Bullish (US Market Structure): The Senate Banking Committee’s advancement of the CLARITY Act signals a major step toward statutory certainty. Prioritising everyday market participants, the legislation brings digital assets into the US regulatory framework. While this imposes new compliance burdens, the statutory mandates for timely disclosures, educational infrastructure, and anti-fraud protections establish clear rules of the road that will build long-term retail and market

1. Executive Summary: The Quantifiable “Cost of Legitimacy” and Market Consolidation This reporting period introduced several regulatory developments with substantial implications for CASP operational models and capital planning. The common theme is a rise in the measurable “Cost of Legitimacy,” as illustrated by the prudential requirements outlined in the Bank of England’s (BoE) consultation on systemic stablecoins. The proposal for a 40% unremunerated reserve requirement