We just published Mulana IM’s investor guide to the CLARITY Act following the latest release of Senate Banking substitute draft.
The key takeaway:
committee passage is not the same as enactment. The substitute draft lowers some near-term markup uncertainty, but it also creates a more complex House-Senate reconciliation problem.
Key points from the report:
- Section 404 is now formal Senate text: passive deposit-equivalent stablecoin yield is restricted, but activity and transaction-based rewards survive more broadly than expected.
- The token framework has shifted toward Regulation Crypto, ancillary assets, network tokens, and non-control certification.
- DeFi treatment is more nuanced than a simple “front-end equals intermediary” model. Control is the key regulatory trigger.
- Tokenized money-market funds remain a major beneficiary, but they are no longer the only surviving yield route.
- The real bottleneck is now floor amendments, ethics language, DeFi/software-developer treatment, and House-Senate reconciliation before the July 4 target.
- Even if CLARITY passes, CFTC/SEC rulemaking and capacity constraints could create a 12-24 month implementation gap.
Read the full report here: link
For professional investors only. Not investment, legal, or tax advice.
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