rapidly evolving fields like crypto and AI," Tuminelli said in an emailed statement to The Block.

• Blockworks: Chevron doctrine is Chevr-OFF
  

• “​​In the absence of specific legislation granting and clearly outlining regulatory authority over crypto, federal regulators are attempting to adapt their existing statutory authorities to cover crypto-related activities,” crypto advocacy group The DeFi Education Fund said Friday. “This approach is problematic because these authorities are ill-suited for the task, their application is unclear, and their authority is questionable.”

• Blockchain Tipsheet: Tips for June 11, 2024
  

• DeFi Education Fund's Max Bernstein tells blockchain tipsheet that much like DEF's mission of explaining decentralized finance (DeFi) to policymakers and regulators among others, the "State of the Union" will provide the latest "insights to the community about what is going on and what DEF is doing to protect DeFi’s immense potential."

• Blockchain Tipsheet: Tips for June 6, 2024
  

• DeFi Education Fund CEO Miller Whitehouse-Levine tweeted last night about the must-pass addition, "Massive expansion of sanctions designation authorities (and mandatory imposition?) including 'foreign digital asset transaction facilitators' put into [Sen. Mark Warner's] intel bill, which passed out of committee unanimously yesterday. Very concerning..."

• Mondaq: If Craig David Made Court Cases…

• As the DeFi Education Fund has stated in its amicus brief in those proceedings, an adverse finding against Storm will have huge ramifications for software developers who create open source, general use software, who would be held "criminally liable when third party bad actors use that software years after it was created and with no direct or active engagement between the developers and those bad actors".

Podcasts

• Boys Club Podcast: A 101 briefing on Crypto Regulation in the US with Amanda Tuminelli, Chief Legal Officer at DeFi Education Fund

• On this episode of the podcast, Deana talks with Amanda Tuminelli of the DeFi Education Fund. They talk about the recent regulatory and policy news around crypto in the US, what values and principles should be present in crypto policy more generally, and how crypto has entered the political realm.

Blog Posts

• Crypto & Pre-Enforcement Challenges: Another Tool in the Arsenal 

For up-to-date information about what’s happening in D.C. and what we are up to, please follow us on Twitter @fund_defi and subscribe to our Substack.

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