Following Commissioner Peirce’s statement on crypto vaults, the debate has focused on whether vault activity should be viewed as regulated asset management. Tesseract’s CEO argues that “this is asset management, it is a regulated activity,” while Gauntlet’s Chief Business Officer has challenged broader claims of that nature. Both perspectives raise important points. Vaults can involve meaningful operator discretion, but the extent of that discretion varies significantly between structures. Rather than taking a position, we mapped 100 rated vaults against the spectrum outlined by Commissioner Peirce, from greater operator discretion to more programmatic allocation. Using public evidence and assessing each vault gate by gate: - 17 score 80 or higher on our discretion-bounded index, indicating that allocation is heavily constrained by rules the operator cannot override. - 14 score below 40, indicating a greater reliance on operator discretion. - The remaining 69 fall between those points, where the specific controls and permissions matter more than any single label. The index is descriptive, not a legal opinion, and the 100 vaults represent a sample of the wider market. The full map and underlying tables are below. Every placement is sourced and can be disputed through our platform.

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