The Digital Chamber (TDC) is pleased to announce that we have submitted our formal response to the Senate Banking Committee’s Request for Input (RFI) on the “Responsible Financial Innovation Act of 2025” discussion draft. Drawing on the expertise of our 200+ diverse members across the blockchain ecosystem, TDC provided over 80 pages of comprehensive feedback addressing nearly every question posed. We hope our insights help inform and strengthen the Committee’s efforts as the legislative process moves forward. 

TDC supports the Senate Banking Committee’s thoughtful approach reflected in the discussion draft. At the same time, our members shared concerns about the proposed use of a “decentralization” construct to determine whether an ancillary asset falls under SEC or CFTC jurisdiction. No other major jurisdiction with comprehensive digital asset regulation imposes such a requirement, creating potential pressure for U.S.-based projects to prematurely declare “decentralization” or “blockchain maturity.” Projects must retain the flexibility to develop in line with user, consumer, and investor needs, and not be constrained by rigid statutory definitions. 

Our response also highlights opportunities to improve clarity around certain definitions and structural coherence of the discussion draft. It is essential that all terms related to the digital asset market are clearly and consistently defined. While Section 101 introduces a definition for “ancillary asset” under the Securities Act of 1933, beginning in Section 109, the draft shifts to using the undefined term “digital asset(s)” without clarifying how it relates to “ancillary asset(s).” Additionally, the interaction between Sections 101 and 102 creates ambiguity around the treatment of assets sold by originators—particularly regarding disclosure obligations or exemptions. We recommend clarifying the definitions and resolving the originator-related conflict to ensure regulatory clarity and coherence. 

Finally, while we support granting the SEC discretion to offer alternative paths for token safe harbors and exemptions, our members expressed concern about the extent to which the draft relies on future SEC rulemaking in areas where innovators need clarity now. Critical issues, such as token disclosure requirements and the definition of when a network is under “common control” of related parties, should be clearly enumerated in statute. Without this enhancement, token issuers risk regulatory uncertainty and potential shifts in policy by future Commissions. We instead support the approach taken in H.R. 3633, the CLARITY Act, which establishes a minimum viable framework in statute to provide innovators with a clear and reliable path forward. 

The Digital Chamber appreciates the diligent work of the Senate Banking Committee staff, Chairman Scott, and Senators Cynthia Lummis, Bill Hagerty, and Bernie Moreno on the introduction of the “Responsible Financial Innovation Act of 2025” discussion draft. We commend the Committee’s thoughtful engagement with stakeholders and recognize its good-faith effort to foster blockchain innovation while upholding strong consumer protections. As the largest and most diverse blockchain trade association, TDC looks forward to continued collaboration with Congress and regulators to ensure that the final market structure legislation reflects the needs of our members and strengthens the U.S. digital economy. 

Read the full TDC response here.

If you have any questions, please reach out to policy@digitalchamber.org