Issue: Does the SEC’s new proposal impact the crypto ecosystem? Short answer: Most likely, yes, if the assets being traded are deemed securities and orders are accepted on a non-discretionary basis. What happened: The SEC proposed an amendment to the Exchange Act Rule 3b-16 that would eliminate the current exemption in Regulation ATS that excludes “systems that merely route orders to other facilities for execution” from registering as an Alternative Trading System (ATS). The