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    Navigating the Digital Asset Market Structure Bill (FIT21 Act)

    Operational and regulatory guidance for tomorrow’s digital finance leaders

    Published: December 11, 2025

    Matthew Watson

    Senior Business Services Analyst

    Matthew Watson

    What is the FIT21 Act?

    The Financial Innovation and Technology for the 21st Century Act (FIT21 Act) is a landmark U.S. legislative proposal that aims to establish a comprehensive regulatory framework for digital assets. It clarifies the roles of the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC), introduces new registration categories, and sets disclosure standards for digital asset issuers, exchanges, and intermediaries.

    Key provisions of FIT21 include:

    • Clear distinction between digital commodities (regulated by the CFTC) and restricted digital assets (regulated by the SEC)
    • Certification process for decentralized blockchain systems
    • New registration requirements for digital commodity exchanges, brokers, and dealers
    • Enhanced disclosure obligations for token issuers and developers
    • Exemptions for certain Decentralized Finance (DeFi) protocols and secondary market transactions

    Expected Timeline:

    • Final rulemaking is expected in late 2026
    • Enforcement is expected to begin between 2027–2028, depending on final rule publication

    Why FIT21 Matters

    The FIT21 Act will reshape how digital assets are classified, traded, and disclosed. It introduces new compliance hurdles to navigate as well as strategic opportunities for banks, FinTechs and exchanges.

    Implications for financial institutions:

    • Jurisdictional clarity between SEC and CFTC
    • New registration pathways for digital asset services
    • Disclosure and governance standards for tokenized products
    • Operational upgrades for DeFi and blockchain integrations

    How First Derivative Can Help Navigate FIT21

    First Derivative offers vast experience and expertise in navigating and supporting many financial institutions and clients across evolving regulatory landscapes. We can provide comprehensive, end-to-end services to help financial institutions confidently navigate the complexities of FIT21. Our support spans regulatory interpretation, operational readiness, and strategic positioning in the evolving digital asset landscape.

    FIT21 preparedness can be split into four key areas:

    (Click for information)

    Regulatory Strategy & Impact Assessment

    • FIT21 Act gap analysis and jurisdictional mapping
    • Asset classification (commodity vs. security)
    • Blockchain decentralization certification support

    Registration & Compliance Enablement

    • SEC/CFTC registration advisory for exchanges and brokers
    • Disclosure framework design for token issuers
    • Policy development for DeFi protocols and smart contracts

    Technology & Data Architecture

    • Blockchain audit trail integration
    • Risk and compliance automation for digital asset transactions
    • Data governance aligned with FIT21 Act standards

    Stakeholder Engagement & Advocacy

    • Board-level briefings and investor communications
    • Scenario planning for enforcement and rulemaking delays

    First Derivative can support you in these functions and more.

    Why First Derivative?

    Navigating FIT21 demands a partner with a blend of regulatory sophistication and industry agility – that’s where First Derivative excels. With deep expertise in regulation and governance, we offer nuanced, actionable guidance and support across complex ecosystems. First Derivative brings insight spanning the SEC, CFTC, and banking supervisory bodies, allowing us to decode overlapping regulatory mandates and anticipate enforcement priorities. Our expert teams design tailored solutions for a wide array of stakeholders including exchanges, FinTech innovators and established banking institutions – ensuring each client gets a roadmap that aligns with their business model and risk appetite. Backed by a proven track record of delivering compliance frameworks and resolving regulatory hurdles, we don’t just advise; we embed resilience, accuracy and clarity into every engagement. Whether you are launching a new product or overhauling internal controls to meet FIT21 standards, we are positioned to lead, guide and assist you confidently on your FIT21 journey.

    Summary

    In summary, the FIT21 Act is more than a compliance challenge, it’s a chance to lead in the next era of financial innovation. First Derivative, through its proven track record in the regulatory space and compliance, is ready to guide and support your institution with clarity, confidence, and strategic foresight.

    Let’s Talk

    If you’re looking to strengthen your compliance posture or prepare for what’s next, we’d love to start a conversation. Reach out to the First Derivative team.

    Contact us today

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