Regulatory Analysis Report] Legal value creation through transaction data, formal listing on exchanges, and institutional linkage mechanism under the Clarity Act (H.R. 3633)
- Overview and analysis background
This report supports the U.S. House of Representatives Bill H.R. We analyze the process by which digital assets obtain legal status and are listed on exchanges under 3633 (Digital Asset Market Clarity Act).
In the past, traditional investment-centered virtual asset offerings (ICOs), which were the initial funding method for the virtual asset market, were subject to strong regulation by the U.S. Securities and Exchange Commission (SEC).
On the other hand, the Clarity Act proposes a new institutional framework that allows for direct listing on exchanges without prior regulatory approval by recognizing it as a legal 'digital product' if the value is proven based on transaction data and fee consumption, which is the actual usage of blockchain.
- Basis for legitimate value creation (actual use and intrinsic value of blockchain)
• Text of the law (Title I, Section 102)
• “A digital asset shall be classified as a digital commodity if the network on which it operates is a mature blockchain, and its economic value is substantially derived from the use and functioning of the blockchain, rather than the entrepreneurial or managerial efforts of a common enterprise.”
• Korean interpretation
If the network on which the digital asset runs is a mature blockchain, and its economic value is substantially derived from the actual use and functionality of the blockchain rather than from the entrepreneurial or managerial efforts of a joint enterprise, the digital asset is classified as a digital good.
• Interpretation of legal meaning and application to project
This clause specifies that the value of an asset must come from objective data within the blockchain network, not from subjective marketing or promotions by the development team. ‘Use and functioning’ as defined in the original text refers to the amount of transactions that occur in real time on the on-chain and the gas fee consumed to maintain the network. This provides a strong legal basis for projects that generate transactions by running actual Web3 services and launchpad apps based on a large user base, such as the Pi Network. In other words, the data itself created by users voluntarily consuming network fees becomes evidence of legitimate intrinsic value recognized by the U.S. government.
- Right to formal listing on the exchange through on-chain data
• Text of the law (Title II, Section 204)• “A registered digital commodity exchange may list a digital asset for trading without prior regulatory approval, provided that the issuer or the exchange demonstrates through verifiable on-chain metrics that the asset functions as a digital commodity and meets the decentralized transaction thresholds established under this Act.
• Korean interpretation
• “A registered digital goods exchange may list a digital asset for trading without prior regulatory approval if the issuer or exchange demonstrates through verifiable on-chain metrics that the asset functions as a digital good and meets the decentralized transaction thresholds established under the Act.
• Interpretation of legal meaning and application to project This provision ensures that accumulated on-chain data can serve as a legal passport for exchange listing. In the past, when listing a coin, there was a regulatory risk that it had to pass the SEC's strict securities review or the listing was put on hold altogether. However, according to this bill, as long as the exchange proves with 'data' that the actual transaction number and degree of dispersion of the blockchain meet the standards, it will have the legal right to independently proceed with formal spot listing without the government's notice. This means that the transparent node distribution data and transaction records accumulated by the Pi Network serve as a basis for free pass listing without regulatory risk for exchanges.
- Obligation to provide and link data to institutions and exchanges
• Text of the law (Title III, Section 308)
• “Registered digital commodity exchanges and institutional intermediaries shall utilize continuous distributed ledger analytics tools to monitor, verify, and report real-time on-chain transaction data and fee metrics to ensure market integrity and provide empirical data for asset valuation.”
• Korean interpretation
• “Registered digital goods exchanges and institutional broker-dealers must utilize continuous distributed ledger analytics tools to monitor, verify and report real-time on-chain transaction data and fee metrics to ensure market health and provide empirical data for asset valuation.”
• Interpretation of legal meaning and application to projectThis provision stipulates that exchanges and large financial institutions in the United States must mandatory link and verify the on-chain data of the relevant blockchain when handling specific virtual assets. Exchanges must use their own distributed ledger analysis tools to constantly monitor token distribution channels, node dispersibility, and real-time fee consumption patterns and report this to regulators.
At the same time, this bill exempts from securities law regulations only those projects that have proven their maturity by providing such transparent transaction data in real time. As a result, financial institutions will be able to invest large amounts of investment funds without risk based on clean data linked to the exchange in real time.
- Comprehensive conclusion and future outlook
In conclusion, the value creation and asset disclosure stipulated by the Clarity Act are completely different from the speculative ICOs of the past that aimed only at users' investment funds.
When a developer first builds a blockchain ecosystem and accumulates reliable transaction and fee data, the exchange links this data to the system in accordance with the law and voluntarily carries out an official listing. It is an advanced institutional financial infrastructure that allows U.S. financial institutions to legally and safely invest funds based on this verified and transparent data.
The reason why Pi Network's core team and Dr. Chengdiao Pan have completely rejected the traditional ICO for several years and focused only on the utility app ecosystem and transaction build-up is also analyzed as a long-term legal ploy to legally absorb institutional funds from Wall Street by completely passing the data screening and listing standards of the Clarity Act.
Regulatory Analysis Report] Under the Clarity Act (H.R. 3633), the creation of legitimate value through transaction data, formal listing on exchanges, and institutional linkage mechanisms
- Overview and Analysis Background
This report analyzes the process by which digital assets acquire legal status and are listed on exchanges under the U.S. House of Representatives Bill H.R. 3633 (Digital Asset Market Clarity Act, hereafter referred to as the Clarity Act).Traditional Initial Coin Offerings (ICOs), which were an initial funding method in the past for the virtual asset market and focused on investment, were subject to strong regulation by the U.S. Securities and Exchange Commission (SEC).
On the other hand, the Clarity Act proposes a new institutional framework that allows for direct listing on exchanges without prior regulatory approval by recognizing the value proven based on transaction data and commission consumption, which are the actual usage of blockchain.
- Basis for creating legitimate value (the actual use and intrinsic value of blockchain)
The original legal text (Title I, Section 102)
“A digital asset shall be classified as a digital commodity if the network on which it operates is a mature blockchain, and its economic value is substantially derived from the use and functioning of the blockchain, rather than the entrepreneurial or managerial efforts of a common enterprise.”
Korean interpretation
If the network on which the digital asset runs is a mature blockchain, and its economic value is not derived from the entrepreneurial or managerial efforts of a joint enterprise but is actually derived from the actual use and function of the blockchain, then the digital asset is classified as a digital commodity.
Interpretation of legal meaning and application of projectsThis clause states that the value of an asset should come from objective data within the blockchain network, rather than from the development team's subjective marketing or promotion. The 'use and functioning' defined in the original text refers to the amount of transactions occurring in real-time on-chain and the gas costs incurred for maintaining the network. This provides a strong legal basis for projects that generate transactions by running practical Web3 services and launchpad apps based on a large user base, such as the Pi Network. In other words, the data created by users voluntarily spending network fees itself becomes evidence of legitimate intrinsic value recognized by the U.S. government.
- The right to official listing on the exchange through on-chain data
The original legal text (Title II, Section 204)
"A registered digital commodity exchange may list a digital asset for trading without prior regulatory approval, provided that the issuer or the exchange demonstrates through verifiable on-chain metrics that the asset functions as a digital commodity and meets the decentralized transaction thresholds established under this Act.
Korean interpretationRegistered digital commodity exchanges can list their digital assets for trading without prior regulatory approval if they demonstrate through on-chain indicators that the issuer or exchange can verify that the asset functions as a digital commodity and meets the distributed transaction standards established under this bill.
Interpretation of legal meaning and application of projects This provision ensures that accumulated on-chain data can serve as a legal passport for exchange listings. In the past, there were regulatory such as having to pass the SEC risks' strict securities review or having the listing completely suspended. However, according to this bill, if the actual transaction figures and distribution of the blockchain are proven to meet the criteria with 'data,' the exchange will have the legal right to independently conduct a formal in-kind listing without being mindful of the government. This means that the transparent node distribution data and transaction records accumulated by the Pi Network serve as a basis for exchanges to list on a free pass without regulatory risks.
- Obligations to provide and link data to institutions and exchanges
The original legal text (Title III, Section 308)“Registered digital commodity exchanges and institutional intermediaries shall utilize continuous distributed ledger analytics tools to monitor, verify, and report real-time on-chain transaction data and fee metrics to ensure market integrity and provide empirical data for asset valuation.”
Korean interpretation
Registered digital commodity exchanges and institutional intermediaries are required to utilize continuous distributed ledger analysis tools that monitor, verify, and report real-time on-chain transaction data and fee metrics to ensure market soundness and provide empirical data for asset valuation.
Interpretation of legal meaning and application of projects This provision stipulates that exchanges and large financial institutions in the United States must mandatorily link and verify the on-chain data of the blockchain when handling specific virtual assets. The exchange must constantly monitor the distribution channels of tokens, the degree of distribution of nodes, and real-time fee consumption patterns using its own distributed ledger analysis tools, and report this to regulatory authorities.At the same time, this bill exempts projects that have proven maturity by providing such transparent transaction data in real-time from securities regulations, allowing financial institutions to inject large-scale investment funds without risk based on clean data that is linked to the exchange in real-time.
- Comprehensive Conclusions and Future Forecasts
In conclusion, the value creation and asset disclosure stipulated by the Clarity Act are completely different from speculative ICOs, which were previously focused solely on user investment.
If the developer first builds a blockchain ecosystem and accumulates reliable transaction and fee data, the exchange will then, in accordance with the law, link this data to the system and autonomously proceed with formal listing. U.S. financial institutions will then use this verified and transparent data as a basis to inject legally and securely, creating an advanced institutional financial infrastructure.
The reason why the core team of Pi Network and Dr. Cheng Diao Pan have focused solely on the utility app ecosystem and transaction build-up, completely rejecting traditional ICOs for years, is also analyzed as a long-term legal strategy to perfectly pass the data review and listing standards of this Clarity Act and legally absorb institutional funds from Wall Street.