Back to collectionKamino, Veda and Aave Publish a DeFi Securities-Law Framework
The paper argues that legal treatment should follow actual rights and control, while limiting its conclusions to specified protocol and vault designs.
Kamino Foundation, Veda Tech Labs and Aave Labs published a public summary of legal analysis submitted to the SEC on October 26. The paper argues that direct participation in the decentralized lending protocols and non-custodial vaults it describes does not create a note or investment contract, and that the analyzed vaults are not investment companies. It separately says compensated curators may fall under the Investment Advisers Act while lacking custody when code prevents them from taking or redirecting user assets. These are the authors’ legal conclusions, not an SEC rule or approval; different promises, control rights, withdrawal limits or structures could change the analysis.