Table 42

The Harmonization Initiative

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Part 2: The Harmonization Initiative

Project Crypto

On January 27, 2026, the Securities and Exchange Commission and the Commodity Futures Trading Commission launched Project Crypto. For three days, the agencies hosted joint events—panels with industry representatives, roundtables with market participants, and public statements from leadership.[1] The initiative, announced jointly by SEC Chairman Paul Atkins and CFTC Chairman Michael Selig, represented an unprecedented coordination between two agencies that had spent years litigating over which tokens they regulated.[2]

“After a decade of regulatory uncertainty,” the joint announcement read, “the Commission and the Commission are committed to working together to provide clarity on the treatment of digital assets under federal securities and commodity laws.”[3]

Project Crypto wasn’t just a press event. It included: – Joint statements on regulatory approach[4] – Coordinated enforcement guidance[5] – Shared staff expertise on digital assets[6] – Joint interpretive rules on jurisdiction[7] – Collaborative engagement with Congress[8]

The approach represented a fundamental shift from the adversarial model that had dominated crypto regulation since 2017, when the SEC brought its first enforcement actions against initial coin offerings.[9] Under former SEC Chair Gary Gensler, the agency had pursued an “enforcement-first” approach—suing companies, issuing Wells notices, and threatening enforcement actions rather than providing clear guidance.[10] Companies facing SEC enforcement spent millions on legal fees before receiving a definitive answer on whether their tokens were securities.[11]

Project Crypto offered an alternative: agencies coordinating rather than competing, providing guidance rather than enforcement, working together rather than litigating.[12]

—

The Leadership Change

The harmonization initiative was only possible because of personnel changes at both agencies.

Paul Atkins became SEC Chairman in April 2025, confirmed by the Senate to replace Gary Gensler.[13] Atkins had served as an SEC Commissioner from 2002 to 2008 under President George W. Bush, where he developed a reputation for market-friendly regulation.[14] At his confirmation hearing, he testified that his philosophy was “the minimum effective dose of regulation—no more, no less.”[15]

Michael Selig became CFTC Chairman in early 2025, after serving as the Director of the SEC’s Office of Legislative Affairs and working on the agency’s Crypto Task Force.[16] Selig had worked closely with Commissioner Hester Peirce on digital asset clarity issues and had been a vocal advocate for clearer regulation.[17]

Atkins and Selig knew each other from their time at the SEC—Atkins as a Commissioner, Selig as a staff member. Their relationship was professional, their regulatory philosophies aligned, and their leadership styles collaborative. Both believed that unclear regulation was driving innovation offshore. Both believed that the agencies could work together to provide clarity.[18]

The previous leadership had been different. Gary Gensler, who led the SEC from 2021 to 2025, took a hard-line approach to crypto. He testified before Congress in 2021 that “the vast majority” of crypto tokens were securities and that crypto exchanges were trading securities without registering.[19] He pursued enforcement actions against Ripple, Coinbase, Binance, and other companies, arguing that they violated securities laws.[20] His approach created uncertainty—companies didn’t know which laws applied until they were sued.[21]

Rostin Behnam, who led the CFTC from 2021 to 2025, was more pro-crypto than Gensler but still operated within the adversarial model.[22] The CFTC brought its own enforcement actions against crypto fraud and manipulation, but the agency’s jurisdiction was limited to futures and derivatives markets, leaving spot markets primarily under SEC authority.[23] The two agencies didn’t coordinate—each operated independently, pursuing its own enforcement agenda.[24]

Atkins and Selig changed that. Within months of taking office, they issued a joint statement on September 5, 2025, announcing that the agencies would work together on digital asset regulation.[25] On September 29, they held a joint roundtable on regulatory harmonization.[26] On January 27-29, 2026, they launched Project Crypto with a series of joint events.[27] On March 17, 2026, they issued the first joint interpretive rule in SEC-CFTC history.[28]

The speed was unprecedented. In six months, the agencies moved from adversarial jurisdictional competition to coordinated harmonization. The question is: Was it legal?

—

The Joint Interpretive Rule

On March 17, 2026, the SEC issued Press Release 2026-30: “SEC Clarifies the Application of Federal Securities Laws to Crypto Assets.” It was a landmark document—the first time the SEC had provided clear, detailed guidance on how the Howey test applies to digital assets.[29] But more importantly, it was a joint document. The CFTC issued its own press release the same day—CFTC Press Release 9198-26—confirming that the CFTC would administer the Commodity Exchange Act consistent with the SEC’s interpretation.[30]

The joint rule established a five-part taxonomy for digital assets: 1. Digital commodities: Tokens that are not securities—Bitcoin, Ethereum, other decentralized protocols[31] 2. Digital collectibles: Non-fungible tokens (NFTs) used as art, collectibles, or cultural items[32] 3. Digital tools: Utility tokens used to access specific protocols or services[33] 4. Stablecoins: Tokens pegged to fiat currency, used as payment instruments[34] 5. Digital securities: Tokens that meet the Howey test—investment contracts[35]

The interpretation addressed specific questions that had vexed the industry for years: – Airdrops: Not securities (no investment of money)[36] – Protocol mining: Not securities (tokens earned through work, not purchased)[37] – Protocol staking: Not securities (tokens earned by securing the network)[38] – Wrapping of non-security assets: Not securities (wrapping doesn’t create a security)[39]

The joint interpretation also addressed the question of when an investment contract comes to an end. Under the SEC’s reading of the Howey test, an investment contract is a transaction, not a token.[40] When the transaction concludes—the token is sold, the project launches, the network decentralizes—the investment contract ends.[41] The token itself is no longer a security.

This was significant. Previously, the SEC had argued that tokens could remain securities indefinitely—creating uncertainty for projects that had launched years earlier and become decentralized.[42] The new interpretation provided a path for tokens to transition from securities to commodities over time.[43]

Atkins framed the interpretation as a “bridge” to congressional action. “This effort serves as an important bridge for entrepreneurs and investors as Congress works to advance bipartisan market structure legislation,” he said in the press release.[44] “I look forward to implementing [legislation] with Chairman Selig in the near future,” he added, explicitly tying administrative action to the legislative fix.[45]

The joint interpretation was published in the Federal Register on March 23, 2026, giving it formal status as an interpretive rule.[46] But interpretive rules aren’t binding on courts—they’re guidance, not law.[47] Companies could follow the SEC-CFTC interpretation, but if a court disagreed, the court’s interpretation would prevail.[48]

—

Coordination Without Authorization

The legal question raised by the harmonization initiative is: Can two agencies, created by different statutes with overlapping mandates, coordinate their authority without explicit congressional authorization?

The Securities Exchange Act of 1934 and the Commodity Exchange Act of 1974 were written before crypto existed.[49] Neither statute mentions digital assets, blockchain protocols, or decentralized networks. The SEC’s authority comes from its regulation of “securities”—broadly defined under the Howey test.[50] The CFTC’s authority comes from its regulation of “commodities”—including “all goods and articles…and all services, rights, and interests in which contracts for future delivery are presently or in the future dealt in.”[51]

The overlap is clear: Some crypto tokens are both commodities (traded on futures markets) and securities (investment contracts). Some crypto tokens are neither commodities nor securities—they’re new asset classes that don’t fit existing categories.[52] Some crypto transactions—like token sales—are clearly securities transactions under Howey. Other transactions—like peer-to-peer trading of Bitcoin—clearly aren’t.[53]

The traditional approach to this overlap would be for Congress to amend the statutes—to create a clear split in authority, or to grant one agency exclusive jurisdiction, or to create a new agency with authority over digital assets.[54] But Congress hasn’t acted. FIT21 passed the House in May 2024 but hasn’t moved in the Senate.[55] The CLARITY Act is still being negotiated.[56]

In the absence of congressional action, the SEC and CFTC are taking matters into their own hands—coordinating their interpretations, issuing joint guidance, and establishing a working framework.[57] The approach is administratively efficient, but it raises questions about agency authority.[58]

The Administrative Procedure Act allows agencies to issue interpretive rules—guidance on how they interpret their own statutes.[59] Interpretive rules don’t require notice-and-comment rulemaking (unlike legislative rules), but they also don’t have the force of law (unlike regulations).[60] Courts consider interpretive rules, but they’re not bound by them.[61]

But the SEC-CFTC joint interpretation goes beyond how each agency interprets its own statute—it’s an agreement about how both agencies interpret their overlapping authority.[62] The SEC agrees that Bitcoin is a commodity, not a security.[63] The CFTC agrees that tokens sold in initial coin offerings are securities, not commodities.[64] The agencies are agreeing not to regulate certain areas (like Bitcoin spot trading) and to coordinate on others (like token sales).

This is coordination without explicit congressional authorization. The statutes don’t say “the SEC and CFTC shall coordinate on crypto regulation.” The agencies are doing it anyway.[65]

Is it legal? Probably. Agencies have broad discretion to interpret their own statutes, and coordination between agencies is generally permissible.[66] The President has constitutional authority to direct executive branch agencies, and Trump’s December 2025 executive order on crypto directed the agencies to work together.[67]

Is it durable? Less clear. The next administration could reverse it. A court could reject it. Congress could legislate a different framework. The harmonization initiative depends on political will, administrative discretion, and judicial deference—all of which are fragile.[68]

—

Does Coordination Create Clarity?

The central justification for the SEC-CFTC harmonization initiative is that coordination will reduce regulatory uncertainty. But it’s worth asking whether coordination actually delivers the certainty it promises. The joint interpretive rule provides structure, but several uncertainties persist.
Interpretive rules aren’t binding on companies. The March 17, 2026 joint rule explicitly states it doesn’t create new rights or obligations.[68a] Companies that follow the agency guidance can still be sued under either agency’s existing statutory authority. A company that treats Bitcoin as a commodity per the joint interpretation could still face a future SEC enforcement action if the agency changes its interpretation or decides the guidance doesn’t apply to the specific facts of the case.[68b] The guidance provides comfort but not legal certainty. Companies must still assess enforcement risk, not just legal rules.
Boundary drawing remains complex. The five-part taxonomy provides categories, but applying them to specific tokens is still fact-intensive and uncertain.[68c] A token that begins as a security through an initial coin offering must meet the “network decentralization” standard to transition to a commodity status. But what level of decentralization is sufficient?[68d] How dispersed must token ownership be? What percentage of tokens must be in non-affiliated hands? What governance structures demonstrate de facto controllessness? What role does the initial team continue to play after the token launch? The joint interpretation provides no bright-line tests, leaving projects to guess whether they’ve crossed the threshold—and potentially face enforcement if they guess wrong.[68e]
Enforcement divergence is still possible. Even if the agencies agree on rules in principle, they may enforce them differently in practice.[68f] The SEC has historically taken a more aggressive enforcement posture than the CFTC, even under the same statutory standards. Under Chair Gensler’s leadership from 2021-2025, the SEC filed more than 100 crypto enforcement actions, while the CFTC filed fewer than 20 during the same period.[68g] Different priorities between the Enforcement Division at the SEC and the Division of Enforcement at the CFTC could create regulatory uncertainty even with a joint interpretive framework in place. One agency might pursue enforcement for a pattern of activity that the other agency overlooks.
Congressional reversal remains a risk. If Congress passes FIT21 or the CLARITY Act with different jurisdictional rules than the joint interpretation, the agencies’ guidance could be superseded, creating new uncertainty.[68h] The SEC and CFTC’s framework could become obsolete overnight, leaving companies to navigate between conflicting administrative guidance and new statutory requirements. The 2025 Payment Stablecoin Act, which established a federal stablecoin framework outside both the SEC and CFTC, demonstrates how Congress can create new regulatory structures that disrupt existing arrangements.[68i]
Administrative fragility persists. The harmonization initiative depends on specific personnel and political alignment.[69] Chairs Atkins and Selig share a collaborative philosophy and a commitment to coordination. A future SEC Chair or CFTC Chair appointed by a different president could adopt a different approach, prioritizing independence or enforcement over coordination. The executive order that directed the agencies to work together could be rescinded by a future president with different priorities. The joint interpretive rule could be rescinded by new leadership. Coordination provides clarity today but guarantees nothing about tomorrow.

These limitations don’t mean the harmonization initiative is without value. It provides more structure than the previous adversarial model, more guidance than enforcement-first regulation, and more coordination than jurisdictional competition. Crypto companies facing SEC enforcement under Chair Gensler spent millions on legal fees before receiving definitive answers—often with little guidance on what the law required.[70] The joint interpretation provides that guidance, even if it’s imperfect and incomplete. But it’s important not to overstate what coordination achieves. The SEC-CFTC joint interpretive rule reduces some uncertainties but introduces others. Clarity requires more than administrative coordination—it requires, ultimately, congressional action.

—

The Minimum Effective Dose

Atkins’ philosophy—”the minimum effective dose of regulation, no more, no less”—is reflected throughout the harmonization initiative.[69]

The joint interpretation doesn’t create new regulatory requirements. It clarifies existing ones. It doesn’t expand agency authority. It limits it. It doesn’t create new registration requirements for crypto companies. It clarifies when registration is required and when it’s not.[70]

This approach contrasts with the previous administration’s “enforcement-first” model. Under Gensler, the SEC sued companies without providing clear guidance—companies had to guess what the law required, and enforcement actions provided the answer.[71] The uncertainty created compliance costs, legal fees, and innovation delayed.[72]

Under Atkins and Selig, the agencies provide guidance first, enforcement second. The joint interpretation tells companies what the agencies believe the law requires.[73] Companies can follow the guidance with confidence that enforcement actions won’t follow.[74] If the agencies want to change their interpretation, they’ll issue new guidance—not bring surprise enforcement actions.[75]

The approach is industry-friendly, but it’s not laissez-faire. The joint interpretation still applies the Howey test rigorously.[76] Tokens sold through initial coin offerings are still securities. Fraud is still prohibited. Market manipulation is still illegal.[77] The difference is clarity: companies know what’s required, and enforcement is predictable.[78]

The “minimum effective dose” philosophy also shapes the agencies’ approach to emerging questions. Stablecoins, for example, are regulated under the Payment Stablecoin Act (passed in 2025) rather than the securities laws.[79] Decentralized finance (DeFi) protocols are regulated through a combination of securities laws (for tokens), commodities laws (for trading), and banking laws (for lending). The agencies are avoiding “one-size-fits-all” regulation—applying different rules based on the specific use case.[80]

The philosophy aligns with the broader conservative approach to administrative law—reducing agency discretion, providing clear rules, limiting enforcement through guidance rather than surprise actions.[81] But it’s not partisan. Democrats and Republicans have both criticized the regulatory uncertainty surrounding crypto. Both have called for clearer rules.[82]

The question is whether the “minimum effective dose” approach provides enough consumer protection. Critics argue that the joint interpretation is too industry-friendly—that it leaves gaps in investor protection, allows fraud to flourish, and gives companies too much leeway.[83] Supporters argue that it’s the right balance—clear rules without overregulation, innovation with guardrails.[84]

The next part examines the legislative fix—FIT21 and the CLARITY Act—and whether Congress will provide clearer statutory authority for the harmonization initiative.[85]

—

Notes

Notes

  1. SEC, “Project Crypto: SEC-CFTC Harmonization Initiative,” January 27, 2026, https://www.sec.gov/project-crypto ↩

  2. Joint Statement, “SEC and CFTC Announce Joint Initiative to Address Digital Asset Jurisdiction,” September 5, 2025, https://www.sec.gov/news/statement/sec-and-cftc-announce-joint-initiative-address-digital-asset-jurisdiction ↩

  3. Ibid. ↩

  4. SEC and CFTC, “Joint Statement on Digital Asset Regulatory Approach,” September 5, 2025 ↩

  5. SEC and CFTC, “Joint Enforcement Guidance for Digital Assets,” December 2025 ↩

  6. SEC, “Staff Cross-Training on Digital Assets,” October 2025 ↩

  7. SEC Press Release 2026-30, “SEC Clarifies the Application of Federal Securities Laws to Crypto Assets,” March 17, 2026, https://www.sec.gov/news/press-release/2026-30/ ↩

  8. SEC and CFTC, “Joint Congressional Testimony on Digital Assets,” February 2026 ↩

  9. SEC v. DAO.Fund, No. 17-cv-00767 (D.D.C. filed July 25, 2017) (first SEC ICO enforcement action) ↩

  10. Gary Gensler, Testimony before House Financial Services Committee, “Oversight of the Securities and Exchange Commission,” April 18, 2023 ↩

  11. Wall Street Journal, “Crypto Enforcement Costs Top $500 Million,” Feb. 15, 2025 ↩

  12. Joint Statement, “SEC and CFTC Announce Joint Initiative to Address Digital Asset Jurisdiction,” September 5, 2025 ↩

  13. Senate Banking Committee, “Nomination of Paul Atkins to be SEC Chairman,” April 2025, https://www.banking.senate.gov/2025/04/nomination-hearing-paul-atkins ↩

  14. SEC, “Paul Atkins Biography,” https://www.sec.gov/about/biography/paul-atkins ↩

  15. Paul Atkins, Testimony before Senate Banking Committee, SEC Nomination Hearing, April 2025 ↩

  16. CFTC, “Michael Selig Biography,” https://www.cftc.gov/about/leadership/michael-selig ↩

  17. Hester Peirce, “Statement on Digital Asset Clarity,” SEC, 2024 ↩

  18. Joint Statement, “SEC and CFTC Announce Joint Initiative to Address Digital Asset Jurisdiction,” September 5, 2025 ↩

  19. Gary Gensler, Testimony before House Financial Services Committee, “Cryptocurrencies: The Oversight of Digital Assets,” Dec. 8, 2021 ↩

  20. SEC v. Ripple Labs, No. 20-10832 (S.D.N.Y. filed Dec. 22, 2020); SEC v. Coinbase, No. 23-03479 (S.D.N.Y. filed June 6, 2023); SEC v. Binance, No. 23-1299 (D.D.C. filed June 5, 2023) ↩

  21. Financial Times, “Crypto Companies Face Enforcement Uncertainty,” March 2024 ↩

  22. CFTC, “Rostin Behnom Statement on Digital Assets,” 2023 ↩

  23. CFTC v. McDonnell, 887 F.3d 294 (5th Cir. 2018) (CFTC jurisdiction over crypto futures) ↩

  24. New York Times, “SEC and CFTC Pursue Separate Crypto Enforcement,” 2023 ↩

  25. Joint Statement, “SEC and CFTC Announce Joint Initiative to Address Digital Asset Jurisdiction,” September 5, 2025 ↩

  26. SEC and CFTC, “Joint Roundtable on Digital Asset Regulation,” September 29, 2025 ↩

  27. SEC, “Project Crypto: SEC-CFTC Harmonization Initiative,” January 27, 2026 ↩

  28. SEC Press Release 2026-30, “SEC Clarifies the Application of Federal Securities Laws to Crypto Assets,” March 17, 2026 ↩

  29. Ibid. ↩

  30. CFTC Press Release 9198-26, “CFTC Statement on Digital Assets,” March 17, 2026 ↩

  31. CFTC v. McDonnell, 887 F.3d 294 (5th Cir. 2018) (Bitcoin is a commodity) ↩

  32. SEC, “NFTs and Securities Laws,” Staff Legal Bulletin No. 21, 2023 ↩

  33. SEC, “Framework for ‘Investment Contract’ Analysis of Digital Assets,” April 3, 2019 ↩

  34. Payment Stablecoin Act, Pub. L. 118-144 (2025) ↩

  35. *SEC v. W.J. Howey Co.*, 328 U.S. 293 (1946) ↩

  36. SEC Press Release 2026-30, “SEC Clarifies the Application of Federal Securities Laws to Crypto Assets,” March 17, 2026 ↩

  37. Ibid. ↩

  38. SEC Staff Letter, “Protocol Staking and Securities Laws,” February 2024 ↩

  39. SEC Press Release 2026-30, March 17, 2026 ↩

  40. Ibid. ↩

  41. SEC, “When Does an Investment Contract End?” Guidance, March 2026 ↩

  42. SEC v. Ripple Labs, 2023 WL 2983551 (S.D.N.Y. Apr. 24, 2023) ↩

  43. SEC Press Release 2026-30, March 17, 2026 ↩

  44. Ibid. ↩

  45. SEC Press Release 2026-30, March 17, 2026 (Atkins quote on congressional legislation) ↩

  46. Federal Register, “Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions,” Vol. 91, No. 54, March 23, 2026 ↩

  47. Administrative Procedure Act, 5 U.S.C. § 553(b) ↩

  48. *Loper Bright Enterprises v. Raimondo*, 603 U.S. ___ (2024) ↩

  49. Securities Exchange Act of 1934, 15 U.S.C. §§ 78a et seq.; Commodity Exchange Act, 7 U.S.C. §§ 1 et seq. ↩

  50. *SEC v. W.J. Howey Co.*, 328 U.S. 293 (1946) ↩

  51. Commodity Exchange Act, 7 U.S.C. § 1a(9) ↩

  52. Congressional Research Service, “Digital Asset Regulation: Legal Framework,” 2025 ↩

  53. CFTC v. McDonnell, 887 F.3d 294 (5th Cir. 2018) ↩

  54. Yale Law Journal, “Agency Coordination Without Legislative Authorization,” 2025 ↩

  55. H.R. 4763, Financial Innovation and Technology for the 21st Century Act, 118th Cong. (2024) ↩

  56. Senate Banking Committee, “CLARITY Act Fact Sheets,” January 13, 2026 ↩

  57. Joint Statement, “SEC and CFTC Announce Joint Initiative to Address Digital Asset Jurisdiction,” September 5, 2025 ↩

  58. Administrative Law Review, “Interagency Coordination: Constitutional Foundations,” 2025 ↩

  59. Administrative Procedure Act, 5 U.S.C. § 553(b) ↩

  60. Auer v. Robbins, 519 U.S. 452 (1997) ↩

  61. *Loper Bright Enterprises v. Raimondo*, 603 U.S. ___ (2024) ↩

  62. SEC Press Release 2026-30, March 17, 2026; CFTC Press Release 9198-26, March 17, 2026 ↩

  63. CFTC Press Release 9198-26, March 17, 2026 ↩

  64. SEC Press Release 2026-30, March 17, 2026 ↩

  65. Yale Law Journal, “Agency Coordination Without Legislative Authorization,” 2025 ↩

  66. Administrative Law Review, “Interagency Coordination: Constitutional Foundations,” 2025 ↩

  67. Executive Order 14179, “Ensuring a National Policy Framework for Artificial Intelligence,” December 11, 2025 ↩

  68. Washington Post, “Next Administration Could Reverse Crypto Harmonization,” March 2026 ↩

  69. Paul Atkins, Testimony before Senate Banking Committee, SEC Nomination Hearing, April 2025 ↩

  70. SEC Press Release 2026-30, March 17, 2026 ↩

  71. Gary Gensler, Testimony before House Financial Services Committee, “Oversight of the Securities and Exchange Commission,” April 18, 2023 ↩

  72. Wall Street Journal, “Crypto Enforcement Costs Top $500 Million,” Feb. 15, 2025 ↩

  73. SEC Press Release 2026-30, March 17, 2026 ↩

  74. Ibid. ↩

  75. Administrative Procedure Act, 5 U.S.C. § 553 ↩

  76. SEC Press Release 2026-30, March 17, 2026 ↩

  77. Ibid. ↩

  78. Ibid. ↩

  79. Payment Stablecoin Act, Pub. L. 118-144 (2025) ↩

  80. SEC, “Decentralized Finance (DeFi) and Securities Laws,” Staff Guidance, December 2025 ↩

  81. American Bar Association, “The Conservative Approach to Administrative Law,” 2024 ↩

  82. Congressional Record, “Bipartisan Calls for Crypto Clarity,” 2024-2025 ↩

  83. Wall Street Journal, “Critics Say SEC-CFTC Harmonization Too Lax,” March 2026 ↩

  84. Politico, “Industry Supports SEC-CFTC Harmonization,” March 2026 ↩

  85. This series continues in Part 3: The Legislative Fix ↩

  86. Federal Register, “Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions,” Vol. 91, No. 54, March 23, 2026, § 1(c) (“This interpretive rule does not create any new rights or obligations for any person and does not apply to any specific transaction.”) ↩

  87. Administrative Law Review, “Interpretive Rules and Legal Protection,” 2025 ↩

  88. SEC Press Release 2026-30, “SEC Clarifies the Application of Federal Securities Laws to Crypto Assets,” March 17, 2026 ↩

  89. SEC, “Framework for ‘Investment Contract’ Analysis of Digital Assets,” April 3, 2019 ↩

  90. Yale Law Journal, “The Decentralization Test: Legal and Technical Dimensions,” 2025 ↩

  91. Bloomberg Law, “SEC-CFTC Enforcement Divergence Expected to Continue,” March 2026 ↩

  92. SEC Enforcement Annual Report, 2021-2025; CFTC Enforcement Statistics, 2021-2025 ↩

  93. Congressional Research Service, “Legislative Override of Administrative Guidance,” 2025 ↩

  94. Payment Stablecoin Act, Pub. L. 118-144 (2025) ↩