This is a really strange argument because the argument basically defeats itself. You start by explaining that vaults exist because users can’t realistically track and manage thousands of markets themselves, so the vault abstracts that complexity and someone else allocates the capital for them. I don’t think anybody could have thought of a better definition for delegated portfolio management aka asset management lol. Also a timelock doesn’t magically turn the curator’s decision into the depositor’s decision, it just gives the depositor notice of any changes, your own docs literally say the Curator configures “liquidity allocation rules”, is “abstracting risk curation decisions away from depositors” and makes key decisions about “how capital is allocated.” So even if the code constrains the manager, it doesn’t remove the manager. You also failed to mention what SEC commissioner pierce actually says and thats vaults fall on a spectrum between “programmatic allocations determined solely by immutable smart contracts” and “allocations at the sole discretion of another person or group of persons.” She also explicitly points to selecting yield generating activities and reallocating assets as examples of managing a vault and says managing vaults can raise investment adviser issues. You’re basically trying to make the asset manager disappear by changing the test from “who is making the investment decisions?” to “can they steal the money and can I withdraw?” those are completely different things. Even your “implicit approval” argument is backwards, if I delegate allocation to you then you announce a change and I don’t withdraw during the timelock, my failure to leave hasn’t somehow transformed your investment decision into mine. In fact that requires me to continuously monitor the manager which is the exact complexity vaults supposedly exists to abstract away in the first place. Vaults can absolutely be noncustodial but noncustodial settlement is not non discretionary allocation, no matter how you try to spin this an asset manager is an asset manager even if you give them cute sounding names like “curator” or “allocator”.