Plume Network walked into the SEC’s Crypto Task Force with a blueprint for how onchain vaults should be regulated, and the core argument was as much about what regulators shouldn’t touch as what they should.
The framework, submitted by General Counsel Salman Banaei on September 21, 2026, proposes splitting the vault ecosystem into four discrete roles: vault protocol developer, vault curator, vault administrator, and vault token issuer. Under Plume’s model, only the latter two would be subject to regulatory oversight, leaving developers and curators outside that perimeter.
The four-box framework
Vault protocol developers build and maintain the technical infrastructure. Vault curators make investment strategy decisions about what assets the vault holds. Vault administrators handle operational functions like managing deposits and withdrawals. Vault token issuers create and distribute the tokens that represent a depositor’s share of the vault.
According to Plume’s submission, the administrator and token issuer roles carry regulatory weight because they involve direct interfaces with investors and the mechanics of investor capital. The developer and curator roles, in this framing, sit closer to the infrastructure side of the ledger.
The SEC has made the submitted materials public but has not endorsed the framework, which is the standard treatment for third-party regulatory proposals at this stage.
What Plume has at stake
This is not an abstract policy exercise for Plume. The company’s primary yield product, the Nest vault protocol, reportedly has over 213,000 token holders and more than $250 million in total value locked. As of October 21, 2026, Plume Vaults carried approximately $226 million in TVL, and recent 30-day fees across the Nest vaults totaled about $1.02 million.
The September presentation builds on a relationship with US regulators that Plume has been cultivating through 2026. Banaei testified before the SEC in March 2026, and the company secured a Bermuda Monetary Authority Class M Digital Asset Business Licence in May 2026, specifically covering regulated vault operations. Plume is structured as a subsidiary of Kimber Labs Inc.
The Bermuda licence gives Plume a regulated operational footprint outside the US while the domestic framework remains unsettled.
The broader regulatory ask
Beyond the four-role taxonomy, Plume is pushing for two additional clarifications from regulators. The first involves custody rules for onchain vaults held by registered funds. The second involves enabling secondary markets for tokenized fund shares, which would allow investors to trade their vault positions without waiting for a redemption window.
Disclosure: This article was edited by John Chen. For more information on how we create and review content, see our Editorial Policy.