Consensus Check - UNI should fund a political defense organization for decentralized finance

@jamico these are great comments; proposal should not be approved in current form

the urgency is false as every single one of these people already commands millions of dollars through their respective organizations and is already engaged in DeFi lobbying and advocacy…they need to go back and propose a decentralized, non-trust-maximized alternative…

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Actually the project being built by Uniswap Grants right now by Tally, the Tally FailSafe (See above) does exactly what you’re talking about- decentralizes the trust. It works as optimistic execution, but ultimately, it is the token holders who have authority over the spending. That solves the concerns in my opinion.

These are great ideas. Taking a more inclusive and crypto native approach will almost surely help to advance the cause and improve the optics here and with any regulator the group engaged with.

However, most of the concerns raised before have not been addressed.

  1. Why is so much money needed?

As Matt Corva wrote (see below), each major bank disclosed about $3m per year on policy spend. This is a lot of money!

However, each major bank operates a far larger, far more complex business than Uniswap – and faces far more legal and policy issues. They really aren’t comparable businesses. Yet they only spent $3m per year.

Why do we think Uniswap needs to spend so much more to handle a much narrower range of issues?
To put it in perspective, upon a quick search, it looks like each major bank discloses approximately ~3MM in policy spend per year, and that’s what is reported. That’s not to say that the number proposed is correct or incorrect, but just to put real life costs to what otherwise might seem like a big number.

Likewise, as Marvin said, trade association heads are paid more than $2m per year. One example is Robert Cook, the head of FINRA. Another is the current head of SIFMA. Is this the sort of organization we are trying to from?

If so, we probably need a much clearer plan and a large upgrade in talent. The folks who typically take these jobs are former head regulators (Cook was a repeat division head at the SEC) - not young crypto lawyers.

  1. What accountability is there?

As currently written, the proposal simply exits 1m Uni with no strings attached. This is wildly out of line with how budgets work at the bigger banks and how regulatory campaigns are usually undertaken.

For example, when the large US investment banks lobbied to influence the regulations promulgated under Dodd Frank, they typically needed to get approval of quarterly budgets and KPIs. Project managers and often outside consultants were employed to drive the process. If the results didn’t occur, budget would be cut or changed and people would be fired.

Here, what do we have besides a grant of 1m Uni to a small board - without even a clear statement of what success looks like.

How is this OK when it is 10x more money than a typical large bank spends a year on lobbying? Put differently, how do you think Goldman Sachs or Morgan Stanley would evaluate this proposal?

  1. How is this conflict of interest acceptable?

At the same time as I am sympathetic to any lawyer or policy wonk who is fighting for DeFi, this proposal pretty clearly creates significant conflicts of interest for each lawyer involved, as well as HLSBFI. Why are we comfortable with this?

To see this very clearly, suppose that Hayden and 3 of his friends proposed taking 1m Uni from the Treasury to start a DeFi VC fund. They then continued to pitch the project to all of you, and piled on to support it on Twitter.

Then they pushed the issue to a vote and used their influence to exit 1m Uni to a separate fund that they controlled.

Afterwards, they continued to be involved in Uniswap AND to hand out checks from the new VC fund - with no accountability to Uniswap.

Why is this OK?

  1. Do the behaviors of the lawyers who would be on this board actually support their being on this board?

As you probably guessed, my answer is no because of the conflicts of interest. But I actually think it is worse.

None of the responses from the potential board members have addresses the basic issues of accountability, budget size or conflicts. In fact, none provide any evidence why 1m Uni are needed for this effort or how 1m Uni will be spent. Likewise, none lay out any details on organizational structure, oversight, or staffing (beyond that the group will hire one full time employee).

Moreover, may of the responses just seem disingenuous or irrelevant. For example:

If you had to beat, say, the LA Lakers at home … you can’t do it on a $2 million dollar budget. There is no point fielding a team of amateurs that will definitely lose, so you have to go big or go home. The top trade association bosses make over $2M each year (it is pretty sickening but there is often much more at stake, and democracy is better than the alternatives). Many of the most persuasive lawyers who lead teams that win these fights earn more than the average professional athlete. The proposed fund here is actually much too small to hire many of those people, but it could support the hiring of more good, hungry junior talent and a few targeted big hires–

To put it very bluntly, how is this relevant?

And who, then, are the Goldman Sach’s and Morgan Stanley’s of the world hiring for $3m per year? And, who are these partners?

Aren’t they the right comps …, and the Lakers payroll just a side show?


I’m Jake Chervinsky, General Counsel of Compound Labs and one of the proposed committee members for this organization. I strongly support the proposal and I’d like to explain why in as much detail as possible here, as well as address some of the community’s concerns. I’ll start with a summary of my main points and then expand on each; if you have any questions or want me to dig deeper on anything, please ask.


  1. The success of DeFi in general, and Uniswap in particular, depends on how effectively we engage with regulators and policymakers over the next 6 to 18 months. If we fail to act quickly and forcefully, the consequences could be severe.

  2. The proposed committee is well-qualified to manage this program, both in terms of skill and experience with DeFi policy and government affairs, and in terms of commitment to the principles of decentralized governance.

  3. Funding for engagement with regulators and policymakers should come from DeFi protocol treasuries at the discretion of decentralized governance. Uniswap can take lead, but other protocols should join as well.

  4. The proposed funding amount is appropriate given the scope and urgency of the task, especially considering how much money TradFi spends on government affairs, and the fact that centralized crypto companies have no incentive to lobby for DeFi.

  5. Programs like this should always operate at the pleasure of decentralized governance, and those involved should always be accountable to the community. This means we, the committee members, must (and will) prioritize transparency.

About Me

I’m a lawyer based in Washington, D.C. with a background in regulatory compliance and government enforcement defense. I started my career with a multinational firm handling anti-money laundering and anti-corruption matters for Fortune 500 clients. After a federal judicial clerkship, I joined a boutique firm specializing in cross-border dispute resolution and white collar criminal defense. I fell down the crypto rabbit hole in 2017 and represented a number of clients in crypto-related matters involving the SEC, CFTC, and DOJ before joining the industry full-time.

I joined Compound as General Counsel in May 2019 after realizing how DeFi can reshape the global financial system for the better. Since then, I’ve focused all my energy on the legal, regulatory, and policy issues surrounding DeFi. I serve as Chair of the Blockchain Association’s DeFi Working Group and as a Strategic Advisor to Variant Fund. I’m a member of the Uniswap community and I’m personally, deeply committed to the success of DeFi as a whole. Achieving the mission of this program is exactly why I’m here in the first place.

DeFi Regulatory and Political Landscape

In my view, regulatory risk is the single greatest threat to DeFi today. Before this year, DeFi received fairly little attention from the government due to its small size; the industry’s perception was that DeFi was “flying under the radar.” But with success comes scrutiny. After the rise of yield farming, the DeFi bull market, and Uniswap’s appearance in mainstream media, those quiet days are over. Regulators and policymakers worldwide are now watching closely. Although some of them understand the benefits that DeFi offers, many others are skeptical about a decentralized financial system that lacks the intermediaries they regulate.

Initial reactions from some regulators have been discouraging. In the AML/CFT arena, policy changes are now being considered that could significantly harm DeFi. For example, the FATF’s March 2021 draft guidance suggested that governance token holders could qualify as regulated VASPs, or that crypto exchanges could be prohibited from allowing withdrawals to non-custodial wallets. Policymakers are also concerned about the risks posed by stablecoins — a critical piece of the DeFi ecosystem — to monetary sovereignty and financial stability. As time goes on, we can expect to hear more questions and concerns about numerous other subjects as well, including the US federal securities, commodities, and tax laws, to name a few.

It’s crucial that we take the concerns of regulators and policymakers seriously. Like it or not, they have an unparalleled ability to hamstring the growth of DeFi, and if we fail to engage, the most likely outcome is a draconian “regulate first, ask questions later” approach which could set DeFi back by years, if not permanently. Luckily, we still have time. Most regulators and policymakers haven’t made up their minds yet, and in the US, some high-ranking positions are still waiting to be filled. But we can’t wait; now is our best chance to have a meaningful impact on DeFi policy before these decisions are made for us without our input. Time is of the essence.

Proposed Committee and Program Strategy

My fellow proposed committee members are among the smartest, most experienced, and most effective advocates for good DeFi policy in the world. I’ve had the pleasure of working personally with nearly all of them and I have no doubt that they’re the right people to lead this effort. From the feedback I’ve seen, the community seems to agree, so I’ll leave this here.

But what exactly will we do with the funds? Although the decision won’t be up to me alone, and my fellow committee members may have other (better) ideas, here’s generally how I think about our strategy and use of funds:

  • Education. The vast majority of regulators and policymakers don’t yet understand the technical and practical details that distinguish DeFi from TradFi. Without that knowledge, their initial reaction may be to impose the same regulatory obligations on DeFi protocols as they do on centralized financial institutions. In other words, they may mistakenly assume that Uniswap is an “exchange” like any other, implicating all the same risks and requiring all the same regulatory safeguards as Coinbase, et al. That’s wrong. To avoid such an outcome, we need to educate regulators and policymakers on how DeFi works and why its unique properties negate the need for many traditional regulations.

  • Advocacy. We can’t just educate government officials about the greatness of DeFi and then hope they leave us alone. Instead, we need to advocate strongly in favor of policies that support adoption of DeFi protocols and against policies that restrict access to DeFi or create a regulatory moat around entrenched incumbents. Good advocacy is both reactive and proactive; we need to address regulatory developments as they arise and advance our own policy proposals. Good advocacy is also both government-facing and public-facing; we need to engage with regulators and policymakers while also building consensus within the industry and grassroots support from the community.

  • Defense. We need to be prepared to take swift action in case of hostile guidance, rulemaking, legislation, executive orders, enforcement actions, or otherwise. It’s hard to predict in advance what form our defensive efforts might take, and hopefully the need won’t materialize at all. Yet, there’s plenty we can and should do now to prepare for the worst. For example, we could commission legal research on defense theories or constitutional protections that may apply to DeFi. Equally important, it’s a huge benefit to have resources set aside and available to allocate quickly in an emergency.

I anticipate the bulk of this work will involve retaining specialists such as researchers, lawyers, lobbyists, organizers, designers, and consultants, as well as making contributions to other aligned organizations and hiring full-time staff for the 501(c)(4). I understand that hiring lawyers and lobbyists may seem distasteful — in a sense, it goes against the ethos of DeFi, which emphasizes opting out of the legacy power structures that brought us to this point in the first place — but as @Marvin put it, this is “what it takes to win.” I prefer to win.

Funding from Uniswap and Other Protocols

Given the importance of engaging on DeFi policy, I believe this program is a valuable use of Uniswap’s resources and a paramount example of how DeFi communities can achieve off-chain goals without sacrificing the decentralization at their core. Uniswap is especially well-positioned to lead this initiative. The issues and strategy that I outlined above are particularly important for Uniswap as a decentralized exchange protocol that allows users to trade an enormous range of Ethereum-based assets, an activity that’s heavily regulated in the traditional centralized context. Uniswap also has the capacity to fund the program thanks to its substantial treasury.

That said, I appreciate the feedback from some community members that Uniswap shouldn’t be asked to fund the entire program on its own, or all in one shot (more on that below). There’s no question that, to be effective, we will need to engage with regulators and policymakers on behalf of the entire DeFi sector, not just Uniswap. For that reason, although I do believe Uniswap is the right “founding protocol” for this program, my hope is that other DeFi communities will see fit to join the effort and allocate additional funds from their treasuries to the 501(c)(4).

Initial and Total Funding Amounts

As far as I can tell, the point of greatest contention within the community is how much funding the program should receive. In my opinion, the size of the request in this Consensus Check is ultimately appropriate given the magnitude of the task at hand. As @sukernik explained, we aren’t proposing to form a startup that can wait to launch a minimum viable product before seeking additional funding. We’re proposing to form a nonprofit that can meaningfully impact policy on the global stage within the next 6 months.

This mission is an expensive one. There are thousands (literally, thousands) of regulators and policymakers worth engaging around the world today. There’s virtually no amount of money that we couldn’t put to good use immediately. Other industries that have above-average success with government affairs — including TradFi itself — spend hundreds of millions of dollars each year to influence policy in the United States alone. Make no mistake, we are the underdogs. In my view, if protocol treasuries can help us level the playing field, we’re obligated to use them.

It’s particularly important for protocol treasuries to fund DeFi-specific policy efforts because nobody else will. As of now, centralized crypto companies have a tense relationship with DeFi. While they appreciate the role that DeFi tokens played in catalyzing the bull market, they also see DeFi protocols as competitors. These companies aren’t incentivized to, and indeed do not, dedicate resources toward DeFi policy. Coin Center and the Blockchain Association are both fantastic organizations, but neither focuses exclusively on DeFi as the 501(c)(4) would. If this is to be the only DeFi-specific policy organization in the world, we should fund it properly.

However, I also appreciate that 1M UNI is a significant sum, even if only a small fraction of the total treasury, and that some community members aren’t convinced that the full amount should be allocated in a single vote. With that in mind, I wouldn’t object to a smaller initial grant to get the program up and running, with the expectation that we will request additional funds from Uniswap and other protocols when appropriate. Although it may be difficult to measure our progress objectively over short time periods, I trust that the community can understand and evaluate our work in light of that caveat.

Transparency and Accountability

Transparency and accountability are essential to the success of this program and others like it. For many reasons, decentralized governance simply doesn’t work if the governors don’t have equal access to information about the protocol, including how its funds are being used. My goal as a proposed committee member is to provide as much public transparency as possible, to hold myself accountable to the community in the performance of my role, and to hold my fellow committee members to the same high standards.

@Marvin has already outlined the steps we’ll take regarding community updates, budgeting, and more. Personally, I’ll endeavor to make myself available to answer questions and attend community calls as much as possible.


We’re at a challenging time in DeFi’s history. Since last summer, we’ve proved the concept that financial activities more complex than transferring and storing value can be decentralized. As a reward, we’re now a subject of attention for regulators and policymakers worldwide. I strongly support this proposal because I believe it will help us advance good DeFi policy, a goal that is essential to Uniswap’s long-term success and well worth the cost.


Rationale is ok. The amount $40mm is too much. Please give some examples of why we need to have $40mm to be spent on this.


In full support of this proposition. I also second @jonsnow in that $40M may be too much, however I would fully support an initial allocation that would be sufficient to bootstrap the initiative. As progress is made, Uniswap governance can determine how much more should be allocated from the treasury to fund the agenda. Thank you for taking action!

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My name is Grant Gulovsen, an attorney who represents clients in the crypto industry including a few DeFi protocols. I am also a UNI holder. I’m not opposed to the proposal per se but I am concerned that the interests of the committee members (as well as their respective clients) may not align with the interests of “DeFi” as a whole. I therefore would recommend that at least a few more non-lawyers be added to the committee to ensure that broader interests are taken into account.


This seems entirely US centric. Uniswap is decentralized and not subject to a single nation state jurisdiction.


I absolutely agree with providing a smaller initial grant to see how things pan out. This way it wouldnt be too polarizing for the community as a whole because I have a strong feeling a lot of people will NOT want to hold onto their UNI if they know the prices can get absolutely obliterated by passing sell pressure proposals all the time. It will just not be worth the hassle to hold UNI token if you are to fund everything as a holder with massive amounts…

Like one thing that grinds my gears is that people are not discussing the real value of the token and what it might entail for this proposal. 1M UNI is worth 40M now, but what if in 6 months its worth 200M? What if its worth 10M? What will happen in those cases. Will the OP come for another 30M if the token is worth next to nothing in 6 months?? I mean, its ridicilous how nobody is talking about this. This is why we have to provide a smaller amount first, then see if we require more funding.

Blockchain@Columbia supports the overall direction of the proposal though there are numerous changes and specifications that we would like to see in the final proposal for the on chain vote.

  1. We completely agree with @jamico’s points about the rebranding of this to be more educational and non-antagonistic to regulators and lawmakers.
  2. The bylaws of the 501(c) (4) proposal must be included in the on-chain vote that includes provisions such as: the ability of UNI holders to remove/nominate people to the board based off of on-chain votes; consistent schedule of reporting to UNI holders re initiatives, progress, and use of proceeds; and minimum time commitments of board members.
  3. A full-time hire to lead this initiative must be on-board before this vote occurs.
  4. Measurable set of goals and metrics with approximate use of funds and time-line for each.
  5. Specification of amount of funds that will be contingent on other defi “blue-chips” contributing funding to this initiative.

We will be voting for this consensus check as we are looking forward to seeing this alterations to this proposal. If such changes don’t occur then we will be voting against this proposal during the on-chain vote.

The space has become large enough that serious regulatory scrutiny is already occurring and is likely to intensify. Uniswap should take the lead as the preeminent project in the space though not without buy-in from other major projects. Building a positive relationship with informed regulators and legislators is essential to the longevity and success of Uniswap, defi, and crypto in general.


@jchervinsky I think you’ve done great work for DeFi and should be paid accordingly. But let me ask you a serious question -

Why is it OK for the General Counsel of Uniswap and lawyers who worked for Uniswap as their outside counsel OK to be seeking to remove funds from the Treasury to place them in an entity that they control and has no accountability to Uniswap?

How is this not a conflict of interest far beyond what’s permissible in normal corporate law?

@jamico Why don’t you just set up a subsidiary or another entity that is 100% owner by Uniswap token / equity holders, reports to @haydenadams and the board and is funded quarterly by Uniswap?

I am not as silver tongued as many of the lawyers here, but I really can’t figure out why anyone things it makes sense to exit corporate funds to a new entity that has no relationship to Uniswap.

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Same question for you @blockchaincolumbia Why do you support exiting funds from the treasury into a new entity that is not accountable to Uniswap’s board, token holders, etc?

Why not set up a subsidiary or another entity that has a direct reporting line - and is funded periodically - by Uniswap?

Same question for you @lex-node Why would someone support exiting funds from the treasury into a new entity that is not accountable to Uniswap’s board, token holders, etc?

Why not set up a subsidiary or another entity that has a direct reporting line - and is funded periodically - by Uniswap?


Huge supporter of this initiative (with many solid perspectives - on both sides).

A quick comment on the amount > in the grand scheme the $40M price tag is inconsequential to the overall treasury. There should be checks and balances to that; a smaller grant may indeed provide a bit more comfort. But in the end, the focus on the amount vs. the justification of the activity is probably an inconsequential debate. Big swings will need to be taken for future evolution; this is one of them.


Dear Colleague
Everyone here has agreed that DeFi needs an organized effort to “educate” lawmakers and governments (not just one Government) about DeFi, in a manner that will prevent overregulation and protect the DeFi ecosystems. Education might be a smarter way to put it, given that lobbying may not be a tax deductible activity (however, if lobbying is underneath education, then it may be considered what it is and not what it proclaims).
From what can be understood, in response to the well-founded fear that if things are left to their own fate, there may be a crackdown or overregulation or bad regulation of DeFi, it has been proposed here that a US-based non profit is created, with a fixed committee as BD, in which, if this is voted, you will participate. It has been explained that since the US is an important country for the “fate” of DeFi, the efforts are going to be concentrated in the US. To that end, a 1M Uni fund will be “set aside” (sic) for “educative” plans and, in fact, for lobbying and precautionary activities, including -but not necessarily- legal ones. The time-frame of spending the sum and achieving the goals (which remain to be further clarified) is 4-5 years. For other members, the first results would need 2 years to be seen. For you, it would take about 6 months for the first tangible results to become visible and able to be assessed. However, you also admit that “it may be difficult to measure our progress objectively over short time periods”.
There is no breakdown of the proposed non-profit’s activities meaningfully presented. The best effort so far is contained in your above post. Also. No “sample statute” of such a non profit has been uploaded, so that it becomes more clear what kind of provisions you have in mind, in regard to governance, decision making, transparency and accountability. So, up to this point, those of us who follow with interest this discussion, have to guess. A lot of issues are in this manner evading the realm of actual scrutiny
This lack of clarity on the part of the proposal, in regard to critical aspects of the project, still rigidly undermine the discussion.
You say [quote=“jchervinsky, post:71, topic:12700”]
Transparency and accountability are essential to the success of this program and others like it. … My goal as a proposed committee member is to provide as much public transparency as possible, to hold myself accountable to the community in the performance of my role, and to hold my fellow committee members to the same high standards.

-“how much transparency is possible”? (or, let me put it differently: how much transparency is “not possible”?). You saying “as much transparency as possible” implies that at least “some” transparency is not possible.
-nothing clear has been said about “transparency and accountability” -how, specifically, do you intend to guarantee it?
-what are the “same high standards” that you and the other (proposed) committee members will be bound by?

Another issue is that you also do not address the concern of many that the amounts requested are outrageously high. Statements such as “this mission is an expensive one” and that “other industries spend hundreds of millions each year to influence policy” are not sufficient. The fact that the proposal explicitly stated that it indents to influence US policy (which many did not agree with, given the nature of DeFi) contradicts the statement that “there are thousands of regulators and policymakers worth engaging around the world today”. While I would of course agree with the latter, as I have stated in other comments above, the discrepancy between the launching goals and the extension of the scope of the proposed Committee’s work and funding (from US to global, that is, almost 200 times wider) might create an ambiance of distrust. It is, again, crucial that you define the project better. Because, if 1M is seen as a lot for influencing regulation in the US, it may seem for working, in parallel, in 200 jurisdictions. Noone would object if 5.000 UNI were used to influence lawmakers in a country. But 1M just for the US has aroused the objection reflexes in many.

Many other concerns have not been addressed. Such as why the proposed committee cannot have a strong consultative role. Why it has to play the intermediary in the allocation of funds, alienating them from Uniswap’s treasury even before the action to be taken becomes concrete.
Also, whether the BD will be porous or “closed”. Transparency and Accountability issues.
How to keep a decentralized character in it. The “representative of DeFi” role is also very concerning.
It is also not easy to see why putting aside 1M uni to a non profit is “what it takes to win”. Is it because someone said so?
Also, tax concerns have not been answered. If giving these funds to a non profit may endanger seeing up to 35% of these sums end up in the Government’s treasury in the form of taxes, which could be averted if Uniswap paid who the Committee suggested it should pay, then why on earth would a non profit need to play the role of distributor of funds? Have you ensured that a huge sum of UNI will not end up being used in taxes, via the materialization of this proposal?

It should most probably be considered a given that everyone here wants to see DeFi protected and thrive. As I see it, instead of struggling to achieve regulation -while there is no consensus that there must be any at this infant stage of DeFi- that will be time-sensitive and can be subjected to change (therefore needing a constant outflow of funds -theoretically to infinity- to “stay DeFi friendly”), the true protection of this field is ultimately a question of preparing to set the red lines about how far governments -all governments- can go in regulating our economic freedom and our rights, including and primarily our participatory rights. I believe some experts in fields related to the latter should be part of the proposed Committee.

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Good post, thanks for writing Jake. This is exactly the type of explanation I think is valuable to include in a proposal like this from the get go. In particular, I’m glad you enumerated some of the specific legal threats you expect to see in the next 6-12 months and injected some of your knowledge about the legal landscape here.

In terms of planning and budgeting, I think it would be helpful to enumerate even more of the specific legal issues this group expects DeFi to encounter over the next year. In tandem, it would be helpful to outline an expected budget to be spent fighting for each specific issue. If we plan to encounter, for example, a ban on sending tokens from exchanges to non-custodial wallets, then what does this group think is required to fight against it? What would it cost to hire lawyers, consultants, etc. to sufficiently defend against this issue? For other expected issues? This kind of outline, though it obviously won’t be perfect, would make me feel much more confident in this proposal.

Aside from that, my biggest remaining concerns are the all-at-once allocation of capital and the lack of a full-time hire responsible for administrative overhead. If this group committed to a full-time hire and started with an initial allocation of capital to cover the first 6-12 months of operation, I’d probably be in support. Without all of those changes, I’m still firmly against, though I think all of your reasoning behind this group’s motivations is spot-on.

it would solve the concerns but this group has zero apparent interest in using that type of tool and being accountable in that way

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If this purpose and the related duties are the key (sole?) protection that UNI holders have, then why isn’t the purpose being explicitly defined in advance as part of draft charter documents for the non-profit? Why “give us the money first then we’ll figure everything else out–don’t worry, you’ll be protected”? How can you appeal to the fact that ‘we’ll have a purpose and be accountable for it’ but not define that purpose exactly as part of the proposal?


Can you explain why you have not been transparent in your other lobbying efforts and why the community should expect something different now?

Marc Boiron is head of Blockchain Association DeFi group. If Blockchain Association has not allowed transparency and collaboration with the public through now, why would they start allowing it? How will those of you with ties to multiple organizations square your duties to be ‘zealous advocates’ for those specific organizations with a duty to work in the interests of DeFi in general? Will you recuse yourself every time the interests or rules and policies of your specific organizations conflict with those of DeFi in general?

What if a regulator or legislator would make a compromise for projects that are not backed by VCs but maintains that VC-backed projects too closely mirror the traditional IPO path and must be regulated more stringently? Will you accept the compromise for the good of DeFi even though you represent multiple VC-backed projects and are ‘special advisor’ to a VC?

What about if a regulator points out the power and influence of Uniswap Corporation over the DAO and suggests that regulation could be lighter if the DAO had lower quorum requirements or if the Uniswap Corporation were dissolved? How will you decide whether it is ‘possible’ to disclose this information to the DAO? What about the GC of Uniswap Corporation–he will have a huge conflict of interest in this scenario, won’t he?

Since nearly all information you receive from and send to regulators and legislators will impact your legal clients, how is it possible that such information will not be subject to atty-client confidentiality duties and that you can share it publicly? How will you separate your advocacy efforts as part of this nonprofit purporting to represent all of DeFi from your advocacy efforts for your specific clients? Is your assumption that DeFi projects are so incentive-aligned that advocating ‘for DeFi’ is the same as advocating ‘for Compound’, even though there may be many distinctions between various DeFi projects and Compound on any number of issues? If you agree that there can be conflicts, how will that be navigated considering that you, Rebecca and Marc are all extrinsically affiliated through current and past organizations/relationships? Won’t you inevitably be biased toward defending structures and situations that you have previously supported and thus reducing your own potential for liability, rather than admitting to the potential legal flaws with those and working toward new creative compromises with regulators?

What does transparency mean to you? Many have asked empirical questions about the origins and motives for this proposal that have not been answered. Is that something it’s ‘impossible’ for the proposers to be transparent about?

Would you submit draft legislation to the DAO for review/comment before it is submitted to a congressional committee? What about draft no-action letters?

If you were coordinating with specific projects or leaders in DeFi regarding a specific issue, would you disclose that? Will the CEOs of Compound, Uniswap and Aaave have more access to the information and decisionmaking of this non-profit than the core devs of Sushiswap and Yearn?

To what extent is this proposal being supported by VCs and team members who may face personal liability regarding their choices? and don’t they have a conflict of interest re: their support, since otherwise they would have to spend (more of) their personal funds on defense?

These are critical kinds of questions that you guys are sweeping under the rug.


While I really like this proposal, I’m personally against creating a legal non-profit (to hold the funds) to do it.

This should be a crypto-native construct, answerable to the DAO token holders.

I understand doing this as a DAO, rather than a non-profit would be hard to do, but if thats the case: then those are the challenges this legal defense fund should solve first.

I get the value of creating an organization that lobbies in the defense of crypto/DeFi/etc in general, but I am a practical person, and I would rather see the legal energy go first into creating the structures by which future legal defense funds can successfully operate. Let us dog-food the future first.

EDIT: I would support some sort of compromise here as well. I think it’s more important to get something like this to happen, so I am open to compromise.