At the congressional level, the CLARITY Act and broader market structure legislation have long been on hold, with the midterm elections hoped to serve as a "political unlocking point," yet no clear path has been provided. In this legislative vacuum, the power center for U.S. crypto regulation is quietly shifting south, sliding from Congress on the mountaintop towards various federal agencies in Washington, D.C. Maylea Ma, Deputy General Counsel of 1inch, believes that in the coming years, the rules that will truly change the industry's daily operations are more likely to come from the SEC, CFTC, and the Treasury Department, rather than from lawmakers still pulling at the text. One of the most straightforward signals of this shift is the no-action letter sent by the SEC's Division of Corporation Finance to Canton Coin: under certain conditions, they do not recommend taking enforcement action regarding its programmed issuance and explicitly classify it as a "digital commodity," refining a previously ambiguous class of assets within the agency's framework. On the other end, Lighter's operational data for October reveals that despite a total trading volume of $72.9 billion (with the core platform accounting for $53.8 billion and Robinhood Chain $19.1 billion), the platform still recorded a fee revenue of $4.09 million, proving that even if the regulatory boundaries are governed by case guidance and enforcement patchwork, the industry continues to operate at high speed in a "gray area." This contradiction thus surfaces: when legislation stalls, and agencies like the SEC build a de facto new order through no-action letters and case determinations, will the industry's boundaries be shaped into a sustainable long-term framework, or will they remain a temporary map rewritten with changes in government and judicial precedents?

CLARITY Act Stalemate: Congress Remains on Pause

At the congressional level, the CLARITY Act, seen as providing a unified written framework for crypto assets, has long remained in the halls without entering the voting chamber. Previously anticipated to be a turning point, the midterm elections have been viewed by many lobbying teams as an opportunity to "change representatives and political calculations," but so far, this political rotation has not yielded any visible legislative breakthroughs, and the timeline for the bill remains blank. Maylea Ma, Deputy General Counsel of 1inch, assesses that the regulatory progress that will truly take shape in the coming years is more likely to continue coming from the SEC, CFTC, and the Treasury Department rather than the stagnant Congress, hinting at a cruel reality with her phrase "agency-led transitional period": the legislative vacuum will be the norm the industry must adapt to, rather than a short-term noise.

In this context, the nature of the regulatory "script" has changed. Maylea Ma emphasizes that the rules constructed by agencies through guidance, enforcement, and no-action letters lack the stability of codified law that would not be easily overturned by subsequent governments; the long-term goal can only be to enter formal statutory text. D3 co-founder Michael Ho directs his criticism towards the equally stalled market structure bills: with both the market structure and CLARITY caught in Congress, the entire U.S. crypto policy is forced to rely on agency guidance that can be reversed by future governments, resulting in significant investors opting to stay on the sidelines, unwilling to allocate assets in a framework swayed by election cycles. For project teams, this means compliance planning and implementation paths must revolve around "reversible verbal commitments," with each business line's lifecycle needing to leave room for rule changes by new governments or new SEC leadership; for project teams and agencies, this state of being compelled to bet on regulatory articulation amid a legislative vacuum is itself the greatest policy risk.

SEC No-Action Letter: Canton Coin Classified as a Digital Commodity

During the legislative hiatus, the Canton team chose to directly throw the question back to the regulators: what exactly is this token? The response from the SEC's Division of Corporation Finance was a rare no-action letter. According to the disclosed briefing, the letter clearly categorizes Canton Coin (CC) as a "digital commodity" and emphasizes that its functional design is closely tied to the programmatic operation of the Canton network—issuance, circulation, and destruction are embedded in the network rules. On this premise, the SEC's Division of Corporation Finance stated that when certain specific conditions are met, its staff would not recommend taking enforcement action concerning the programmed issuance of Canton Coin; however, these specific conditions have not been fully disclosed, meaning the external market can only see the conclusion without the full reasoning details.

The phrase "digital commodity" signifies to project teams and agencies that it pulls CC one step away from the most rigorous regulatory track of "suspected securities." If viewed as a security, issuers typically must go through the full registration, disclosure, and intermediary licensing pathways, while digital commodities are more focused on trading rules, market manipulation, and general compliance obligations, resulting in entirely different compliance costs and entry barriers. The issue is that this no-action letter is merely a case-specific, reversible agency guideline; it cannot substitute for the congressional-level CLARITY Act, nor can it automatically replicate a path for other token projects. The true signal being released is the SEC's willingness to try to place some tokens onto the digital commodity track in situations "closely tied to the underlying network's programmatic operation"; yet under the premises of opacity in conditions and the potential for future governments to overturn the guidance, all project teams looking towards Canton Coin can only regard this letter as a mirror, rather than a compliance checklist they can confidently reproduce.

Agency Guidance Filling the Legislative Vacuum: SEC and Others Define Regulatory Boundaries

Canton Coin is just a starting point; it illustrates who is effectively writing the crypto rules in the vacuum created by the stalled CLARITY Act and market structure legislation. Maylea Ma's assessment is straightforward—what will genuinely change the life-and-death lines of projects in the coming years is not the delayed congressional codified law, but rather the enforcement documents, guidance, and no-action letters in the hands of the SEC, CFTC, and the Treasury Department. Michael Ho also points out that with the market structure bill stagnating, U.S. crypto policy becomes locked into these agency guidelines "that can be overturned by future governments," and Congress's absent role is gradually being filled by federal agencies through case enforcement. The SEC handles issuance and trading platforms within the framework of securities law, the CFTC pulls businesses touching derivatives and commodity attributes into its jurisdiction, while the Treasury Department firmly enforces funding flows and identity verification through compliance requirements. Together, these three have pushed the boundaries of "what can be done, where to do it, and how to report" significantly forward, but all of this remains at the document level, rather than legislative enactment.

The problem is that this boundary delineated by enforcement and no-action letters is inherently reversible. Maylea Ma stresses that agency guidance cannot provide stability that will not be reversed with changes in government; Michael Ho also mentions that because these guidelines can be overturned by the next government or court, heavyweight institutional funds choose to remain cautious. Under this path, compliance strategies for U.S. project teams and platforms are forced to adjust: on one hand, they need to redesign licensing routes and product structures around the existing guidelines of the SEC, CFTC, and Treasury Department, breaking down functions such as issuance, matching, and clearing into tracks that are more easily accepted by current rules; on the other hand, they cannot treat any piece of guidance as a "final solution," but must leave room for future rule reversals by increasing disclosures and strengthening compliance risk control. Lighter's achievement of $72.9 billion in monthly trading volume and multimillion-dollar fee income under uncertain circumstances indicates that the market can continue to operate in the gray area; however, in a system led by agencies rather than legislation, all participants must accept one premise: today's compliance path could be redrawn any time following the next election or judicial decision.

Lighter's October $72.9 Billion Trading Volume: Expansion of the Regulatory Gray Zone

The operational data for October disclosed by Lighter pushes this high-frequency platform directly under the regulatory radar: with a total monthly trading volume of $72.9 billion, including $53.8 billion from the core platform and $19.1 billion contributed by Robinhood Chain, the fee revenue amounts to $4.09 million. The briefing does not provide month-on-month or year-on-year comparisons, leaving it uncertain whether this represents acceleration, deceleration, or a sideways movement near a peak. This information gap, in itself, is a strategy—against the backdrop where the U.S. requires "case-by-case determinations" for foreign platforms and on-chain agreements, Lighter uses numbers to prove itself as a real existing infrastructure, yet deliberately offers regulators no easily readable trend data.

Structurally, Lighter ties the "core platform" for high-frequency matching with the on-chain operations of Robinhood Chain, technically and brand-wise straddling the intersection of on-chain agreements and foreign platforms. The current U.S. regulatory landscape is characterized by legislative stagnation, with agencies defining boundaries through case enforcement and no-action letters; platforms like Lighter thrive exactly in the areas where these boundaries have not yet been etched in stone: on one side, it can position itself as merely a matching tool for global liquidity, with Robinhood Chain serving solely as an on-chain settlement layer; on the other hand, if in future cases the SEC, CFTC, or Treasury Department deem similar models as unregistered trading venues, brokerage services, or supervised market infrastructures, the previous $10 billion to even $100 billion monthly transaction volume accumulated by Lighter in the "gray zone" could become subject to inquiries regarding information disclosure, customer classifications, and anti-money laundering and sanctions checks. The current $4.09 million in monthly fees serves as proof of profitability in an uncertain environment, but in a system led by agencies rather than legislation, it could similarly be regarded as a sample to measure "compliance willingness" during future inspections.

Platform Choices in an Agency-Led Era

In the U.S. market, the trifold pattern of being led by case guidance from the SEC, CFTC, and the Treasury Department, the long stagnation of the CLARITY Act and market structure legislation at the congressional level, coupled with platforms like Lighter still reporting high trading volumes and multimillion-dollar monthly fees, has pushed the industry into a position where it must make a statement: continue rolling out business in the gray area or actively reconstruct itself into an infrastructure that can be "understood" by regulatory agencies. Maylea Ma warns that the changes that will genuinely materialize in the coming years will likely still come from agencies; tools like no-action letters will repeatedly construct regulatory outlines in cases like Canton Coin, but these puzzle pieces will invariably be subject to change with government shifts or court rulings, which is also the fundamental reason for what Michael Ho refers to as "institutional funds continuing to wait and see." For project teams and platforms, establishing a presence in the U.S. is no longer a question of "whether there are guidelines," but rather they must simultaneously devise plans for two timelines: on one hand, designing product structures, asset classifications, and disclosure templates according to existing SEC, CFTC, and Treasury guidelines, ready to explain every logical chain link with no-action letters and enforcement precedents; on the other hand, acknowledging that political events like midterm elections may still pull the CLARITY Act or market structure bills back to the negotiating table, and once these bills are pushed forward again, they could very likely enshrine or redraw the borders currently temporarily delineated by agencies in written law, codifying which tokens are viewed as commodities and which business processes must be incorporated into specific regulatory frameworks, while simultaneously altering the leeway between licenses, risk control, and business lines. The $72.9 billion in monthly transactions and the $4.09 million in fees reported by Lighter today under uncertain rules serve not only as a footnote to the risk preferences of the market in the agency-led era, but they also remind all participants entering the U.S. that the real important decision is not whether to comply, but whether to be willing to turn every revenue line and every transaction into a regulatory story that stands scrutiny for a future that could be "locked in" by codified law at any moment.

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