The Hippocratic oath, "first do no harm," might have some relevance here. In the absence of an identified material problem, and in the face of opposition from both buy-side and sell-side, it is not easy to see the reason for the amendment. That, of course, leaves aside a fundamental question as to whether the amendment is consistent with the statute, a question that does not provide an easy "yes."  

FINRA has had this proposal under study for a considerable period and has been testing various reporting requirements. Some version of the rule likely will be adopted. Firms should consider this concept proposal and carefully review both the substantive and the reporting requirements.  

The testimony highlights the complexity of the issues involved in the development of the digital asset ecosystem, and underscores how delinquent the regulators have been to date in failing to meet the challenge. These are not issues that will be quickly resolved.  

More important as a practical matter than whether the DAO is a "person," the CFTC's statement emphasized that the controlling individuals of the DAO were liable for its debts.