U.S. SEC Commissioner Hester Peirce releases regulatory statement on crypto vaults and on-chain lending: a triple-judgment framework of the Howey Test, Investment Company Act, and Investment Advisers Act.
On July 22, 2026, SEC Commissioner Hester Peirce issued a formal statement, systematically outlining for the first time the boundaries of federal securities law application for crypto vaults and on-chain lending strategies. The core criterion is that if a vault's return strategy, asset allocation, and risk control parameters are determined by a specific party, it may constitute an investment contract, an investment company, or securitized notes. The statement cites multiple legal frameworks, including the Howey Test, the Reves Notes Case, and the Investment Company Act of 1940, and welcomes practitioners to proactively communicate compliance pathways.