NewsCryptoPlume Proposes Four-Role Vault Regulatory Framework to SEC's Crypto Task Force

Plume Proposes Four-Role Vault Regulatory Framework to SEC's Crypto Task Force

Author: CryptoBriefing·

Key Takeaways

  • •Plume Network's General Counsel Salman Banaei presented a four-role regulatory framework for onchain vaults to the SEC's Crypto Task Force on September 21, 2026.
  • •Under the proposal, vault administrators and token issuers would be subject to regulation because they interface directly with investors, while protocol developers and curators would remain outside the regulatory perimeter.
  • •Plume's Nest vault protocol reportedly holds more than $250 million in total value locked across over 213,000 token holders, with Plume Vaults carrying roughly $226 million in TVL as of October 21, 2026.
  • •Beyond the role taxonomy, Plume is asking regulators to clarify custody rules for onchain vaults held by registered funds and to enable secondary markets for tokenized fund shares.
  • •The SEC has made the submission public but has neither endorsed it nor taken a position, while Plume holds a Bermuda Class M digital asset licence covering regulated vault operations.
Plume Proposes Four-Role Vault Regulatory Framework to SEC's Crypto Task Force

Plume Network has presented the SEC's Crypto Task Force, the agency's dedicated unit for developing its regulatory approach to crypto assets, with a framework for onchain vaults, arguing that oversight should apply to certain participants in the ecosystem while leaving others outside the regulatory perimeter.

The framework was submitted by Plume General Counsel Salman Banaei on September 21, 2026. It divides 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 fall under regulatory oversight, while developers and curators would remain outside that perimeter. That split is the heart of the proposal: where a participant lands in the taxonomy determines whether it must answer to regulators or operate outside that perimeter entirely.

The Four-Role Framework

Onchain vaults are pooled, smart contract-based structures in which deposits are put to work under a defined strategy, and the submission assigns each stage of that operation to a distinct role. Vault protocol developers build and maintain the technical infrastructure. Vault curators make investment strategy decisions about which assets a vault holds. Vault administrators handle operational functions such as managing deposits and withdrawals. Vault token issuers create and distribute the tokens that represent a depositor's share of a vault.

Plume's filing contends that the administrator and token issuer roles warrant regulation 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

The proposal is not an abstract policy exercise for the company. Plume'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 throughout 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 United States 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 rules that govern how such funds must safeguard assets held on investors' behalf. The second concerns enabling secondary markets for tokenized fund shares, which would allow investors to trade their vault positions without waiting for a redemption window.

The SEC has taken no position on the submission so far; how the task force engages with the four-role split, and with the two follow-on clarifications, will be the next signal of how the domestic regulatory perimeter for onchain vaults is drawn.