When it comes to developer protections, there's a fundamental principle worth stressing: non-custodial software developers shouldn't be classified as money transmitters, and they shouldn't be required to KYC their users. That should be the baseline.
However, Title 3 raises serious concerns. Several provisions contain language that could potentially enable excessive regulatory oversight of DeFi protocols. These problematic references need to be either removed entirely or substantially revised to protect the decentralized development ecosystem from regulatory overreach.
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When it comes to developer protections, there's a fundamental principle worth stressing: non-custodial software developers shouldn't be classified as money transmitters, and they shouldn't be required to KYC their users. That should be the baseline.
However, Title 3 raises serious concerns. Several provisions contain language that could potentially enable excessive regulatory oversight of DeFi protocols. These problematic references need to be either removed entirely or substantially revised to protect the decentralized development ecosystem from regulatory overreach.