BRAEDEN ANDERSON
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We provide authoritative analysis on securities and commodities regulation, SEC and FINRA enforcement, and legal developments affecting crypto, digital assets, fintech, and financial services, authored by Braeden Anderson.
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Code Without a License? The SEC Signals a Path for Crypto Interfaces Outside Broker Registration
The SEC has drawn a new line between software and securities intermediaries. This analysis examines the implications for DeFi interfaces, transaction-based fees, and evolving market structure.
The SEC’s Bail-In Position Prioritizes Function Over Formalism
The SEC’s no-action letter to the Bank of England signals a shift in how U.S. securities law applies to cross-border bank resolution. By allowing reliance on Section 3(a)(9) in bail-in scenarios, the SEC is prioritizing market stability over formal registration requirements. Chairman Paul Atkins’ call for broader rulemaking suggests a potential exemption for securities issued during regulatory bail-ins. This development has significant implications for asset managers, broker-dealers, and institutions with exposure to foreign banks. It reflects a more pragmatic approach to global financial regulation and highlights the tension between investor protection and systemic stability in crisis scenarios.
Is Avalanche a Security?
Avalanche sits at the center of the SEC’s evolving crypto framework, and as a securities law nerd, this is the kind of debate I genuinely enjoy. With the agency’s 2026 interpretation recognizing “digital commodities” and Ava Labs advancing a functional, infrastructure-first approach, the analysis is becoming more precise. This piece explores whether AVAX fits within securities law, how the SEC’s latest guidance reshapes the landscape, and where automation, liability, and real-world network activity still leave meaningful open questions.
Rule 15c2-11 and the Cost of Regulatory Drift
The SEC’s proposed amendments to Rule 15c2-11 mark a long-overdue correction to years of regulatory uncertainty affecting fixed-income markets. By narrowing the rule’s scope to equity securities, the Commission is realigning its application with market reality and prior intent. This article breaks down what went wrong, why it matters, and what the proposal signals for future rulemaking and regulatory discipline.
The SEC’s New Enforcement Manual Signals a Procedural Reset in Securities Enforcement
On February 24, 2026, the SEC’s Division of Enforcement published a revised Enforcement Manual. This article is a clean-room, original discussion of the press release and the 2026 Enforcement Manual. It is also meant to sit naturally inside the enforcement “throughline” I have been building on Anderson Insights: the idea that enforcement outcomes are increasingly driven by (i) data and surveillance sophistication, (ii) procedural architecture, and (iii) the downstream consequences of resolutions, often more than the headline penalty itself.