Bybit

Regulatory status for this October 15, 2026 analysis: The SEC’s controversial Staff Accounting Bulletin No. 121 (SAB 121), which required entities safeguarding crypto-assets for platform users to recognize an on-balance-sheet liability and matching asset at fair value, was formally rescinded by the SEC’s Office of the Chief Accountant on January 23, 2025 through Staff Accounting Bulletin No. 122 (SAB 122). Combined with the Office of the Comptroller of the Currency (OCC) Interpretive Letter 1183, prudentially regulated US financial institutions have transitioned back to standard off-balance-sheet fiduciary custody accounting. This analysis outlines the legal mechanics, capital relief, institutional ETF diversification, and ongoing tax implications for market participants. ...

Regulatory status for this October 14, 2026 analysis: The SEC’s 2022 exchange-definition proposal, supplemented in 2023, was withdrawn in June 2025. Its proposed expansion to communication protocol systems did not become an operative amendment. The title and description refer to that historical regulatory theory and its architectural implications, rather than an effective 2026 registration mandate. The Federal Register withdrawal notice is the controlling starting point. Executive summary: an abandoned expansion with lasting architectural significance The central issue in the Rule 3b-16 controversy was whether a system facilitating securities transactions should face exchange regulation even when it neither maintains a conventional order book nor holds customer assets. That question matters to decentralized exchanges, or DEXs, because transaction execution can be distributed across a website, routing software, autonomous contracts, governance participants, and independently supplied liquidity. ...