[Aave Labs and Other Organizations Disagree with the Crypto Innovation Council on Crypto Vault Regulation] Aave Labs, the Kamino Foundation, and Veda Tech Labs filed a report with the U.S. Securities and Exchange Commission arguing that non-custodial vaults, under certain structures, do not necessarily constitute co-investment projects or investment companies. The framework proposed by the Crypto Innovation Council, along with Bitwise, Galaxy, and Morpho, emphasizes the degree of control individuals have over investment decisions and assets. Aave Labs and other organizations point out that vault managers who provide paid investment advice on securities may still be subject to investment advisory laws.