Crypto Accountability Requirements Lacking in CLARITY Act

I’m writing to urge you not to support the Digital Asset Market Clarity (CLARITY) Act, H.R. 3633, when it comes before the Senate unless the bill is amended to address several critical concerns. While I understand the goal of bringing greater clarity to crypto regulation, the current approach risks creating harmful gaps in investor protection and market integrity. First, the bill should not rely too heavily on functional or maturity-based classifications that can be manipulated through corporate structuring or product design. If regulatory treatment can shift based on technical framing rather than underlying economic reality, investors will continue to face uncertainty and unequal protections. Second, any jurisdictional split between the SEC and the CFTC must be paired with robust, enforceable consumer safeguards. I’m concerned that a “clearer” framework could still leave retail investors exposed—particularly regarding custody, disclosure, marketing practices, conflicts of interest, and access to dispute resolution. The Senate should ensure that retail-facing activity is subject to consistent baseline protections regardless of how a token is categorized. Third, the bill should strengthen oversight of intermediaries and market participants, including trading venues, brokers, and custodial services. Crypto markets are especially vulnerable to fraud, manipulation, and misleading conduct. Clear rules should explicitly address market integrity, including prevention of wash trading, insider dealing, and coordinated price manipulation, with meaningful penalties for violations. Fourth, the bill needs clearer treatment of stablecoins and DeFi. Stablecoins can affect payments and broader financial stability, while DeFi introduces unique risks around governance, control, and accountability. Without specific standards for reserves, redemption rights, auditing, and responsibility for protocol-affecting actors, the bill may institutionalize regulatory ambiguity rather than eliminate it. Finally, I ask that you require transparent implementation timelines, measurable compliance standards, and adequate resources for enforcement agencies. If the bill becomes law without these guardrails, the public will bear the cost of confusion. I respectfully request that you vote against the CLARITY Act unless these issues are addressed through amendments that deliver real investor protection, market integrity, and accountability.