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Bitwise, Galaxy and Morpho Back CCI Framework for U.S. Crypto Vault Regulation
The Crypto Council for Innovation (CCI) has proposed a framework to bring crypto vaults under U.S. securities laws. In a 238-page report published October 29, the CCI set out how regulators can assess different vault structures under existing rules, including the Securities Act of 1933, the Investment Company Act of 1940 and the Investment Advisers Act of 1940. The report tests 90-year-old securities rules against blockchain-based vaults.
Crypto vaults are smart contracts that take user token deposits and deploy them into strategies such as lending, borrowing and investments to generate returns. Adoption is expanding beyond decentralized finance (DeFi), with traditional financial institutions also exploring the model. S&P Global data shows assets deposited in vaults reached $131 billion in April 2026.
The CCI, joined by members from Bitwise, Galaxy Digital and Morpho, argues that crypto vaults should not automatically fall outside federal securities laws simply because they run on blockchain technology and smart contracts. Bitwise CEO Hunter Horsley said: “Vaults are going to change capital markets. We are delighted to be part of it.”
The report introduces a two-sided “Control Framework” to determine how much authority human operators hold over deposited assets and how much control investors have over their funds. On the operator side, it examines four factors: mandate, execution, governance and disposition. This assesses whether operators can select investment strategies, reallocate capital, change protocol rules or move deposited assets. On the depositor side, it considers six conditions: comprehensibility, verifiability, observability, predictability, notice and actionability.
The core argument is that vaults with immutable smart contracts, transparent operations, limited human discretion and permissionless withdrawals should face a different regulatory assessment from those where operators retain significant control over investment decisions.
The proposal draws parallels with Section 10301 of the proposed CLARITY Act, which addresses nondecentralized finance protocols based on whether identifiable individuals or groups can control or materially alter their functionality. The CCI wants regulators to adopt a similarly control-based approach.
For regulatory clarity, the CCI also wants the SEC to follow the approach it used for ETFs: grant individual exemptions to qualifying vault structures under Section 6(c) of the Investment Company Act before introducing broader, standardized rules. Horsley added: “We worked with regulators for years to help make crypto ETFs possible. We are happy to collaborate again, this time on vaults.”
The proposal echoes the July 22 statement by SEC Commissioner Hester Peirce, “Headstands and Summervaults,” which cautioned against treating all crypto vaults alike. Vaults are not uniform.
A recent AMBCrypto report highlighted how Web3 protocols are moving away from their original promises of openness, permissionlessness and decentralization. It cited Hyperliquid, Aave and Polygon as projects that have adopted models prioritizing internal vaults, buybacks and treasury accumulation over directly distributing value to token holders.
The CCI argues that crypto vaults should not automatically fall outside U.S. federal securities laws. S&P Global data shows assets deposited in vaults reached $131 billion in April 2026.