Bull Blockchain Law is proud to announce its leadership role in collaborating with The Digital Chamber (“TDC”) and the Blockchain Game Alliance on comments to the Consumer Financial Protection Bureau (CFPB) regarding the application of the Electronic Fund Transfer Act (EFTA) and Regulation E to self-hosted wallets and blockchain gaming platforms.
In March. TDC’s Gaming Workstream—in partnership with the Blockchain Game Alliance and Bull Blockchain Law—submitted detailed comments to the CFPB demonstrating that the Bureau’s 2021 Interpretive Rule miscategorized self-hosted wallets as intermediated “accounts” operated by “financial institutions.” The Workstream highlighted that this misclassification would impose onerous and technically infeasible regulatory burdens on wallet providers and gaming platforms.
Following those submissions, on May 15, 2025, the CFPB withdrew its Interpretive Rule (FR Doc. 2025-08646), opening the door for clearer, technology-neutral guidance.
Self-custody wallets and blockchain gaming ecosystems must be regulated in a way that protects consumers without stifling innovation. Our joint submission with TDC delivered practical, technology-aware recommendations to achieve that balance.
We are proud to support the policy goals of Web3 and blockchain gaming companies as they drive innovation, foster consumer empowerment, and shape the future of the digital economy. Thank you to all who participated in TDC’s Gaming Workstream for your invaluable contributions to this effort.
To schedule a consultation with one of our attorneys to discuss your Web3 gaming needs, please visit https://bull-legal.com/contact-us/ or email tyler@bull-legal.com.