On the same timeline, several letters to regulators, hundreds of millions of dollars in warrants, and the custody plan of a major German bank outline a new order in the crypto industry: In December 2025, the SEC threw out a discussion draft concerning CTP but has not given a final answer; U.S. centralized platforms are wavering between enforcement threats and compliance negotiations; on September 14, 2026, a16z and the DeFi Education Fund submitted a response letter requesting that the SEC allow for a "notification filing" lightweight approach based on the 1998 ATS rules for CTP, an attempt to forcibly transplant the traditional securities regulatory template onto the on-chain matching system. On the other side of the Atlantic, Deutsche Bank applied to offer Bitcoin and digital asset custody services to European institutions and corporate clients by the end of 2026 under frameworks such as MiCA, facing direct competition from native custodial institutions and traditional major banks on the same regulatory track; meanwhile, on the capital markets side, Bitcoin treasury company Strive disclosed that as of September 11, 2026, it still had approximately $718 million in PIPE warrants with an exercise price of $27 that had not been exercised, with the exercise window extended to October 13, making this potential equity a leverage point between treasury models and market sentiment. CoinShares reminded that the Federal Reserve's shift to more hawkish policies and the stalled progress of the CLARITY Act have made the U.S. regulatory timeline increasingly uncertain; when the traditional financial regulatory framework collides with CTP and Bitcoin treasury companies, the misalignment of macro rates and legislative rhythms is rewriting who can survive in the new round of institutional entry and corporate treasury reallocation, and who is forced to stand outside compliance boundaries.
a16z Moves 1998 ATS On-Chain
When the SEC released the CTP discussion draft in December 2025 but delayed finalizing an answer, a16z and the DeFi Education Fund submitted a "ready script" on September 14, 2026: directly transplanting the ATS rules that regulated alternative trading systems in 1998 onto the chain. In their response letter, they were not opposing inclusion in the securities regulatory system, but explicitly demanded that CTP should register with the SEC like the alternative trading systems of the past through a notification filing process, rather than being treated under the heavy burden model of national securities exchanges. The reason is simple: the ATS rules have already been validated in the traditional market, providing a lighter compliance path for matching systems while acknowledging them as "securities infrastructure," without dragging every system into the heaviest licensing structure.
More crucially, this response letter requested that the SEC use the ATS framework to define the obligation boundaries and exemption scope for CTP—what functions would bear disclosure, monitoring, and reporting responsibilities, and which could operate at lower costs—thus placing on-chain platforms within an existing securities regulatory lineage rather than starting from scratch. For a16z and DEF, this not only helps U.S. centralized platforms, threatened by enforcement, to strive for a "viable pathway" but also seizes discourse power at the institutional design level: once CTP is written into rules as "like ATS," future determinations about who can facilitate matches, who can engage institutions, and how capital can enter through licensing and registration will extend along this old track from 1998 into the on-chain world, determining who is formally included within compliance boundaries and who is kept outside long-term.
Can the CTP Notification Filing Path be Opened?
For U.S. platforms, the real choice is not whether "to be regulated" but which track to be stuffed into: if ultimately CTP is benchmarked against the model of national securities exchanges, it means high-intensity registration, ongoing disclosure, and compliance system investments, leaving only a few leading platforms, and even fewer traditional financial groups, able to bear the cost; whereas a16z and DEF advocate that CTP should be treated like the alternative trading systems since 1998, exchanging lighter registration and disclosure obligations for "managed identity," entering the list through a notification filing. Between these two paths lies the reality many platforms in the U.S. are currently experiencing: burning cash to maintain operations in a gray area of enforcement and negotiation, without a unified CTP licensing template to refer to, and whether compliance costs are a bottomless pit or "quantifiable expenditures" fully depends on where the SEC ultimately stands.
Once the SEC incorporates CTP into the ATS concept, the next question is drawing the line: clearly, centralized matching platforms in the U.S. will be included, but whether OTC systems providing electronic quoting and matching functions, or middleware offering technical services for multi-asset matching, will be seen as "alternative trading systems" is currently not clearly delineated even in the discussion draft. For DeFi front ends and smaller matching platforms, this line is a matter of life and death—if the notification filing approach is adopted, they can at least expect a "lightweight access" pathway: existing under filing status after meeting specific reporting and compliance requirements; conversely, if the SEC rejects the notification filing and insists on high-bar registration, those limited in size and closely interacting with on-chain tools may find it hard to obtain licensing and hard to prove they are "completely detached from the U.S. market," with the entire compliance expectations for the sector long hanging over this undecided regulatory red line.
Strive's $718 Million PIPE Warrant Countdown
For Strive, the real countdown is not a regulatory hearing, but the date inscribed in the warrant agreement. Strive CEO Matt Cole disclosed that as of September 11, 2026, the company still had about $718 million in PIPE warrants unexercised, corresponding to approximately 26.596 million shares, with an exercise price of $27, and the exercise window, postponed due to Columbus Day, is locked in at 5:00 PM EDT on October 13, 2026. This is not just a "benefit of options," but a financing commitment that has already been registered, disclosed, and must continuously update information under U.S. securities regulatory frameworks: once investors choose to exercise, the company can obtain about $718 million in a compliance track at once, while all dilution, use of funds, and risk warnings must be clearly visible to the market in public documents.
The problem is that this warranty is in a macro headwind period. CoinShares already pointed out in mid-September 2026 that the Federal Reserve’s inclination towards a more hawkish stance and the increased probability of rate hikes within the year, with factors like the Iranian conflict pushing up energy prices, are pressing down market valuations. For institutions holding PIPE warrants, whether to exercise depends not only on Strive's performance as a Bitcoin treasury company but also on whether, in such a tightening policy and rate environment, they are willing to take on a significant position at the $27 exercise price and accept the accompanying dilution effects and lock-up period restrictions. For Strive and similar treasury companies centered on Bitcoin as core assets, whether these warrants can be ignited before the deadline is not just a capital replenishment opportunity window but a concentrated vote to test whether their model can continue to persuade institutional investors to commit "patient capital" under tightening regulations and limited liquidity.
Deutsche Bank Bets on Crypto Custody
Unlike Bitcoin treasury companies relying on PIPE and warrants for survival, Deutsche Bank chooses to bet on regulatory licenses. As one of Europe's systemically important banks, this traditional financial institution has publicly provided a specific timeline under long-standing prudent regulatory frameworks: after obtaining regulatory approval, it plans to offer Bitcoin and digital asset custody services to European institutions and corporate clients by the end of 2026. This means that in Europe, where the unified regulatory framework under MiCA has set the license thresholds, the question of who will "hold" institutional funds is shifting from the game between native custodial institutions and a few financial technology companies to a regulatory track co-participated by large banks and licensed crypto institutions.
Under the MiCA framework that establishes separate licensing for custody and trading businesses, once granted approval, a strictly compliance-bound entity like Deutsche Bank will reshape the power balance in institutional custody: large asset managers, corporate treasuries, and family offices are likely to prefer custodians with established banking relationships familiar with capital rules and anti-money laundering scrutiny processes. For native custodial institutions like Coinbase Custody and BitGo, this represents both direct competition and potential channels for overseas expansion and compliance outsourcing; they must either accelerate obtaining licenses in Europe and meet MiCA requirements or form technical and operational collaborations with traditional banks to remain on the compliance pathway for institutional funds; and for the entire European market, pushing custody businesses out of the "regulatory gray area" into a dual-track structure of bank regulation and specialized crypto licenses will directly determine how large projects and treasuries choose compliance methods in Europe.
Hawkish Federal Reserve and CLARITY Stalled
While Europe uses MiCA to fit custody and trading into the existing regulatory framework, CoinShares' research reports that the Federal Reserve plays a different role: that of a macro regulator compressing valuations. The reports state that the Federal Reserve still considers inflation too high, with the latest rate path predictions showing limited room for interest rate cuts before 2027; under factors like the Iranian conflict pushing energy prices, the likelihood of another rate hike within the year is actually increasing. For crypto assets, this means higher discount rates and tighter risk appetites; CoinShares directly perceives this hawkish stance as the first layer of pressure suppressing valuations and financing environments in the short term and warns that Bitcoin's year-end target of $80,000 is facing macro-level resistance, rather than just emotional volatility.
The second layer of pressure comes from legislation that should have provided "guardrails." The CLARITY Act was originally seen as a key pathway to provide federal-level regulatory clarity for crypto assets, but its advancement has stalled post-2025, and a unified framework has yet to be established. The end result is a discussion draft for CTP released in December 2025 that has yet to transform into final rules, alongside the hesitant CLARITY; the federal regulatory timeline is clearly lagging behind market volatility itself. For U.S. CTPs, they oscillate between enforcement and settlement negotiations, unable to see the shape of future licenses while having to explain their valuations under high interest rates; for treasury companies and institutional allocators relying on capital markets tools, rising macro rates and undecided rules make them uncertain about whether they can "make money," and even less certain whether these arrangements will remain legal in the eyes of regulators in a few years, with this dislocation becoming the hardest variable to quantify in 2026 compliance decisions.
Decisions of Institutions and Trading Platforms Under Regulatory Red Lines
During the window period where the SEC released the CTP discussion draft at the end of 2025 but has yet to provide a final version, U.S. centralized platforms are forced to walk a tightrope between enforcement threats and "future licenses," vying through opinion letters to transplant the 1998 ATS pathway into CTP rules, while enduring the legislative vacuum caused by the stalled progress of the CLARITY Act; at the same time, Bitcoin treasury companies like Strive are locked into capital market terms—the ability of $718 million in PIPE warrants to be exercised before October 13, 2026, is not just about stock prices but also about whether investors are still willing to buy into such a volatile balance sheet through compliance votes. Across the ocean, Europe has drawn relatively clear license boundaries for custody and trading under MiCA, with Deutsche Bank awaiting approvals and planning to launch custody services by the end of 2026, meaning native crypto custodial institutions will face their first direct competition under a unified regulatory framework from traditional banks with licenses and brands. Thus, a new boundary is forming: whether the U.S. CTP framework replicates the lightweight notification filing of ATS or moves towards heavier regulation will determine whether centralized platforms are incorporated into the system or pushed out of compliance peripheries; whether European banks can timely obtain custody approvals will determine whom institutional funds ultimately trust to hold keys; the outcome of Strive’s warrant exercises will serve as a litmus test for whether the Bitcoin treasury model can continue financing in capital markets through PIPEs and warrants. The intersecting uncertainty of these three timelines will rewrite the competitive landscape for trading platforms, banks, and treasury companies over the next one to two years.
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