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Five takeaways from the release of a much-awaited crypto market structure bill

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The U.S. Capitol is shown the morning after the Senate passed legislation to reopen the federal government on Nov. 11, 2025 on Capitol Hill in Washington, DC.

Win McNamee | Getty Images

The Senate Agriculture Committee has released a draft of its portion of a much-awaited digital assets market structure bill — a critical step toward accelerating institutional and retail adoption of cryptocurrencies. 

Unveiled on Monday by Agriculture Chair John Boozman, R-Ark., and Sen. Cory Booker, D-N.J., the bipartisan discussion draft lays the groundwork for creating guardrails for the crypto industry in the U.S. It also establishes guidelines for institutions that want to work with digital assets, from bitcoin and ether to tokenized financial instruments.

“This is the most consequential roadmap for how an institution is going to integrate digital assets into their business,” Cody Carbone, CEO of crypto trade association Digital Chamber, told CNBC. “It’s like the best possible step-by-step of what type of compliance rules requirements they would need to follow to work with crypto.”

Here are five key takeaways from the discussion draft.

1. Grants favorable regulatory status to some cryptocurrencies

The text classifies some of the largest digital assets by market capitalization such as bitcoin and ether as “digital commodities,” placing them under the Commodity Futures Trading Commission’s purview.  

This provision removes a major blocker to digital asset adoption for institutional fiduciaries, Juan Leon, an analyst at crypto-focused asset manager Bitwise, told CNBC.

“Compliance and risk departments will finally have a federal statute to point to,” Leon said. “This shifts the internal conversation … [and] it provides the legal certainty required to move assets into a formal, strategic allocation.”

It will also create “a starkly bifurcated market” consisting of regulated and unregulated tokens, with the former class of assets seeing “a massive influx of institutional capital, deep liquidity and a robust derivatives ecosystem.”

2. Requires crypto firms to segregate funds and manage conflicts of interest

The draft calls for crypto companies to “establish governance, personnel, and financial resource separation among affiliated entities that perform distinct regulated functions.”

Bitwise’s Leon interprets the provision as a challenge to the “all-in-one” business model that is common among crypto exchanges. According to those models, an exchange, broker, custodian, and proprietary trading desk are all wrapped up into one entity. 

In other words, digital asset firms could be required to keep their various businesses separated like traditional financial companies, according to Leon. The change would serve as “a foundational pillar for institutional adoption.”

3. Gives the CFTC more power to regulate digital assets 

The text gives more power to the CFTC, empowering it to work in tandem with the Securities and Exchange Commission to issue joint rulemaking on crypto-related matters.

“There’s a lot more power or authority delegated to the CFTC to have jurisdiction over this industry,” Carbone said. 

The shift comes after the SEC for years served as the main regulator of digital assets, after it edged out the CFTC to gain authority over the industry. 

4. Allows the CFTC to collect fees

The draft calls for regulated entities to pay fees to the CFTC. Those fees would go toward registering digital commodity exchanges, brokers and dealers, in addition to conducting oversight of regulated entities and carrying out education and outreach. 

5. Establishes listing standards for tokens

The text calls for crypto exchanges to only permit trading of digital commodities that are “not readily susceptible to manipulation.”

It’s a provision that could reduce the number of “rug pulls” and other scams that are still common in some parts of the crypto industry, with the goal of establishing standards and building confidence in the market.

What’s next?

The Senate Agriculture Committee’s discussion draft is far from final, but it does offer critical insights into the direction of efforts to pass crypto-friendly regulations in the U.S., according to Carbone.

“It’s not final, it’s not done, but this gives a good sense of where Congress is going and what the final rules may be,” Carbone said. 

The committee will likely spend the next few weeks getting feedback on their draft, meaning it may be “almost impossible to get [a final version of this part of the bill] done by the end of the year,” he added.

However, that period will give lawmakers time to offer more concrete guidance on several issues that are bracketed – or not yet finalized – in the discussion draft. Those include provisions on anti-money laundering rules and regulations specific to decentralized finance players.

Several crypto players plan to work in tandem with lawmakers to help iron out those details, among others. 

“We’ve long said crypto is a bipartisan issue, and this draft from Chairman Boozman and Senator Booker reflects that,” Moonpay President Keith Grossman told CNBC. “It’s critical that legislation distinguishes between centralized intermediaries and decentralized systems, and we look forward to working with the Committee to get it right.”

The discussion draft is only one piece of larger legislative efforts to overhaul regulations for the crypto industry, according to Carbone. Ultimately, the text will be combined with the Senate Banking Committee’s draft on the digital assets market structure in a bid to create one comprehensive bill.

And although lawmakers are nowhere near the finish line in that process, crypto firms are finding other ways to work with regulators and other authorities to meaningfully advance their industry, Grayscale Investments Chief Legal Officer Craig Salm told CNBC.

“In the absence of comprehensive legislation, we’ve still seen meaningful progress on the regulatory front,” Salm said, adding that the SEC, Internal Revenue Service and Treasury Department have recently provided guidance around staking in crypto exchange-traded products. “That said, thoughtful legislation will be critical to solidifying the foundation of the digital asset industry in the U.S. and unlocking even greater value for investors and consumers.”

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Private Credit Expansion and Regulatory Oversight in 2026 Capital Markets

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The global private credit market has solidified its role as a fundamental pillar of enterprise finance, expanding rapidly across middle-market lending, asset-backed finance, and infrastructure financing. As non-bank financial institutions capture a larger share of corporate debt origination, global regulatory bodies are increasing oversight to evaluate market transparency and systemic risk interconnections.

Growth Drivers in Direct Lending
Direct lending platforms have continued to attract substantial institutional allocations from pension funds, sovereign wealth entities, and insurance companies seeking attractive risk-adjusted yields. Private debt funds offer corporate borrowers customized financing structures, faster execution timelines, and confidentiality compared to syndicated loan markets.

In 2026, private credit managers are increasingly financing larger corporate transactions, providing multi-billion-dollar credit facilities for buyout deals and corporate restructurings. The flexibility of private debt contracts—featuring unitranche pricing and tailored covenant packages—has made direct lending the preferred capital source for middle-market enterprise sponsors.

Regulatory Scrutiny and Systemic Risk Assessment
The rapid growth of non-bank intermediation has drawn heightened scrutiny from financial regulators in North America and Europe. Because private debt agreements are negotiated privately without public exchange disclosures, central banks are evaluating potential vulnerabilities related to asset valuation consistency and fund liquidity profiles.

Regulatory agencies are introducing guidelines aimed at improving reporting standards for private investment vehicles managing institutional assets. Key focus areas include monitoring leverage ratios within private credit funds and evaluating indirect credit exposures between commercial banking institutions and private debt funds.

Navigating Elevated Refinancing Costs
With benchmark interest rates remaining elevated, private debt borrowers face higher debt service obligations on floating-rate credit facilities. Financial advisory firms report an increase in proactive liability management strategies, including payment-in-kind (PIK) interest options, equity infusions from sponsors, and covenant modifications.

Private credit managers with deep operational capabilities are actively working alongside portfolio companies to optimize working capital and maintain cash flow coverage ratios during periods of higher borrowing costs.

Key Financial Takeaways
1. Mainstream Asset Class: Private credit has expanded beyond niche alternative asset status into a core corporate finance solution.
2. Enhanced Transparency Standards: Regulatory frameworks are evolving toward greater disclosure requirements for private debt managers.
3. Proactive Risk Management: Lenders and sponsors must prioritize debt sustainability and active portfolio monitoring amid high benchmark rates.

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Venture Capital and Startup Valuations in 2026: Focus on Unit Economics and Sustainable Growth

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The global venture capital (VC) ecosystem is operating under a disciplined investment framework in 2026. Following years of valuation adjustments and shifting liquidity environments, venture capital firms and private equity investors are prioritizing proven unit economics, positive cash flow pathways, and capital efficiency over rapid, unconstrained user acquisition.

The Shift Toward Disciplined Startup Valuations
Early-stage and growth-stage startup valuations have stabilized at sustainable historical averages. Venture capital partners are conducting rigorous due diligence processes before deploying capital, scrutinizing gross margins, customer acquisition costs (CAC), net revenue retention (NRR), and lifetime value (LTV) metrics.

While total capital deployed remains robust, seed and Series A funding rounds are taking longer to finalize. Founders are expected to demonstrate clear product-market fit and defensible intellectual property rather than relying on top-line revenue projections unsupported by strong underlying economics.

M&A Activity and Liquidity Solutions
The market for venture-backed exits is seeing renewed momentum through strategic mergers and acquisitions (M&A) and secondary market liquidity facilities. Established corporate enterprises are acquiring high-performing technology startups to integrate proprietary artificial intelligence models and specialized software solutions into their product ecosystems.

Simultaneously, secondary market transactions have become an essential liquidity mechanism for early employees and institutional investors. Specialized secondary funds are purchasing pre-IPO shares at discounted valuations, providing liquidity opportunities while companies remain private for longer durations.

Sector Allocation: Deep Tech, Clean Energy, and Enterprise Automation
Venture capital investment is heavily concentrated in deep technology and capital-intensive engineering sectors. High-growth investment themes include:
– Next-Generation Semiconductors: Hardware startups designing specialized AI processors and energy-efficient microchip architectures.
– Clean Technology: Battery chemistry innovations, carbon capture solutions, and grid-scale energy storage startups.
– Enterprise Process Automation: Software platforms that automate complex workflows in healthcare, financial services, and industrial logistics.

Key Insights for Entrepreneurs and Investors
1. Prioritize Capital Efficiency: Startups focused on achieving operational profitability receive higher valuation premiums from institutional investors.
2. Strategic Exit Planning: Corporate M&A is serving as a primary exit route for venture-backed startups navigating prolonged IPO windows.
3. Focus on High-Moat Technologies: Deep tech and proprietary software architectures are securing the majority of growth-stage capital allocations.

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The Evolution of Digital Payments: Cross-Border Settlement and Central Bank Digital Currencies in 2026

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The infrastructure supporting global commerce is undergoing a major technological upgrade as real-time digital payment rails, cross-border settlement solutions, and Central Bank Digital Currency (CBDC) pilot programs achieve widespread commercial adoption. Financial institutions and fintech developers are reimagining payment processing to eliminate friction, lower transaction fees, and accelerate settlement speed.

Transforming Cross-Border Settlement Infrastructure
For decades, international corporate payments relied on legacy correspondent banking networks characterized by multi-day settlement delays, opaque fee structures, and high foreign exchange markups. In 2026, modern cross-border payment networks are enabling near-instantaneous settlement for international trade transactions.

Financial technology platforms are leveraging distributed ledger technology and real-time gross settlement (RTGS) interconnections to settle transactions in seconds. International trade participants benefit from reduced working capital requirements and minimized foreign exchange volatility risks during cross-border transfers.

Commercial Expansion of Central Bank Digital Currencies
Central banks representing major global economies are advancing CBDC initiatives from research phases into active commercial deployment. Wholesale CBDCs—designed specifically for interbank settlement and financial institution clearing—are demonstrating substantial efficiency gains in domestic and international transactions.

At the retail level, several nations have introduced public digital currency options alongside existing commercial banking networks. These sovereign digital payment channels aim to expand financial inclusion, lower consumer transaction fees, and improve the efficiency of government-to-citizen financial disbursements.

Open Banking and Embedded Finance Ecosystems
Alongside settlement infrastructure upgrades, open banking regulations and embedded finance frameworks are transforming merchant-consumer interactions. Commercial businesses across retail, travel, and business-to-business (B2B) services are integrating seamless payment APIs directly into their customer software interfaces.

Through open banking frameworks, consumers can initiate secure bank-to-bank payments without relying on traditional credit card networks, significantly reducing merchant processing fees. Integrated Buy-Now-Pay-Later (BNPL) options and point-of-sale credit facilities continue to expand, driving higher conversion rates for digital commerce platforms.

Strategic Financial Takeaways
1. Treasury Optimization: Corporate treasurers should leverage instant cross-border payment platforms to minimize liquidity buffers and foreign exchange exposure.
2. CBDC Integration: Financial institutions must prepare internal core banking systems to interface with emerging wholesale CBDC payment rails.
3. Merchant Fee Reduction: Enterprise merchants can lower payment processing overhead by adopting account-to-account (A2A) open banking checkout solutions.

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