September 2025 - The FinTech Quarterly

Introduction

In September 2025, financial services regulation reached a pivotal turning point, with the SEC's groundbreaking private fund access guidance and the approval of the Solana ETF prospectus eroding barriers between traditional finance and digital assets. This convergence isn't just incremental change—it's a seismic shift enabling retail investors to tap into trillion-dollar private equity markets. At the same time, blockchain platforms are gaining mainstream legitimacy as investment vehicles under securities regulations.

This in-depth quarterly edition delves into the SEC's democratization of private equity funds, unpacking expanded access frameworks, valuation mandates, and advisor liability risks for investment management firms. It provides a thorough regulatory analysis of the Solana ETF approval, highlighting precedents for alt-layer protocols, institutional adoption, and compliance architectures. We address the private fund valuation crisis with practical solutions for illiquid asset fair value determinations, and spotlight Chairman Paul Atkins' Project Crypto initiative, driving a pivot from SEC enforcement to collaborative rulemaking.

Explore state-level digital asset frameworks, such as Illinois' new protections, banking custody clarity for crypto assets, and global developments in EU MiCA and UK crypto regulations. Our Tech Spotlight covers AI models passing the CFA Level III, tokenized private fund interests, Web3 identity for KYC/AML, and cross-chain interoperability for digital asset ETFs—plus AI-blockchain alliances reshaping the finance industry.

Featured Coverage: SEC private fund retail access • Solana ETF regulatory analysis • Private fund valuation crisis • Project Crypto framework • AI CFA Level III benchmarks • Tokenized collateral & stablecoins • Illinois Digital Assets Act • Crypto custody no-action relief • Cross-chain protocols for ETFs

Article Highlights

1. The Democratization of Private Funds

Excerpt: The SEC's latest guidance fundamentally restructures access to private equity investment opportunities, dismantling barriers for accredited-only participation and creating opportunities—and compliance challenges—for investment management firms.

Read Time: 8 minutes

Key Takeaways: Tiered retail access (10% portfolio cap) • Quarterly fair value under ASC 820 • Heightened advisor fiduciary duties

2. Solana ETF Approval: Regulatory Analysis

Excerpt: The SEC's approval of the first Solana-based ETF prospectus sets a precedent for Layer-1 blockchains, accelerating institutional adoption and mandating advanced compliance measures, such as real-time blockchain monitoring.

Read Time: 7 minutes
Key Takeaways: Decentralization & custody criteria • $10B projected inflows • Integration with traditional surveillance

3. The Private Fund Valuation Crisis

Excerpt: With retail access, quarterly valuations of illiquid assets become mandatory—SEC guidance demands ASC 820 methodologies, independent specialists, and robust governance to mitigate litigation risks.

Read Time: 6 minutes
Key Takeaways: Governance committees • Third-party audits • Sensitivity disclosures for volatility

4. Regulatory Roundup: What's Moving the Needle

Excerpt: SEC's enforcement pivot continues—no new crypto actions; Project Crypto advances via roundtables. Joint SEC-CFTC spot trading clarity, Illinois Digital Assets Act, and custody relief expand options.

Read Time: 10 minutes
Key Topics: Atkins' July speech • DeFi exemptions • State licensing by 2027 • EU MiCA Level 2 standards

5. Tech Spotlight: AI & Blockchain Convergence

Excerpt: AI models hit 79% on CFA Level III; DTCC tokenizes collateral. Tokenized LPs enable fractional ownership, while Web3 KYC is facilitated via ZK-proofs. Cross-chain bridges handle a $760M Solana volume.

Read Time: 9 minutes
Key Innovations
: o4-mini reasoning scores • Stablecoin payments • Smart contract waterfalls • Debridge interoperability

This newsletter provides general insights on SEC regulations, crypto ETF approvals, and private equity funds—not intended as legal advice. Tailor these to your business.

Written by: Bo Howell, Managing Director, FinTech Law
Research & Drafting Assistance: Claude Sonnet 4.5 (Anthropic) & Grok 4 Fast (beta) (xAI)
Editorial Review: FinTech Law Editorial Team

This edition of The FinTech Quarterly provides general information on topics like private equity funds, SEC regulations, and digital assets—it does not constitute legal advice. Consult qualified counsel for business-specific guidance.© 2025 FinTech Law. All rights reserved.