What changed in v.1:This is v.1 of the living research paper, assembled fresh from nine initial findings spanning narrative infrastructure, lobbying networks, legislative text analysis, pre-positioning patterns, beneficiary identification, revolving-door disclosures, and enforcement posture. The paper establishes the core documentary record: overlapping lobbying firms representing Coinbase and Circle on FIT21, Coin Center's $12.9M war chest and $800K executive compensation, Cedar Innovation Foundation's emergence as a new narrative actor, FIT21's decentralization certification mechanism as a potential Howey Test bypass, and CFTC's parallel jurisdictional expansion through litigation. Key gaps — donor identities, meeting logs, and the full legislative history — are flagged explicitly in the 'What We Still Don't Know' section.
Crypto and Digital Asset Regulation: Market-Structure Decisions Before Full Public Debate
MOBILIZR Living Research Paper — v.1 All claims are record-attributed. This paper surfaces what public records indicate; it does not certify truth or assign intent.
What the Record So Far Points To
Public filings, lobbying disclosures, legislative texts, and nonprofit records collectively point to a well-resourced, multi-layered effort to shape U.S. digital-asset market-structure and stablecoin policy before broad public deliberation has concluded. The documentary record indicates that a small cluster of firms — led by Coinbase and Circle Internet Financial — retained overlapping lobbying shops, coordinated through trade associations, and benefited from narrative infrastructure funded through 501(c)(4) organizations whose donor lists are not publicly disclosed. The legislative centerpiece, H.R. 4763 (FIT21), contains statutory language that records suggest mirrors long-standing industry advocacy goals: a self-executing decentralization test that, if met, routes digital assets away from SEC securities oversight and toward the CFTC. Enforcement records at the CFTC simultaneously point to an agency using litigation to expand its jurisdictional footprint. The record is silent on several critical questions — including the full donor base behind key nonprofits and the precise meeting logs between industry and committee staff — that would be necessary to assess the full scope of access and influence.
I. The Legislative Text: What H.R. 4763 (FIT21) Actually Says
H.R. 4763, the Financial Innovation and Technology for the 21st Century Act, passed the House in the 118th Congress. Its text introduces a statutory mechanism requiring the SEC to certify whether a digital asset network meets specific criteria for "decentralization" — including thresholds related to control, voting power, and development activity [step:5095acb2]. If the SEC certifies a network as sufficiently decentralized, the asset transitions to CFTC oversight as a "digital commodity" rather than remaining under SEC jurisdiction as a security [step:5095acb2].
The documentary record points to this as a significant structural departure from existing securities law. The traditional Howey Test — the judicial standard for determining whether an asset is a security — is a facts-and-circumstances analysis applied case by case. FIT21's decentralization certification mechanism, by contrast, creates a statutory pathway that, records suggest, functions as a self-executing override of that standard [step:5095acb2]. House Financial Services Committee Chairman McHenry's public remarks, as reflected in committee press releases, indicate that opposition to SEC Staff Accounting Bulletin 121 (SAB 121) was used as a narrative anchor to build bipartisan support for the broader jurisdictional shift [step:5095acb2].
The House Report accompanying FIT21 (H. Rept. 118-484) has not been fully extracted in text-searchable form in the current record, and automated access controls at SEC.gov have limited retrieval of the formal SEC statement on the bill [step:38580358]. The record is therefore currently silent on the precise enforcement cases Congress cited as "regulation by enforcement" in the legislative history, though CFTC records indicate that nearly half of FY2023 enforcement activity targeted digital assets [step:38580358].
II. Who the Lobbying Record Shows Advocating for FIT21
Primary Proponents
LDA filings and industry coalition data indicate that Coinbase Inc., Circle Internet Financial, and the Blockchain Association are the primary registered advocates for H.R. 4763 [step:0a104706]. Coinbase reported approximately $1.04 million in lobbying expenditures for Q1 2024 alone, with filings listing "digital asset market structure" and "regulatory clarity" — referencing FIT21 — as specific issues [step:0a104706]. The Blockchain Association's filings show sustained lobbying on the bill across multiple quarters in 2024, representing a membership of over 100 firms that records suggest would benefit from reclassifying many digital assets as "digital commodities" under CFTC jurisdiction [step:0a104706].
Overlapping Lobbying Infrastructure
2023–2024 LDA filings indicate that S-3 Group (S-3 Public Affairs) and Franklin Square Group appear as registered lobbyists for both Coinbase and Circle Internet Financial simultaneously, with filings specifically listing "market structure" (H.R. 4763) and "stablecoin regulation" (S. 2281) as lobbying issues [step:ce380b63]. The same filings list individual lobbyists at these firms who public records indicate previously served as staff on the House Financial Services Committee — the committee that drafted FIT21 [step:ce380b63]. OpenSecrets client profiles for both Coinbase and Circle corroborate the LDA filing data [step:ce380b63].
Pre-Positioning: Lobbying Registrations Before the Bill
LDA registration records indicate that several crypto-native and infrastructure firms established formal Washington representation well before FIT21's July 2023 introduction. Records show Chainalysis registering representation through DiRoma Eck & Co. LLP in Q4 2021, and Marathon Digital registering through the same firm in Q1 2022 — between 15 and 21 months ahead of the bill's introduction [step:afb6aefd]. Dapper Labs similarly established DC representation in this window [step:afb6aefd]. The record does not disclose what specific policy discussions, if any, occurred between these newly registered entities and committee staff during this pre-introduction period.
III. The Narrative Infrastructure: Nonprofits and Messaging
Coin Center
IRS Form 990 data for Coin Center (EIN 47-1315917), a 501(c)(4) organization, indicates net assets exceeding $12.9 million as of 2022, with revenue drawn almost entirely from contributions [step:7ca160cd]. Because 501(c)(4) organizations are not required to publicly disclose their donors, the record is silent on the identities of Coin Center's funders. Executive compensation for Coin Center's top official is listed in 990 filings as approaching $800,000 annually [step:7ca160cd]. LDA filings show Coin Center maintaining a sustained $120,000 per quarter lobbying operation directly engaging the CFTC as of 2026 filings [step:c8639b4d].
Cedar Innovation Foundation
LDA records indicate the emergence of Cedar Innovation Foundation, Inc. (incorporated in Wilmington, Delaware) as an additional narrative actor, initiating lobbying in mid-2024 with quarterly spend reaching $80,000 by year-end [step:c8639b4d]. Unlike Coin Center's filings, which specifically target the CFTC and SEC, Cedar's LDA reports indicate a focus on broader "technology and innovation" framing directed at both chambers of Congress [step:c8639b4d]. The record does not disclose Cedar's funding sources or its relationship, if any, to industry entities already identified in this paper.
Stand With Crypto
Public records indicate that Stand With Crypto, a 501(c)(4) advocacy portal, is linked to Coinbase and lists H.R. 4763 among its featured legislative priorities [step:0a104706]. The record does not disclose Stand With Crypto's full donor base or budget.
Taken together, the record points to a multi-pronged narrative structure: specialized legal and regulatory advocacy (Coin Center, targeting CFTC/SEC directly) paired with broader "American innovation" public messaging (Cedar Innovation Foundation, Stand With Crypto) [step:c8639b4d].
IV. The Revolving Door: What Disclosed Records Show
Coinbase Executive Ties
SEC filings for Coinbase Global, Inc. (CIK 0001679788) — specifically the 2024 DEF 14A proxy statement — identify the board and executive leadership structure [step:5bc3936f]. Public records separate from the proxy indicate that Paul Grewal, Coinbase's Chief Legal Officer, previously served as a U.S. Magistrate Judge and held roles at Facebook [step:5bc3936f]. Faryar Shirzad, Coinbase's Chief Policy Officer, has documented prior service as Deputy National Security Advisor and at Goldman Sachs [step:5bc3936f]. The proxy statement notes that Shirzad was not a Named Executive Officer in the 2024 summary compensation tables, meaning his full biographical disclosure does not appear in that filing's summary sections [step:5bc3936f]. Kathryn Haun stepped down from the Coinbase board in 2024, as reflected in the proxy [step:5bc3936f].
Lobbying Firm Staffers
As noted above, LDA filings for S-3 Group and Franklin Square Group list individual lobbyists with prior House Financial Services Committee staff experience, now representing both Coinbase and Circle on the legislation that committee drafted [step:ce380b63]. The record does not disclose the specific roles these individuals held on the committee or the nature of their prior access to the drafting process.
V. The Regulatory Posture: CFTC Enforcement and Jurisdictional Expansion
CFTC press releases through early 2026 indicate an aggressive litigation strategy aimed at establishing or defending jurisdictional claims. Records point to suits against prediction market operators in Wisconsin, New York, and Massachusetts, with the CFTC asserting "exclusive jurisdiction" over event contracts in those matters [step:1838d449]. The CFTC record also reflects resolution of matters arising from the 2022 FTX collapse, including a supplemental consent order involving Nishad Singh [step:1838d449]. These enforcement actions, taken together, suggest the CFTC is using litigation to define the prudential perimeter of its authority over digital-adjacent markets at the same time Congress is considering legislation that would expand that authority [step:1838d449].
The record is silent on whether CFTC leadership has had documented meetings with industry advocates lobbying for expanded CFTC jurisdiction during this period, as calendar and visitor log data for the relevant timeframe has not been retrieved in the current record.
VI. Consumer-Protection and Prudential Implications: What the Record Indicates
The record does not yet contain a systematic crosswalk between FIT21's statutory text and specific consumer-protection provisions or their absence. What the record does indicate is structural: the bill's decentralization certification mechanism would, if enacted, shift primary oversight of a broad category of digital assets from the SEC — which applies disclosure requirements, anti-fraud rules, and registration obligations developed over decades — to the CFTC, which has a different statutory mandate and a historically smaller retail-investor protection apparatus [step:5095acb2]. The record does not contain agency-published analyses quantifying the consumer-protection delta between the two regulatory regimes as applied to digital assets.
What We Still Don't Know
The following gaps in the current record are material to a complete assessment:
Donor identities behind key 501(c)(4) organizations. The record is silent on who funds Coin Center, Cedar Innovation Foundation, and Stand With Crypto. Without this, the chain of financial sponsorship behind the public narrative cannot be traced.
Meeting logs and calendar data. No visitor logs, FOIA-released calendars, or documented meeting records between industry lobbyists and committee staff (or agency leadership) have been retrieved. The record cannot currently speak to the frequency or nature of access.
The full FIT21 legislative history. H. Rept. 118-484 has not been extracted in searchable form. The specific enforcement cases Congress cited as "regulation by enforcement" justifications remain unidentified in the current record [step:38580358].
Senate trajectory. The record does not yet contain a systematic account of S. 2281 (Lummis-Gillibrand) or its successor drafts, committee markups, or the stablecoin provisions' relationship to Treasury and Federal Reserve positions.
Cedar Innovation Foundation's funding and industry ties. LDA filings establish Cedar's existence and lobbying targets but are silent on its donors, board, and any relationship to firms already identified in this paper [step:c8639b4d].
Faryar Shirzad's full disclosure record. The 2024 Coinbase proxy omits his compensation and full bio from summary sections; OGE filings or other ethics disclosures from his prior government service have not been retrieved [step:5bc3936f].
CFTC leadership meeting records. Whether CFTC commissioners or senior staff have had documented meetings with entities lobbying for expanded CFTC jurisdiction remains unaddressed in the current record [step:1838d449].
This is a living document. All findings are subject to revision as additional records are retrieved. Absence of a finding does not indicate absence of a fact — it indicates the record has not yet been obtained.