On-chain treasury infrastructure Veda, in collaboration with Aave and Kamino, submitted a legal framework to the SEC

On November 3, Veda, an on-chain treasury infrastructure provider, announced that Veda, Aave Labs, and Kamino Foundation released a public summary of a legal framework discussing how U.S. federal securities laws apply to decentralized lending protocols and non-custodial treasuries. Veda stated that the framework addresses how securities laws should apply when financial activities traditionally performed by intermediaries are executed by smart contracts, and ownership, control, and decision-making are decentralized among different participants. The three parties submitted a more detailed version to the U.S. Securities and Exchange Commission (SEC) on October 26 and requested to communicate with the commission's staff. Aave Labs clarified that the detailed version was submitted to the SEC's crypto working group and corporate finance department, and requested a meeting with the staff, with the complete submitted documents remaining confidential.

Veda stated: Securities regulation should follow the rights, obligations, and powers that are actually formed by arrangements, including who owns the assets, who bears the obligations, who exercises the authority, and whose economic outcomes are affected. Common infrastructure, receipt tokens, or discretionary service providers cannot unilaterally decide the above issues. The document analyzes against the Howey investment contract standard, Reves note standard, the Investment Company Act of 1940, and the Investment Advisers Act of 1940, and concludes that the analyzed agreements and treasury arrangements do not constitute investment contracts or notes, and the described treasury does not constitute an investment company, nor does the discretionary investment compensation necessarily constitute custody of client assets.

Veda also stated that these conclusions depend on the specific structure, contractual arrangements, and distribution of rights and powers described in the document; if the ownership structure, repayment commitments, discretionary powers, or redemption restrictions differ, the legal analysis may also change. This submission did not request the SEC to establish exemptions, safe harbors, or specialized regulatory regimes for decentralized finance, but rather to apply existing securities laws and ask the commission to confirm that the law has distinguished between activities such as issuance, investment management, and custody. The blog post noted that the content is for informational reference only and does not constitute legal advice, and the SEC has not endorsed the conclusions of the document. According to publicly available information from RootData and Veda, Veda was established in 2024 and completed an $18 million financing round led by CoinFund in June 2025.