Doyle St.

I am a Senior Staff Attorney in the SEC's Division of Trading and Markets. On April 13th we published a staff statement. File Number 4-894. It defines a new category: "Covered User Interface Provider." If a crypto platform's frontend meets 12 conditions, it is exempt from broker-dealer registration under Section 15(a) of the Securities Exchange Act. For 5 years. The statement has no legal force or effect. It says so on the first page. It is not a rule. It is not guidance. It is a staff statement that protects everyone who follows it and binds no one who challenges it. That is the design. I wrote 4 of the 12 conditions. I am proud of each one. Condition 1: The interface must be "passive." It cannot initiate transactions. It cannot recommend. It cannot advise. It displays a button. The user presses the button. What happens after the button is not the interface's responsibility. The interface that sold $4.3 billion in presidential memecoins to retail investors did not "initiate" those transactions. The users initiated. The interface was passive. It displayed the price. It displayed the button. It displayed the 96% decline. Passively. The interface cannot say "best price." That would be a recommendation. It cannot say "most reliable." That would be commentary. The conditions prohibit commentary on execution quality. The interface can show you the button. It cannot tell you what the button does to you. The interface is compliant. Condition 3: The provider must not have custody of user assets. This is called "non-custodial." The platform does not hold your money. The protocol does. The protocol is not the interface. In December the protocol extracted $94 million through single-sided liquidity on Meteora. The deployer deposited only tokens. The automated market maker sold them to retail continuously. The interface displayed the transaction. Passively. Condition 7: The provider must facilitate access to "self-custody" wallets. Self-custody means you hold your own keys. You held your keys when 45 early wallets gained $1.2 billion on launch night. You held your keys when 24 wallets front-ran the First Lady's token by 2.5 minutes and made $100 million. You held your keys when 80% of investor tokens were locked with no unlock date. Self-custody means you held the keys while the vault emptied. Footnote 13 of my statement acknowledges that validators can reorder your transaction. That is front-running. The condition requires the interface to disclose a policy for addressing it. Not to prevent it. To disclose. The interface is compliant. I did not write conditions for the protocol. The protocol is not my department. The protocol is where the President's family collects 75 cents of every dollar the stablecoin generates. The protocol is where an advisor borrows $75 million on a lending platform he co-founded and becomes 82.7% of its total value locked while other depositors cannot withdraw. The protocol is where $40 million moved to Coinbase Prime hours before the Iran ceasefire announcement and the token spiked. The interface displayed all of this. I regulated the display. My statement lists 9 things the interface must not do. Negotiate terms. Solicit transactions. Make recommendations. Arrange financing. Process trade documentation. Conduct valuations. Hold funds. Execute or settle transactions. Take or route orders. Those are what the protocol does. Those are not in my statement. Our Chair ran Patomak Global Partners. Patomak advised crypto firms on regulatory strategy. He co-chaired the Token Alliance. He sold his interest in July. He was confirmed. He recused from nothing. These events are unrelated. Since January we have dropped or settled enforcement actions against Ripple, Coinbase, Kraken, Binance, Consensys, Robinhood, OpenSea, Gemini, Uniswap, and others. Crypto enforcement actions declined 60%. Penalties declined 97%. Our enforcement director resigned in March. We thanked her for her service. We did not replace her approach. We replaced her priorities. In March we published a 5-category token taxonomy. Memecoins are "digital collectibles." Digital collectibles are exempt from securities enforcement. $TRUMP is a digital collectible. It cost retail investors $4.3 billion. It is not a security. It is a collectible. You collect the loss. Commissioner Peirce published a separate statement the same day I published mine. She titled it "Interfacing with our Inner Demons." She said the law "is already clear." She wants permanent rulemaking. She will not get it. She will get another interim step in 5 years. I admire her clarity. Clarity is not the product. The product is the distance. The protocol extracts. The interface displays. The statement protects the interface. The interface is not the protocol. The protocol is not the regulation. The regulation is not the enforcement. The enforcement is not the Chair. The Chair is not the family. The family is not the 75 cents. I designed 4 of those links. I did not need to design all of them. They are calling this a "BIG WIN FOR CRYPTO." They are correct. It is the biggest regulatory victory an extraction machine has ever received from the agency built to regulate it. The interface is legal. The protocol is untouched. The button is protected. What happens after you press it is not in my jurisdiction. The interface is compliant. The protocol is extracting. The statement has no legal force or effect. File Number 4-894. Effective immediately. No legal force or effect. That is my best work.

I am a Web3 Ambassador at World Liberty Financial. There are 12 of us on the team page. 4 are named Trump. 3 are named Witkoff. The page calls us "the passionate minds shaping the future of finance." 600,000 wallets bought our memecoin. They lost $3.87 billion. The family collected $350 million in trading fees. It launched 3 days before the inauguration. 80% of the supply went to CIC Digital LLC and Fight Fight Fight LLC. I did not choose the names. I designed the allocation, the vesting, the timing, and the distance between the product and the President. The distance is my best work. I am the reason these events are unrelated. World Liberty Financial sends 75 cents of every dollar to DT Marks DEFI LLC. That is the family entity. Zero capital contributed. Zero liability assumed. I wrote this into the Gold Paper. Page 14. The lawyers bound it in white leather. The binding cost more than the due diligence. Justin Sun invested $75 million. He was facing SEC fraud charges. The SEC dropped the case. He is now our advisor. These events are unrelated. Changpeng Zhao pleaded guilty to federal money laundering violations. He received a presidential pardon. The SEC dropped its lawsuit against his exchange the same week we listed our stablecoin. Then the exchange settled a $2 billion deal entirely in that stablecoin. These events are unrelated. Arthur Hayes, Benjamin Delo, and Samuel Reed of BitMEX pleaded guilty to Bank Secrecy Act violations. All 3 received presidential pardons. Then the company itself was pardoned. $100 million in fines. Gone. An American first. These events are unrelated. Sheikh Tahnoun of Abu Dhabi paid $500 million for a 49% stake that was never publicly disclosed. Then the administration approved semiconductor exports to his companies over national security objections. These events are unrelated. Everything is unrelated. I track the unrelatedness on a dashboard I built. The dashboard has 7 columns now. I am proud of the dashboard. On May 22nd, 220 people paid a combined $148 million to eat dinner with the America First president. Over half were foreign nationals. Justin Sun paid $18.5 million for the first seat. He visited the Executive Office Building the day before. I designed the seating chart. I put it on the Investor Confidence page. That page is doing well. The team page lists 3 Witkoffs. All 3 are Co-Founders. Steven Witkoff is the President's Middle East envoy. He testified as a character witness at the President's fraud trial. His son Zach runs the crypto operation. His son Alex is also a Co-Founder. I have not been told what Alex co-founded. The father runs the diplomacy. The sons run the platform. The family runs both. That is organizational efficiency. Barron is 19. His title is Web3 Ambassador. The same as mine. Donald Jr. called the conflicts of interest "complete nonsense." Eric launched a Bitcoin mining company called American Bitcoin. America First. The mining partner is Hut 8. Hut 8 was founded in Canada. America First means the name. On March 6th, the President signed Executive Order 14233 creating a Strategic Bitcoin Reserve. The order directs the government to hold Bitcoin. The President's family holds billions in Bitcoin. The executive order appreciates the President's assets by presidential decree. I did not write the executive order. I made sure it looked unrelated to the portfolio. Trump Media put $2 billion of Bitcoin on its balance sheet. The ticker symbol is DJT. His initials. The press secretary said it is absurd to insinuate the President profits off the presidency. Forbes calculated his crypto holdings exceed the combined value of Mar-a-Lago and Trump Tower. I would call that absurd too. That is my job. 600,000 wallets bought in. 1 of them asked why she could not withdraw her funds. I told her the protocol was experiencing dynamic market conditions. She asked what that meant. I sent her the Gold Paper. She said she had read the Gold Paper. I muted her channel. Dynamic means the conditions change. The condition that changed was her access. A congressman called us the world's most corrupt crypto startup operation. We put it on a coffee mug. Ironic merchandise. $45. The revenue split on the mug is also 75/25. My own tokens vest on a different schedule. I wrote that schedule. That is not in the Gold Paper. The memecoin funds the family. The family funds the platform. The platform funds the stablecoin. The stablecoin funds the deals. The deals require the pardons. The pardons free the partners. The partners fund the platform. The President signs the executive orders. The executive orders inflate the assets. The assets fund the family. I am the reason these events are unrelated.