Tally will not be moving forward with an ICO. After going through nearly the entire process, we came to the conclusion that it didn’t make sense in the current market. More importantly, we weren’t confident that we could fulfill the promises we would be making to token holders if we sold them tokens.

That realization forced us to confront a harder truth.

After more than five years, Tally is shutting down.

This wasn’t an easy decision, but it’s the honest one.

What Happened

The simplest way to say it is this: there isn’t a venture-backed business in governance tooling for decentralized protocols, at least not yet.

Tally was built on a particular vision of the future. Like many others in the Ethereum ecosystem, we believed we were heading toward a world with:

• Thousands of decentralized protocols

• Millions of active participants

• Robust governance systems operating at scale

In other words, the “infinite garden” vision of Ethereum, a diverse ecosystem of protocols and communities that needed sophisticated coordination and governance infrastructure.

That future hasn’t materialized.

Crypto has certainly produced large and successful businesses. But over the past few years, the industry has largely found product-market fit in payments and speculation. The rich ecosystem of consumer applications, protocol communities, and governance-heavy organizations that we expected simply hasn’t developed at the scale required to sustain companies like ours.

For infrastructure companies built on that vision, the reality is difficult: the market isn’t there yet.

We’ve spent years championing the DAO vision. But at some point you have to accept the world as it is, not as you hoped it would be.

And the reality is that we can no longer build a viable business around this.

What We Built

Even though the company is winding down, I’m incredibly proud of what the Tally team accomplished.

Over the life of the company:

• More than $1 billion in payments flowed through Tally infrastructure

• At one point over $80 billion in value was protected through the systems we helped operate

• Over a million people used the site

• Hundreds of organizations governed themselves through Tally

• Tens of millions of token holder addresses participated in governance through our platform

Most importantly: we never had a major security incident.

Over the years we dealt with everything you might expect in crypto:

• DDoS attacks

• waves of suspicious job applicants (including a few North Korean ones)

• constant infrastructure pressure

• and the regulatory uncertainty of the “Gensler years”

Through all of it, we did our best to protect the ecosystem.

I’m proud to say that some of the greatest organizations in crypto used Tally. And yes — some of the more infamous ones too (I see you Ooki DAO).

But through the good and the bad, we showed that decentralized governance could operate at scale.

The Team

One thing I want to emphasize: the Tally team is exceptional.

They are some of the best engineers and operators in crypto. Full stop.

If you’re hiring, you should talk to them.

Raph and I will still be around for a little while to help with the wind-down process, but the team is actively exploring new opportunities, so feel free to reach out.

What Happens Next

The governance application will begin winding down at the end of the month.

We’ve been working with our major partners to establish continuation plans for enterprise clients, and the interface will remain live for some time while those transitions happen.

If you are a smaller organization using Tally, we may not have been able to reach you directly. In the spirit of decentralization, privacy, and self-sovereignty, we simply never collected contact information for many of the teams using the platform.

If that’s you, hopefully this post reaches you.

Looking Back

I’m incredibly proud of what we built.

I’m proud of the team.
I’m proud of the organizations we worked with.
And I’m proud of the role we played in defending and supporting DeFi when the ecosystem needed it most.

Tally may not be part of crypto’s future, but we were part of its story.

And that matters.

Looking Forward

Personally, I’m not entirely sure what comes next for me.

But I believe in crypto more than ever.

What I’ve come to realize, though, is that crypto is no longer “early.”

A few years ago I spoke with Simona Pop, one of Ethereum’s early innovators. We talked about how the ecosystem never really planned for what success would look like.

What happens when:

• The largest institutions in the world use crypto?

• The most powerful governments support it?

• Crypto becomes infrastructure rather than rebellion?

We’re now discovering the rough edges of that success.

The industry is entering a new phase, and we’re all trying to figure out what the path forward looks like.

I only wish Tally were going to be part of that future.

But that’s okay.

Because we were part of the journey that got us here.

And for that, I’m deeply grateful.

To our team, our users, our partners, and our investors — thank you for believing in us.

I look forward to seeing many of you again somewhere down the road.

— Dennison Bertram

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 16.

Day 27/60

Dennison’s in New York. The market is soft, the macro is uncertain, and the team is being honest about what that means for our timeline.

The market right now

We told you we’d be transparent, and that includes the uncomfortable parts. The market is not in a great place for token sales right now. There’s macro uncertainty, geopolitical tension, and a general softness across the ecosystem. We’re watching it carefully and considering timing with the seriousness it deserves. We’re not lawyers and this isn’t financial analysis: this is just what we’re seeing and thinking through in real time.

The AI thesis

Here’s what’s pulling our attention: we’re seeing increasing interest in using our orchestration protocol for AI agents. And we’ve been developing a thesis around what that means.

The popular narrative is that the agentic economy will be agents doing everything. Dennison’s take is different. What’s actually emerging is the rise of solo founders who can operate entire organizations using agents. The prototype is the product. Technical barriers are collapsing. And that changes the shape of fundraising fundamentally.

The pattern looks like 2008: macro disruption pushes people out of traditional employment, and a wave of them start building. But this time, the tools are radically more powerful. A single person with the right agents can ship a product, find customers, and get to revenue without a team of twenty.

What this means for fundraising

VCs are not going to be able to keep up with the volume of people building new things. The era of pre-seed checks for tens of millions of dollars is ending for a lot of businesses. What replaces it is micro-raises: tens of thousands of dollars, just enough for a couple months to test an idea, then raise again. Maybe your agent co-founder handles part of it.

This is what we’re building toward. We’re developing skills so agents can natively use the orchestration protocol to run their own auctions. But the bigger picture is the tooling we’ve already built: the token sale infrastructure, the transparency, the disclosures. All of it maps directly onto a world where thousands of new founders need to raise capital fast, fairly, and without gatekeepers.

The throughline

It would be easy to look at a soft market and get nervous. We are being thoughtful about timing. But the thesis hasn’t changed: the future of fundraising is on-chain, transparent, and accessible. The AI wave isn’t a distraction from that thesis. It’s an accelerant. The number of people who will need these tools in the next 24 months is about to grow dramatically, and we want to be ready.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 15.

Day 23/60

A milestone today: idOS Network’s token sale is live on the Tally.

What idOS is building

idOS is a decentralized, privacy-first identity operating system for Web3. The core problem it solves: every new app, exchange, or DeFi platform currently makes users repeat KYC and identity verification from scratch. It’s slow, invasive, and creates unnecessary data exposure.

idOS flips that model. You verify once and reuse your credentials across the ecosystem: wallets, stablecoin platforms, DeFi protocols, and more. Your data stays encrypted, self-custodied, and shareable only with your consent. It’s chain-agnostic and open source, designed to work across blockchains rather than locked into a single silo.

For builders focused on compliant onboarding and digital financial services, especially around GDPR, AML, and KYC requirements, idOS is infrastructure-level identity.

Why this matters for us

We’ve been building the Tally token sale platform while simultaneously preparing our own launch. Today is the first external proof point: another team chose to run their sale through our platform.

The sale page is live at tally.xyz/sale/idos. It shows the sale details, how the mechanism works, token information, and project details. These are the kinds of disclosures and transparency that we believe should be standard for every token launch. idOS Network is using the same infrastructure we're building toward for our own token sale: transparent disclosures, fair price discovery, and clear information for every participant.

The throughline

We talk a lot in this series about what we’re building and why. Today is the day the platform stops being a concept and starts being a product with real participants. A team evaluated the options, chose Tally, and their sale is now live with full disclosures, clear mechanics, and transparent project details visible to anyone.

That’s the bar we set for ourselves when we started building this: a platform where any team can raise capital in a way that’s honest, transparent, fair, and accountable. Seeing another team trust it enough to put their own raise on it is the strongest validation we could ask for. And it’s the same infrastructure we’re preparing for our ICO.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 14.

Day 22/60

Dennison’s back in New York after ETH Denver. The event was high signal, and there are other teams preparing to launch on the platform, but the real update is what’s happening behind the scenes: the legal process is now fully underway.

Side letters and investor notifications

If you raised equity and gave investors a side letter, there’s a legal step most people don’t think about until it’s staring them in the face. We’re not lawyers: this is how the process was explained to us by our legal team. The side letter is a promise: if you launch a token, those investors get access to a portion of the allocation. But that promise doesn’t execute itself.

Before the token goes live, every investor on the cap table has to be formally notified. That means documentation: what the token is, how the launch works, what they’re getting, and on what terms. And then they have to sign off. It’s not a courtesy email. It’s a legal requirement, and it takes time, especially with a large cap table.

We’re in this process right now. Dennison is meeting with our legal team at Cooley basically every other day to work through it. The pace is intense, but skipping steps here is not an option.

The valuation problem

Here’s the part that surprised us: you don’t get to pick your own valuation.

When investors exercise their warrants, they need a price. That price has to come from an independent third-party firm that evaluates the protocol: the work that’s gone into it, the complexity of the system, comparable projects, and a range of other inputs. The output is an initial valuation that determines what investors pay for their token allocations.

This matters for two reasons. First, it’s what your investors are actually paying when they exercise. The warrant is a separate instrument from the equity: they have to purchase the tokens, and the price needs to be defensible.

Second, and this is the one that catches people off guard: the valuation affects the team. When team members receive their token allocations, it looks to the IRS like they’re receiving a new asset. If the valuation isn’t handled properly, it can trigger a significant tax liability. For founders with larger allocations, “significant” can mean substantial. Getting this valuation right, and getting it from an independent source, protects everyone.

The throughline

This is the unsexy part of launching a token. No one makes content about cap table notifications and third-party valuation firms. But this is exactly the kind of process that separates compliant launches from ones that create legal problems years down the road.

We’re showing it because it’s real, and because anyone considering a token launch should know that this step exists. Dennison’s advice from the episode: do not skip this process. It will bite you if you do.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 13.

Day 20/60

Before we decided how to launch the TALLY token, we had to answer a question that turned out to be harder than expected: is there actually a token sale mechanism out there that we trust?

For a long time, the honest answer was no.

Every mechanism had the same problem

We looked at every major sale mechanism on the market. Not edge cases: structural problems.

Bonding curves, popularized by platforms like Pump.fun, are simple to understand and a playground for exploitation. There’s no real price discovery happening. The price is set by a formula, not by what the market actually thinks the token is worth.

Dutch auctions sound better in theory but are worse in practice. You start at a high price that decreases over time, and you have to decide: bid now and probably overpay, or wait and risk missing out entirely. It’s a high-stakes timing game, and sophisticated actors will always be better at it.

Batch auctions get closer. They collect all bids over a period and clear at a single uniform price. But all bids are visible on-chain, which means sophisticated traders can watch the demand curve build and then snipe the final blocks with optimally sized bids.

Every mechanism we looked at had the same core issue: they rewarded speed over conviction.

We needed something better

We’re a team launching our own token. We’ve talked a lot in this series about how a token sale is a one-shot event: you don’t recover from a failed launch. We weren’t about to subject the TALLY token to a mechanism where bots could front-run our community, where whales could manipulate the clearing price, or where people who showed up early got punished for it.

We needed something better. For a while, it didn’t exist.

Then Uniswap shipped Continuous Clearing Auctions

In November 2025, Uniswap announced Continuous Clearing Auctions: a new protocol built on top of Uniswap V4. When we saw it, we knew immediately this was what we had been looking for.

CCA runs the auction block by block. Instead of one big batch that clears in a single moment, supply is released gradually across multiple blocks, and each block clears at its own uniform price: the highest price at which all tokens in that block can be sold. Everyone who fills in a given block pays the same price, and no individual trade moves the price.

Here’s the part that really sold us: CCA rewards early participation. When you bid early, your bid is active across all remaining blocks. In early blocks, demand is typically lower, so clearing prices tend to be lower, and your early bid captures allocation at those prices.

That completely flips the incentive structure. In every other mechanism, the smart move is to wait, watch, and snipe. In CCA, the smart move is to show up early with genuine conviction about what you think the token is worth. It transforms the question from “when is the optimal time to bid?” to “what is the maximum price I will pay?”, which is real price discovery.

When the auction ends, all proceeds are automatically deployed to a Uniswap V4 liquidity pool at the discovered price. Instant liquidity from day one. No scrambling for market makers. No thin order books.

Why we’re building on CCA

CCA is MEV resistant. It’s sniping resistant. It rewards genuine participation over bots. It produces real price discovery instead of formula-driven or manipulable outcomes. And it creates liquidity automatically.

That’s why Tally is building around CCA as our primary launch mechanism. When teams come to us, we want to put them on the best available infrastructure. We spent a long time waiting for a mechanism that met the standard we set: not just for our clients, but for ourselves.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 11.

Day 16/60

Cliff, Tally’s Head of Strategy, sits down solo for this one. No product demos, no legal deep dives. Just the conversation he has with nearly every founder who comes to Tally thinking about a token launch: you’re probably not ready yet.

The sequencing problem

There’s a pattern in crypto that everyone recognizes but nobody wants to name. A team has an idea, maybe a whitepaper, maybe a testnet, maybe nothing at all, and their first move isn’t “let’s go find users.” It’s “let’s go raise.” The token becomes the product. The incentives run completely backwards.

Cliff has spent five-plus years across teams like DYDX, Arbitrum, and now Tally, talking to dozens of founders about their token strategies. His advice is almost always the same: slow down.

The core of his argument comes down to one idea: a token sale is a pinnacle event. It’s the single biggest marketing moment a project will ever have. The biggest community-building initiative it will ever run. The one time the entire market pays attention at once. That moment only comes once. If a team doesn’t have a product with genuine traction and real users when it arrives, that moment is wasted.

What happens when teams move too early

Without product-market fit, everything downstream breaks. Projects end up optimizing for the wrong participants: airdrop farmers looking to extract value, speculators flipping on day one. Token mechanics don’t fit because the team hasn’t figured out what the product actually needs yet. Distribution reaches the wrong audience because no one has identified who the real users are.

The harder truth is that most projects don’t recover from a launch that underperforms. The team burns through its biggest window of market attention, the community loses confidence, and the token trades below launch price indefinitely. Now the team is trying to keep building under all that weight. Cliff has watched this happen to strong teams with good ideas who simply moved too early. In most cases, it was avoidable.

The advice

Cliff’s message is direct: give it six more months if that’s what it takes. Ship the product. Build real traction. Attract real users. Then figure out the token.

This is part of why the 60 Days series exists. We’re not documenting the fast way to launch a token. We’re documenting what it looks like to do it carefully, and we’re holding ourselves to the same standard we’d ask of any team. Every decision, every trade-off, every hard conversation: all of it is out in the open.

Why this matters

It might seem counterintuitive for a token infrastructure platform to tell founders to wait. But this is the whole point. The platform we’re building is designed for teams that have done the work: real products, real users, real traction. Helping a team launch before that foundation exists doesn’t serve anyone.

This episode is Cliff laying out the framework we use when evaluating whether a team is ready. It’s the same lens we’re applying to our own process throughout this series.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 10.

Day 15/60

Today’s a different kind of episode. Instead of product updates or strategy sessions, this one’s about the production itself: how we’re actually making this series, what the workflow looks like, and what we’re learning along the way.

The operational side

The 60 Days series runs on a pretty simple system. We plan two to three days ahead, max. There’s a source of truth doc that tracks every episode, and a shared drive where everything gets uploaded once it’s finished.

Every episode also gets translated into Korean for our audience on Twitter and Telegram. That’s been part of the workflow from day one: we’re not treating international distribution as an afterthought.

We have some collaboration episodes coming with partners. We’re not going to say who yet, but those take more planning than the standard daily drops and we’re excited about them.

Building the plane while flying it

We didn’t have the infrastructure for daily video production when this started. We built it as we went. That means the early days were messy: consistently running out of storage, running out of battery, having to airdrop files between devices, mic quality all over the place. If you go back and watch the first few episodes, you can see it.

It’s improving. That’s the point.

A quick production tip for anyone trying something similar: the Blackmagic app for iPhone gets you significantly better video quality than the native camera app. The tradeoff is storage. It eats through it fast.

The hardest part of the edit

The real challenge isn’t filming. It’s cutting. We’re taking hours of footage and conversations and compressing them into two to three minutes. The hardest part of any edit is deciding what to leave out when all of it feels important.

The other constraint is legal. We have to be very careful about the language in every episode. Compliance can’t be a post-production checkbox for us. We review content before it goes out, and that means certain conversations, no matter how interesting, get trimmed or reframed to stay within the guidelines.

The visual evolution

If you’ve been following along, you’ve probably noticed the graphics getting better. Title cards, Substack artwork, YouTube thumbnails, livestream layouts: all of it is evolving as we go. The reality of daily production is that you ship and improve.

That’s going to keep getting better. The team is starting to come together in person more. Dennison’s in Denver, the rest across the globe, and as we get into the final stretch leading up to launch, the production quality will step up. We’re meeting with clients, running team sessions, and building toward a level of polish that matches the stakes.

The throughline

The whole reason we’re doing this series is to show you what it actually takes to launch a token. Our wins, our failures, the unglamorous operational reality of shipping something every single day. You’re going to learn a lot by watching this, but honestly, we’re learning just as much by doing it. The workflow connections and process improvements that come from forcing yourself to produce daily content are serendipitous in a way you can’t plan for.

That’s the bet: build in public, get better in public, and by day 60, have something worth pointing to.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 9.

Day 12/60

Dennison in Dumbo, Brooklyn, filming in front of the Brooklyn Bridge on Presidents Day. Today’s episode is a departure from the usual operational updates: it’s a history lesson. And it’s one that matters for understanding why we’re building what we’re building.

Bonds built bridges

The Brooklyn Bridge was one of the largest infrastructure projects in the world when construction began in 1870. It took 13 years to build and cost about $15 million: an enormous sum at the time. It wasn’t funded by a billionaire or a private corporation. It was financed through municipal bonds issued by the cities of New York and Brooklyn.

That was only possible because of something that happened almost a century earlier. After the Revolutionary War, the United States was financially unstable. The breakthrough came when the federal government, under Washington and Hamilton, consolidated state war debts into federal bonds. That move created credible American sovereign debt for the first time. From that point forward, the country could raise capital not just through taxes, but through markets.

The Brooklyn Bridge is the physical proof of that system working: political authority underwrites taxation power, taxation power underwrites bonds, and bonds finance infrastructure. That’s the American growth engine.

Same principle, new tools

Capital markets are systems for coordinating belief and capital at scale. The tools change across centuries: federal bonds in the 18th century, municipal bonds financing infrastructure in the 19th, equity markets financing corporations in the 20th. Each layer built on the trust infrastructure that came before it.

On-chain capital markets are the next layer. Blockchains allow issuance, governance, and settlement to happen transparently and programmatically. Instead of paper certificates and clearinghouses, you have smart contracts and distributed ledgers. Instead of weeks to settle, you settle in minutes.

What we’re building at Tally is infrastructure for digital capital formation: governance systems that allow communities and organizations to issue, coordinate, and manage capital on-chain. If the 19th century built steel bridges with bond markets, the 21st century may build digital infrastructure with programmable markets. Different tools, same underlying principle: trusted systems that allow capital to flow toward ambitious projects.

Why this matters

It would have been easy to skip today. Day 13, plenty of operational stuff to talk about. But we wanted to make this point explicitly: what we’re doing isn’t new. The mechanism is new. The technology is new.

But the core idea, that credible governance and transparent systems attract capital toward long-term building, is as old as the republic itself.

This is also the kind of content that separates what we’re doing from the typical token launch playbook. Most projects talk about their token. We’re talking about why capital markets exist in the first place, and where they’re going next.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

Over the next 60 days, we’re documenting every step of what it looks like to launch a token the right way, in the United States, in 2026.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 7.

Day 7/60

Dennison is in New York, meeting with Rodrigo Seira from Cooley at their offices in Hudson Yards. The focus today: walking through the legal framework that sits at the center of every token launch in the United States.

The test that governs everything

If you’re launching a token and you want to do it in the US, the conversation starts with the Howey test. It’s the four-part framework courts use to determine whether a transaction qualifies as an investment contract under securities law. All four prongs need to be met: an investment of money, in a common enterprise, with the expectation of profit, derived from the efforts of others.

For a token sale, the first two are difficult to contest. You’re selling something, so there’s an investment of money. Common enterprise is generally presumed. That means the legal analysis often comes down to the last two prongs: whether the purchaser is buying with the expectation of profit, and whether that profit is derived from someone else’s efforts.

Buying to use vs. buying to profit

The expectation of profit prong is where the utility token argument lives. It traces back to a Supreme Court case called United Housing Foundation v. Forman (1975), where people bought shares in a housing co-op. The court ruled that even though the instruments were technically called “shares,” the buyers weren’t making investments. They wanted a place to live. They were buying for utility, so securities laws didn’t apply.

That principle has been tested and expanded through subsequent case law. The standard is whether a reasonable purchaser, given all available information, is buying something because they want to use it or because they’re making a passive investment. It’s a subjective, facts-and-circumstances analysis.

One thing our counsel was clear about: the “utility token” label got a bad reputation during the 2017 ICO boom. Projects would call their token a utility token and assume that was enough to sidestep securities laws. It wasn’t then and it isn’t now. Even tokens with genuine utility can still be sold as part of a securities offering depending on how the sale is structured and how the token is marketed.

Whose efforts matter

The fourth prong looks at whether expected profits are derived from the entrepreneurial or managerial efforts of others. The case law draws a distinction between entrepreneurial efforts, where someone is operating a business, taking risks, and making decisions that drive value, versus ministerial or administrative efforts, like providing a technical service. The analogy our counsel used: paying for an AWS subscription is not the same as giving money to someone who’s running an enterprise on your behalf.

Not all tokens are securities, and not all token sales are either

Beyond the Howey analysis, there’s a broader taxonomy question the industry is still working through. SEC Chair Atkins has outlined his perspective on how different types of tokens should be classified, and Miles Jennings at a16z has published frameworks on the same question.

At a high level, one key distinction is between tokens that are inherently securities (or tokenized versions of existing securities) and those that may not be: utility tokens, collectibles, stablecoins. But there’s an important conceptual point that often gets missed: a token sale can be a securities transaction even if the token itself is not inherently a security. The Howey test has been applied to transactions involving whiskey barrels, chinchillas, even earthworms. None of those things are securities on their own. But when packaged with promises about what a promoter will do, those transactions can become securities transactions.

That distinction matters. It means the analysis isn’t just about what the token does. It’s about how it’s sold, how it’s marketed, and what a reasonable person would expect when they buy it.

The throughline

This is the work most teams do behind closed doors, if they do it at all. The Howey test isn’t a checkbox. It’s a framework that requires you to think carefully about what you’re building, how you’re talking about it, and who you’re selling it to.

We’re showing this because it’s the core of what we believe: if you’re going to launch a token in the United States, the legal analysis is the foundation. Not an afterthought, not a box to check, not something you offshore to avoid.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, legal advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 6.

Day 6/60

Dennison is back in Brooklyn after the Salt Lake City sessions. Today’s episode is a solo check-in filmed on the street: no studio, no slides, just a direct take on the question every founder launching a token is asking right now.

The timing problem

When you’re planning a token launch, timing is probably the single most important variable that affects your raise. It’s also the one you have the least control over. You can build the best product, run the tightest process, have the strongest distribution plan: none of it matters if you launch into a dead market with no attention and no appetite.

Two ICOs launched recently on other platforms and the results were sobering. Hurupay ran a sale on MetaDAO and didn’t hit its minimum raise, so every dollar was refunded. Rainbow Wallet launched with Uniswap CCA and raised only a couple hundred thousand. These are real teams with real products, and the market still didn’t show up the way they needed it to.

That’s the reality of timing. You can do everything right and still get caught by conditions outside your control.

The contrarian case

Dennison’s take is counterintuitive: a down market might actually be the best time to launch. Not because prices are guaranteed to recover, but because launching from a low base means you’re building from the floor rather than falling from a peak. The projects that launch when things are quiet and survive have the strongest foundations when conditions eventually shift.

The broader point is that founders can’t time the market. The political environment is uncertain. Legislation is still unclear. Macro conditions are volatile. Waiting for the perfect window means waiting forever.

What founders can control is execution: the product, the distribution, the team’s ability to ship something people actually want. That’s the thing worth focusing on. Not the chart, not the macro, not the news cycle.

The throughline

This is something we think about constantly as we build toward our own launch. We’re not immune to the timing question. But the conclusion we keep landing on is the same one Dennison lays out in this episode: you focus on what you can control, you build something worth showing up for, and you give it your best shot. Trying to predict conditions you have zero influence over is a trap.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch Episode 5.

Day 5/60

Last day of the SLC offsite. The team drove out to Little Cottonwood Canyon and the Great Salt Lake. No agenda for this one: just a conversation about why we’re building what we’re building and what it’s going to take to ship it in 57 days.

The wrong kind of challenge

One thing Dennison keeps coming back to: the challenges in crypto have historically been the wrong kind. Not “can we find product market fit” or “can we build something people want.” Instead it’s been: is this a scam? Where did the money go? Who actually deployed this contract?

That’s the specific problem Tally is built to solve. The point isn’t to make token launches easy. It’s to make them verifiable, so the real challenge can go back to being: did you build something worth using?

That framing is core to why we’re running this token sale the way we are. Tally’s ICO will use every piece of our own infrastructure. If something doesn’t work, we’ll be the first to know.

Money for the machines

Dennison got into crypto in 2011. His original reasoning: money is the only human concept that isn’t natively communicable over the internet. You can send an email that says “I love you” and the person on the other end feels something. You can send an email that says “here’s a dollar” and they have nothing.

His early mental model was literal: your phone pays the charger for power, the charger pays the outlet, the outlet pays the house. Semi-intelligent machines transacting with each other. It sounded abstract in 2011. It sounds a lot less abstract now that AI agents can reason, write code, and execute transactions.

If the next decade produces a wave of AI-assisted builders and businesses, those builders are going to need infrastructure to raise capital and operate transparently. Not VC pitch decks and Delaware C-corps. Tools that work natively on-chain, available to anyone.

What this means for the ICO

Tyler framed it simply: AI is removing the capability barrier to building. What remains is the infrastructure barrier: financing, incorporation, accountability.

The Tally ICO is how we demonstrate that. We’re using the same tools any project can use on the Tally platform: Uniswap’s CCA mechanism, vesting, liquidity provisioning, and more. 57 days from now, we’ve either shown a working model for transparent, on-chain capital formation, or we haven’t.

That’s the bet. Not a bet on token price. A bet on whether this process works. And we’re documenting every step so anyone who comes after us can see exactly how it went.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch episode 4.

Day 4/60

Dennison, Frisson, and Tommy continued GTM planning in Salt Lake City and sat down to get honest about priorities. There was no shortage of ideas for how to get the $TALLY launch in front of people, but bandwidth is finite. The goal of the meeting was to figure out what actually gets built next and what gets shelved.

Rethinking the roadshow

When we started planning distribution we came up with the idea for token roadshows. Line up institutional investors, pitch meetings, the whole circuit. It’s what you do with an IPO, and since we’re positioning token sales as legitimate capital formation, it felt like the right playbook.

We spent real time on it. Built out a framework internally, pitched the concept a couple times, started scoping what it would take. And then we sat with it honestly and realized: this isn’t the right approach for where we are right now. The market conditions don’t support it, and we’d be spending significant time and resources chasing meetings that probably won’t convert.

So we’re redirecting those resources. Not abandoning the idea forever, but acknowledging that the energy is better spent elsewhere right now.

Distribution, not promotion

We talked about this in the previous episode, but the real question isn’t how to get attention. It’s how to do distribution in a way that doesn’t look like every other crypto launch.

The standard playbook is well known: pay a bunch of accounts to post about your token, hope it drives demand, pretend it’s organic. We’re not doing that. If someone talks about what we’re building, it’s because they actually understand it, they’re operating under a real contract with full paid disclosure, and their content passes through a review process before it goes live.

The other side of distribution is media: podcast appearances, newsletter partnerships, and conversations with outlets that carry real credibility. We’re working on timing that aligns with the launch window, but the bar is the same. Substance over reach.

One thing that came up in the meeting: if we build this process well enough for ourselves, it becomes something we can offer to every team that launches on Tally. The framing matters, and we’re still figuring out the right language for it. But the core idea is that responsible distribution should be a product, not an afterthought.

Going global

The other major decision: we’re expanding into Asian markets. Not eventually. Now.

The infrastructure is being built this week. We’re setting up localized social accounts and community channels for the markets we’re targeting. Different regions have different platform preferences, and we’re building accordingly.

On the content side, Dennison is building Claude-powered automation to manage the translation pipeline. The vision: input the narrative and core content once, generate localized versions across platforms, and have a human review before anything publishes. Tommy is testing AI voice dubbing as a proof of concept, starting with the first episode. If the workflow holds, every video we produce can ship in multiple languages simultaneously.

We’re also exploring whether to send someone to the region to record content with local partners. But that’s dependent on whether initial outreach gets traction. We’re not going to fly halfway around the world to film content nobody is asking for yet.

Spending real money

One thing we committed to in this series is being honest about what this costs. Distribution isn’t free. Media partnerships, production, tooling, localization: it adds up. We’re evaluating several partnerships right now, and the conversations involve real budgets.

Dennison’s position on spending: “the difference between it working and not working is millions of dollars. If we go with the right people, it’s worth spending the money.” We’re being deliberate about where the dollars go, but we’re not being cheap about it either.

The throughline

There’s a moment in the meeting where Dennison says something that stuck: “we’re not going to somehow single-handedly make people want to buy your token. But what we can do is market the shit out of their sale.”

That’s the honest version of what distribution looks like. We can’t manufacture demand. We can’t promise institutions will show up. What we can do is build a real process for reaching people: aligned influencer networks, multilingual content pipelines, media partnerships with outlets that carry credibility. And we can do it in a way that doesn’t rely on the tactics that have made crypto marketing synonymous with scams.

If we get this right for ourselves, it becomes the playbook we hand to every team that launches on our platform. The real product unlock is not just the token sale platform, but the distribution layer that makes it work.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

Watch Episode 3.

Day 3/60

Dennison, Tommy, and Tyler are in Salt Lake City. Cliff is dialing in from Singapore. Today’s strategy session was focused on one question: distribution. How does Tally get the word out about its ICO without resorting to the same tactics that broke the industry in the first place?

The problem we’re solving for

Tyler asked Claude what the most successful ICOs of all time were. The answer: crime.

That’s not a joke. The original ICO era had no transparency, no third-party tools, and no accountability. People made whatever promises they wanted and disappeared. Billions were raised through influencer-driven pump and dump schemes, wash trading, and market manipulation. Most of those tokens are worth nothing now.

The go-to-market playbook that “worked” in crypto was built on:

• No disclosure of paid promotions

• KOLs shilling tokens they were secretly dumping

• Unsophisticated participants getting sold on promises of profit

• No accountability after the sale

It was railroad share days: hucksters selling anything to anybody.

Applying Tally’s product principles to our own distribution

The same transparency principles Tally is building into its token sale platform need to apply to how Tally goes to market. Just like we’re using Uniswap CCA for on-chain price discovery and locking liquidity post-sale, the distribution motion has to match.

We repeatedly landed on rethinking how KOLs work. The function itself is legitimate: tell people that something exists and why it’s valuable. Most teams’ biggest problem is that nobody knows what they’re building. But the way it’s been done is broken.

Dennison’s point: disclosure doesn’t kill effectiveness. Kim Kardashian tells people she’s paid to promote a smoothie. People still buy it. You don’t have to lie. And from the project’s side, you don’t want to raise from people with unrealistic expectations. You cannot promise profit to anyone. So why build a distribution strategy around implying it?

Applying learnings to Tally’s ICO

The team is mapping out a go-to-market strategy built on the same principles as the platform:

• Transparent KOL partnerships: full disclosure, no hidden bags, no undisclosed payments. Treat it like what it is: advertising

• KY(KOL) built into the process: educational materials on what you can and can’t say. Dennison floated an idea for a platform where KOLs register, KYC, sign contracts, and run their content through a check before posting

• Story over hype: the marketing should be about the value proposition of what Tally is building, not “buy this token, it’ll make you rich”

• Paid media and roadshow outreach: done openly, the way traditional advertising works

• Automation and platform integration: bake as much distribution as possible into the product itself

The long-term vision goes even further. If this works, Tally becomes infrastructure where earnest entrepreneurs anywhere in the world can launch tokens, raise capital, and find an audience through a system that’s transparent by default.

The throughline

This is the same argument we are making about the token sale technicals but applied to GTM.

The mechanism should be fair. The pricing should be transparent. The liquidity should be locked. Distribution strategy should be built on the same principles. If you’re cleaning up the space, you have to clean up the whole space.

We're still workshopping and implementing the distribution decisions made during our time in SLC. We will continue to share updates as we progress.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

Over the next 60 days, we’re documenting every step of what it looks like to launch a token the right way, in the United States, in 2026.

This is the project log: a written companion to each daily video. Short updates on what we’re working on, what’s blocking us, and what we’re learning along the way.

Watch episode 2.

Day 2/60

The Plan

Dennison, Tyler, and Tommy are together in Salt Lake City this week to map out the next 60 days. The agenda:

• Go-to-market strategy

• Content production

• Getting all the moving pieces organized for the next 60 days

Why TGE has to come first

The biggest focus right now is legal sequencing. The token needs to be minted 30 to 60 days before any sale happens. The reason: the token can’t have a price when it’s created.

If you mint a token the same day it goes to market, the IRS can assign a value based on what it trades at. That means:

• Team members and early participants could owe taxes on paper value that doesn’t reflect reality

• A high FDV on day one doesn’t mean anyone can actually realize that value

• But the tax bill is real regardless

So the token generation event has to happen well in advance, when the token is provably worth close to nothing. Even then, you need a third-party firm to produce a formal valuation of the protocol. That valuation accounts for:

• Engineering costs and total hours invested

• Audit expenses and who conducted them

• Total capital raised

• Current company valuation

Tally already has a firm engaged on this, but they need a lot of documentation to complete it.

The tax problem nobody talks about

Once the token exists, a whole new tax nexus opens up. The IRS can look at a smart contract, see tokens sitting in it, and ask: who owns that, and who pays taxes on it? Even if the tokens are sitting in a contract that nobody technically controls and that generates no revenue, the answer isn’t as simple as “nobody.”

It gets worse depending on jurisdiction. Some countries, like the Netherlands, are now taxing unrealized capital gains. Think about what that means for a protocol treasury:

• A token gets issued near zero

• It goes through a sale and suddenly there’s a market cap in the hundreds of millions

• You might owe taxes on value that only exists on paper

Where you legally locate the protocol matters enormously, and that’s its own entire workstream.

To-do list

• Engage tax accountants who specialize in token issuance

• Finalize the third-party protocol valuation

• Notify existing investors per warrant agreements

• Mint the token into qualified custody: Anchorage, BitGo, Fireblocks, or similar

• Brainstorm GTM strategies for the next 60 days

This is Day 2 of 60. Each of these topics deserves a deeper dive, and they’ll get one.

We’re documenting everything: the legal sequencing, the tax strategy, the custody setup, the go-to-market, all of it. If you’re building in crypto and thinking about launching a token, this is the playbook we wish existed.

• Follow @tallyxyz on X for video updates

• Learn more about Tally’s token sale platform at tally.xyz

Disclaimer: This content is for informational and educational purposes only. Nothing in this series constitutes financial advice, investment advice, or a solicitation to buy or sell any token or security.

Where it started

Six years ago when we first started Tally, the core idea was simple:

1. What if the cost of capital formation could approach zero?

2. And what if organizations could be created and operated in software instead of being stitched together with paperwork and intermediaries?

That question never really went away. In fact, it just got harder.

Over the last six years, we’ve helped power some of the most important systems in crypto. More than a million people have used software we support. Over a billion dollars has moved through it. And tens of billions of dollars sit behind systems that rely on it.

What that experience has made very clear is this: capital formation is the hardest problem in the stack, and it’s the one that matters the most.

Why ICOs

At their best, ICOs are a way to form capital in the open — without gatekeepers, without backroom deals, and without pretending the hard parts don’t exist. At their worst they’re rushed, opaque, and treated like hype events. They break trust and hurt people.

The problem isn’t the idea. The problem is skipping the work necessary to do the idea right. If on-chain systems are going to be durable, capital formation can’t be improvised or hidden or pushed offshore. It has to be designed carefully and done in the open.

This is what we mean when we talk about on-chain capital markets. And that’s why we’re doing this: and why we’re doing it publicly.

Over the next 60 days, we’re going to show how we think about an ICO from first principles. The legal questions, the design decisions, the trade-offs, and the parts that don’t work the first time. We’re going to work on what we think is the right way to launch a token in America in 2026.

We’re using our own tools and our own process as the case study, because the only honest way to do this is under real conditions with real constraints. Some of our decisions will change. Some of our ideas won’t survive review. And we’re going to show that, too.

If you care about the future of capital formation and how ICOs and on-chain capital markets actually get built, follow along.

We’re going to be showing all of our work.

Tally is the platform to launch tokens, raise capital, and scale. Faster, cheaper, and more globally accessible than IPOs or venture rounds. Over the next 60 days, we're showing exactly how.

Explore Tally · Follow us on X and Youtube

Before diving into on-chain capital markets, it’s worth grounding ourselves in the basics. What are capital markets, and how do they work?

What capital markets do

Capital markets are the systems through which long-term capital is raised, allocated, priced, and traded. They connect capital providers (investors) with capital seekers (companies, governments, projects).

At a high level, capital markets answer four questions: Who needs capital? Who has capital? At what price will capital move from one to the other? And under what rules and protections?

Capital markets are distinct from money markets, which deal with short-term funding like treasury bills or commercial paper, the instruments companies use to cover expenses over short periods.

Primary and secondary markets

There are two markets to understand here: primary and secondary.

Primary markets are where actual capital formation happens. This is where new capital is created. Examples include initial public offerings, follow-on equity offerings, corporate bond issuances, government bond auctions, and private placements like venture capital, private equity, and private debt. In a primary market, investor money goes directly to the issuer.

Secondary markets are where liquidity and price discovery happen. If you’re thinking about tokens, the ICO would be the primary market, and Uniswap would be the secondary market. In traditional finance, secondary markets include public stock exchanges, bond trading desks, and OTC markets. These markets don’t fund the issuer directly, but the liquidity they provide is essential. Without a secondary market, investors would demand a much higher return in the primary market because they’d have no way to exit their position.

Equity, debt, and hybrids

Equity represents ownership claims on residual cash flows. It’s what you classically think of when you think of owning part of a business. Equity is high-risk, high-return, and generally comes with voting and governance rights. Stockholders get to vote. They have some say in the board and thus some control. Equity instruments include common stock, preferred stock, options, and warrants.

Debt is a contractual obligation to repay principal plus interest. It’s lower risk than equity, mostly because debt holders have seniority in bankruptcy. They get paid first, before shareholders, who might not get anything once the debt is netted out. Debt instruments include corporate bonds, government bonds, loans, notes, and asset-backed securities.

Hybrid and structured instruments combine features of equity and debt, generally engineered to reallocate risk in some way. Examples include convertibles, structured notes, and mezzanine debt.

Who makes it work

Capital markets require infrastructure. Issuers are corporations, governments, and financial vehicles like special purpose vehicles or trusts. Intermediaries include investment banks (for underwriting and distribution), brokers and dealers, asset managers, custodians, and clearing houses. Venues are the exchanges: in traditional finance, these are centralized exchanges like the New York Stock Exchange or NASDAQ, plus OTC networks, whether bilateral or dealer-mediated. Regulators set disclosure rules, enforce market integrity, and protect investors; in the US, that's the SEC.

Capital markets as risk-pricing machines

Capital markets are fundamentally risk-pricing machines. The key principles: higher risk means higher expected return (you see this in crypto, where some tokens have very high rates of return but are extremely risky), time value of money, diversification reducing idiosyncratic risk, and systemic risk that can’t be diversified away.

Pricing inputs include cash flow expectations, discount rates, volatility, and correlation with broader markets. The canonical models here are things like discounted cash flow, capital asset pricing model, yield curves, and credit spreads.

Liquidity and market efficiency

Liquidity is the ability to buy or sell something without moving the price. In crypto, liquidity gets discussed constantly. It depends on depth, breadth, and immediacy.

Highly liquid markets in crypto include ETH to USDC or USDC to USDT. In traditional finance, highly liquid markets include large-cap equities (Tesla is extremely liquid) and sovereign bonds.

Illiquid markets in traditional finance include private equity, venture capital, and real assets. It’s hard to get out of a private company. It’s hard to sell land. In crypto, low-liquidity markets are tokens where small sales move the price enormously.

On market efficiency: in practice, markets are efficient enough to be hard to beat, but inefficiencies do exist. You see this in complex instruments, regulatory gray zones where not everyone who might participate is participating, and especially during stress events.

Capital markets versus banking

It’s useful to compare capital markets with banking. Banks are balance-sheet-based, create credit, are relationship-driven, and are intermediated. Capital markets are market-based, allocate capital rather than create it, are price-driven, and are disintermediating, reaching many different people.

Modern finance increasingly shifts risk from banks to markets.

Why capital markets matter

Systemically, capital markets fund innovation and infrastructure. Most good things we have come from capital markets that funded the innovation to create them.

Capital markets enable risk-sharing across society. Many different investors participate in something like Tesla. They encourage disciplined management through pricing, since the price reflects how people think a company is being operated. They also transmit monetary policy and amplify shocks when things are mispriced or overleveraged. The 2008 and 2020 crises are often called capital market plumbing failures, not just bad assets.

Current structural shifts

Several shifts are happening in capital markets right now: passive investing dominance, private markets overtaking public markets, tokenization and on-chain settlement, regulatory arbitrage between jurisdictions, and AI participation in markets.

The question today is less about whether capital markets allocate capital, and more about who controls the rails.

What’s exciting is how crypto is disintermediating many of these functions and making capital markets more efficient, wider, broader.

One of the ideas Tally was founded on is to drive the cost of capital formation to zero and establish incorporation in software rather than jurisdictions. That's where all of this is going, and it's what we're building toward: the infrastructure for on-chain capital markets that makes everything described above faster, cheaper, and more accessible. More on that soon.

Tally provides token infrastructure for the most successful teams in crypto. We help teams launch, govern, and operate token-based systems at institutional scale. If you’re interested in launching with Tally, schedule a free sales consultation.

Digital asset treasury companies were a hot meta in 2025. Now that it’s 2026, it’s worth checking in to see how they’re doing.

DATs are still a big deal in crypto, but performance has cooled off. Many are now trading at a discount to the value of the coins they hold.

What is a DAT?

A DAT is a public company whose main business is to raise capital, whether equity, debt, or convertibles, and use it to buy and hold crypto like Bitcoin or Ether on its balance sheet.

The goal is usually to give shareholders leveraged exposure to the underlying asset and to outperform simply holding the coin, often through active treasury tactics: issuing shares when trading at a premium, using yield strategies, and so on.

For investors who cannot or will not hold tokens or ETFs directly, whether due to mandates, custody, operations, or other reasons, DATs are pitched as a regulated equity wrapper for digital assets.

How are they doing now?

As of late 2025, roughly 200-plus public companies globally have some kind of digital asset treasury strategy, together holding around the low hundreds of billions of dollars in crypto.

However, the DAT trade has struggled. By early 2026, at least 37 of the top 100 Bitcoin treasury companies were trading at a discount to their net asset value. About 40% of them are below NAV overall. In 2025, virtually all major Bitcoin treasury stocks underperformed the S&P 500, and a majority spent more on their Bitcoin than it’s now worth on their books.

The archetype here is the former MicroStrategy, now rebranded as Strategy, which holds about 673,000 Bitcoin, roughly 3% of the eventual Bitcoin supply. The company continues to target aggressive BTC yield and dollar gain KPIs through equity and preferred offerings.

Other large treasuries include firms like Twenty One Capital, Tesla, Block, Coinbase, and Metaplanet. Public companies alone are estimated to hold over one million Bitcoin collectively, about 5% of the supply. Data on corporate holdings is tracked by sites like BitcoinTreasuries.net and CoinGecko.

A newer crop of DATs and Bitcoin standard corporates has broadened beyond BTC into ETH and other majors, with at least one large ETH-heavy treasury accumulating several million ETH by the end of 2025.

Are DATs going to blow up crypto?

DATs concentrate a meaningful chunk of supply, several percent of total Bitcoin plus growing ETH, but this is still a minority versus the broader market, and holdings are spread over many entities.

The real systemic risk is pro-cyclical behavior. If share prices fall and capital markets shut for DATs, they lose the ability to fund new buys. In a severe stress scenario, some could become forced sellers, amplifying drawdowns.

Research notes that the DAT model works best in rising markets with easy capital. In flat or falling markets, persistent NAV discounts, equity dilution fatigue, and debt loads can turn them into a drag instead of a catalyst.

What this means for investors

DATs are basically a levered, actively managed bet on a coin plus equity market and management risk. Spot ETFs, which launched in the US in January 2024, are more like a passive one-to-one wrapper.

In a strong bull market with open equity financing, DATs can outperform the underlying. But investors are exposed to dilution, execution risk, regulation, and the possibility that the stock trades at a discount even when the coin does well.

For someone bullish on crypto and comfortable trading US and global equities, DATs are a high-beta satellite play, not core exposure. Core allocation is usually better done through direct coins or regulated spot ETFs, with DATs as a small speculative overlay if desired.

What to watch in 2026

What happens next is up in the air. If the market rebounds or gets to a healthy spot, DATs could become a better play once again. Right now, the main concern is making sure they don’t become forced sellers.

Tally provides token infrastructure for the most successful teams in crypto. We help teams launch, govern, and operate token-based systems at institutional scale. If you’re interested in launching with Tally, schedule a free sales consultation.

Over the holidays, there was a lot of talk on X from Brian Armstrong, Jesse Pollak, and the Base team about what the Base app needs and how to grow the ecosystem. People gave feedback, threads flew around, and something clicked.

There’s a real opportunity here. Coinbase has all the ingredients to become the kind of company that builders genuinely root for.

The Anthropic model

Think about how Anthropic operates. On paper, they’re a heavily funded AI company on the path to make their founders and early team very wealthy. But the feeling around them is completely different.

They use their own tools the way developers use them. They talk openly about building Claude with Claude; about engineers who don’t type boilerplate anymore because they’re vibe coding with the model. New features aren’t abstract. They show up as concrete boosts to what an individual can build in a weekend.

This past holiday, Claude was the main character. Engineers were home from work, using it, sharing what they built. People loved it.

When Anthropic wins, builders feel it directly. Suddenly someone can scaffold a full app in an afternoon. They can explore an idea they might have shelved before because it was too big for one person. There’s a tight feedback loop between Anthropic’s product roadmap and individual capabilities.

Their success and builder success feel correlated. That’s powerful.

Coinbase has everything it needs

Here’s what’s exciting: Coinbase already has the foundation to create that same feeling.

They’re not just an exchange anymore. They’re a public company with a regulatory moat, incredible engineers, a serious L2 in Base, and a profit-sharing deal with Optimism. Base is moving billions of dollars in value. They have the distribution, the talent, and the positioning to be the place where the next generation of crypto apps get built.

And they’re already shipping meaningful infrastructure. X402 payments. AI integrations. MPC wallets. Smart wallet innovations. These are real tools that expand what builders can do.

The pieces are there. The question is how to connect them to that feeling of shared success.

The opportunity

Imagine if every major Base initiative passed one simple test: Does this make individual builders and users obviously more powerful?

Not “does this create a new market”, but does someone walk away from a new feature feeling like they just got a new superpower? Does the ecosystem feel like a rising tide that lifts all boats?

There’s a version of Base where the default builder experience is: “I can do more here, faster, than anywhere else.” Where Coinbase winning feels like every builder’s toolkit getting better. Where the success stories aren’t about who traded fastest, but about what people built that wasn’t possible before.

That’s the energy that made people love Coinbase in the early days. Brian’s willingness to fight for the technology, the sense that Coinbase’s wins were the community’s wins, that meant everything to people in crypto.

What this could look like

A few things that would amplify that feeling:

Neutral infrastructure. Clear, transparent paths for any great project on Base to get surfaced, funded, and routed liquidity. When builders see that quality rises regardless of partnerships or narratives, they invest more deeply.

Capability unlocks. Tools that lower gas friction. Account models that make UX finally make sense. Payments that feel instant and global. On-chain identity that’s actually useful. Each release making the impossible possible.

Shared upside mechanics. Ways for the ecosystem to win together. When the rising tide is structural, not just rhetorical, people show up differently.

The goal isn’t to copy Anthropic: Coinbase is a big, regulated, publicly listed financial company, not a scrappy AI lab. But the relationship to builders can feel the same: every time Coinbase wins, builders win too.

An invitation

This conversation matters. Not just for Coinbase, but for all the companies in crypto that are winning right now. The ones that figure out how to make their success feel like shared success will build the most durable ecosystems.

For Base builders, people at Coinbase, or anyone thinking about this: what would make Base feel like a place where everyone’s gonna make it? What would make builders genuinely excited when Coinbase ships something new?

Let us know.

Tally provides token infrastructure for the most successful teams in crypto. We help teams launch, govern, and operate token-based systems at institutional scale. If you're interested in launching with Tally, schedule a free sales consultation.

The most important regulatory development to watch in 2026 is the Clarity Act. Here’s where things stand.

Years of ambiguity

For years, U.S. crypto has lived in a gray zone. Regulators stretched decades-old securities and commodity laws over assets and market structures they were never written for. The Digital Asset Market Clarity Act of 2025, universally shortened to the CLARITY Act, was Congress’s first serious attempt to replace that ambiguity with a purpose-built framework.

At its core, CLARITY tries to do three things: define what different kinds of digital assets are, decide who regulates them, and set ground rules for the middlemen who run the markets.

The original purpose

When White House leaders introduced CLARITY in Spring 2025, they framed it as a market structure bill; not about taxing or banning crypto, but about organizing the basic plumbing of trading and issuance.

The key original goals included:

Clear asset classifications. The bill draws a line between digital commodities (like many fungible tokens on mature decentralized blockchains) and investment contract assets that look more like securities.

Regulator demarcation. It gives the CFTC exclusive jurisdiction over spot markets and digital commodities traded on new CFTC-registered venues — digital commodity exchanges, brokers, and dealers — while preserving the SEC’s authority over genuinely securities-like assets and activities.

Modernized protections. It layers in customer asset segregation, anti-fraud and anti-manipulation rules, disclosure and ongoing reporting for certain issuers, and Bank Secrecy Act compliance for intermediaries.

Put simply, the original purpose was to give developers, exchanges, and investors a predictable rule book without forcing everything into the securities bucket by default.

The House version

The House packaged this framework into HR 3633, the Digital Asset Market Clarity Act of 2025, and moved it through both Financial Services and Agriculture committees before passing it on the floor in July 2025.

The House bill defines digital assets on mature blockchains. Assets on sufficiently decentralized, mature networks can qualify as digital commodities and — subject to volume and other limits — avoid SEC registration as securities. It creates new CFTC registration types: digital commodity exchanges, brokers, dealers, and custodians with capital, risk management, record keeping, and customer protection requirements, plus limits on using customer assets (for example, for staking) without express consent. It also preempts some state laws, treating qualifying digital commodities as covered securities for certain purpose — preempting state blue sky registration and easing multi-state compliance difficulty.

On July 17th, the House passed Clarity with bipartisan support and sent it to the Senate, where the real negotiation began.

The Senate’s version

The Senate never simply copy-and-pasted HR 3633. Instead, Senate Banking and Agriculture committees worked up their own digital asset market structure drafts that drew heavily on Clarity concepts but tweaked the balance between consumer protection, enforcement, and innovation.

Analysis of the Banking Committee draft highlights several themes where it diverges from the House approach:

Stronger consumer protection tilt. The Senate draft leans more heavily into guardrails around stablecoins, conflicts of interest, and risk management for trading platforms and custodians—reflecting Banking’s traditional focus on financial stability.

Narrower exceptions. Where the House version carves out a range of technology and infrastructure activities from full securities regulation, Senate language reportedly narrows some exceptions or conditions them on additional safeguards.

More skepticism about preemption. Senators from both parties have signaled more skepticism about broad preemption of state rules and about any framing that appears to strip the SEC of too much authority. That shows up in more explicit enforcement and oversight backstops.

In short, the Senate’s version is less a line-by-line companion bill and more an alternative blueprint built on the same foundations: shared definitions, a central CFTC role for digital commodities, and a clear SEC lane for true securities.

What’s happened since

It’s January 2026 and there’s still no market structure bill in hand.

Since House passage, the story of Clarity has mostly been a story of negotiation. Consumer groups and regulators have all pushed to redraw particular lines. How generous should the path be from investment contract to digital commodity as a network matures? How far should federal law go in preempting states? How tightly should centralized exchanges and stablecoin issuers be supervised?

Commentary throughout mid and late 2025 points to several pressure points:

The SEC-CFTC balance. Stakeholders debated whether Clarity tilts too far toward the CFTC and away from the SEC, and whether that invites regulatory arbitrage or leaves investors exposed.

Treasury and AML expectations. Treasury-focused analysis examined how Clarity’s CFTC-centric model intersects with anti-money laundering obligations, sanctions expectations, and oversight of digital commodity pools.

Political timing. With an election year on the horizon and other legislative priorities competing for floor time, leadership in both chambers needed a package that could get 60 Senate votes without igniting a partisan brawl.

By December, the outlines of compromise had emerged, setting the stage for the first formal showdown over actual legislative text.

What to watch for

Senators on the Banking Committee have landed on January 15th, 2026 for a markup of the crypto market structure legislation widely referred to as Clarity.

The markup is the moment where committee members debate and vote on amendments, then decide whether to send a bill—possibly revised from the House version—to the full Senate. It’s the first on-the-record test of bipartisan support. Reporting suggests many amendments will be hammered out in advance to avoid surprises and reduce floor drama, with Banking and Agriculture expected to coordinate so their pieces of the market structure puzzle fit together.

Optimistic projections envision a path where, if markup goes smoothly, the Senate could pass a reconciled bill within 30 to 45 days and then negotiate final language with the House.

For anyone following regulatory clarity as a theme, January 15th is less the finish line than the moment Congress finally moves from concept to concrete Senate text. The outcome will show whether Clarity remains a House-driven vision or becomes a bicameral framework that can actually reach the president’s desk.

Tally provides token infrastructure for the most successful teams in crypto. We help teams launch, govern, and operate token-based systems at institutional scale. If you’re interested in launching with Tally, schedule a free sales consultation.

This article is adapted from a video essay by Tally CEO & Co-founder, Dennison Bertram. Watch the full video on X.

2025 was an extraordinary year. It started with hope, and now the industry is going through both a reckoning and a struggle to accept what winning looks like. It’s worth reflecting on what happened and what 2026 needs to bring.

2025 was the year crypto became legitimate

We can’t undersell how big that is. For years, building under the Gensler era meant living through lawfare and attacks on crypto. Elizabeth Warren’s “anti-crypto army.” Politicians using words of violence against developers who were just writing code. That was hard for the industry, hard for Tally, and hard for me personally. I was subpoenaed by the SEC for work I did on an NFT project. It cost thousands of dollars to deal with and sapped my enthusiasm for a space I’d been working in since 2013.

My co-founder Raf and I had real conversations about whether building in America was even possible. We live in New York. We have families here. We’re proud of this country and want to build our company here. But we kept asking ourselves: do we have to leave?

That just sucked. And having that cloud lifted this past year has been incredible.

Real progress happened

The GENIUS Act passed in July, the first federal crypto legislation ever signed into law. Stablecoins now have real rules: 100% reserve backing, monthly disclosures, clear licensing paths. This isn’t a small thing. It’s a transformative foundation, and we’ve seen the results. Stablecoin usage has exploded. Traditional businesses building on stablecoins have exploded. That’s what clear regulation gives us.

The SEC under Chair Paul Atkins has been transformative. The crypto task force led by Commissioner Hester Peirce has been incredible. Peirce has run roundtables on everything from custody to DeFi tokenization. We attended the SEC and CFTC harmonization roundtable. We’ve spoken with Commissioner Peirce directly. It’s exciting to see.

But it’s not enough.

What we need in 2026

We need Congress to finish the job and give us a market structure bill so the innovation we’ve seen in stablecoins can play out across all of crypto. We need 2026 to be the year the United States goes from accepting crypto to competing for it. We should be the center of the financial world in crypto.

We need clear regulations that let us build with clarity. We need to know what can be listed where, who regulates what, and what the path is from startup token to network token.

There’s been promising work. Uniswap’s unification proposal. The DUNA (decentralized unincorporated nonprofit association) out of Wyoming, developed by Miles Jennings and co. The DUNA gives participants in decentralized organizations legal liability protection from private plaintiff lawsuits. Now that we have the start of clarity from the government, we have to address private lawsuits, and that’s what the DUNA does. It’s just the start. I expect more states to compete in this space.

Props to Hayden for the unification proposal and moving Uniswap forward in a way that aligns the equity and token discussion happening now in Aave and other communities. There are open questions we’ll hopefully see addressed in 2026. At Tally, our vision is to help make all of this possible, practical, regulated, and clear. But we need to work in partnership with the government. We need clear regulation.

The L2 reckoning

The L2 space is going through challenges. We ended 2024 with an explosion of L2s. The vision was clear: scale Ethereum. And we did. Block space is effectively free now. There’s no excuse not to be on chain when it comes to cost.

But people haven’t moved on chain. The usage numbers are still pretty bad. Ethereum has struggled financially because the revenue that used to go to Ethereum has moved to the L2s, and the L2s aren’t paying that back to Ethereum. The whole ecosystem is suffering.

And here’s the thing: there’s still no app that would make you use an L2. What are the apps driving usage? It’s all speculation, perps, trading, and now capital formation. At the moment, it looks like maybe that’s all we’re going to get. That doesn’t make me happy.

Tally works in the world of capital formation, so that’s exciting for our business. But it’s not exciting for my personal vision of what the ecosystem could be. We need more. We need apps. We need people building fun things, useful things.

It’s fine to abstract away crypto so people don’t know they’re using it. But that means we have to have our own soul-searching moment about what the community of crypto looks like. For years, people used these applications because they were crypto applications. If we move into a world where users don’t even know an app is crypto, then you have to build applications people actually want. That’s hard.

We’re seeing it happen with Shopify, Stripe, Circle, stablecoins, neobanks, all building abstraction layers on top of crypto rails. But that’s payments. Where are the social networks? Why haven’t the social networks worked? We end the year with Farcaster basically becoming a wallet. Where are the social media apps on crypto? They haven’t worked. Props to Friend.tech for trying something exciting. It didn’t work out, but props for trying.

AI has sucked some momentum and excitement out of things. But in 2026, we need to keep building.

Revenue on chain

I want to see scaling revenue on chain. Real businesses. People have been building on token emissions, points programs, airdrop farming disguised as community building. But we want revenue. We want businesses that charge for their services.

Ethereum spent too long trying to nuke anyone being able to have a business by making everything a public good. That was a negative experience. Most public goods besides Ethereum haven’t fared well because there’s no structural market mechanism to invest properly, to search for product-market fit. There’s no revenue at the end of it. You can’t operate organizations without revenue. They have to make money.

In 2026, I’m looking forward to more revenue-generating organizations that lean into charging users. This matters because Gmail is free, Google is free, because you are the product. They’re monetizing you. In crypto, you pay for stuff so you don’t get monetized.

I’m willing to pay to use something so I’m not the product. I don’t want my data to be the product. We need to step back from “free as in free” and build real businesses. Protocols need to generate revenue. Otherwise, the music stops. When you look at the VC investment market, the music has already stopped. Investments have gone down dramatically and focused on a small number of large winners. That’s not positive.

More Ethereum, more innovation

I want to see more from Ethereum. I’ve been excited to see the updates the Ethereum Foundation has made. They’ve listened to the community. They got their act together. I still love building on Ethereum. It’s fun to write smart contracts. It’s fun to build in an ecosystem that’s so deep. You can do anything here.

Props to all the other ecosystems too. I’m a bit of an ETH maxi, although that has hurt me financially. But I’m also excited for the alt L1s: Monad, MegaETH, Kanto, Tempo. I’m especially excited for ultra-fast EVM chains. What can we build when things are really fast?

I’m excited about the ecosystems we work with: ZKsync, Arbitrum, and many more. There are a lot of teams keeping the spirit alive.

Privacy matters

For years, I gave up on privacy. I felt like people didn’t care. The government already knew everything about you. I was wrong.

Privacy is real and critical. It’s probably going to be the most important thing because now, with LLMs and AI, privacy is essential. ChatGPT literally knows everything about you. And now that crypto knows everything about you too, we need private crypto. We need private blockchains. We need to build an entirely new category.

Privacy is one of the things I’m most excited about. I don’t know yet how to get deeper involved or how to use it in a way that works, but it’s deeply on my mind.

Looking ahead

It might feel like the doldrums right now, but keep the spirit up. We’re doing great things in this ecosystem. Tally is building cool stuff. If you’re looking to launch a protocol or a token in 2026, come talk to us. We’re building the best ICO platform in the industry, along with the best suite of tools for operating organizations on chain.

See you in 2026.

Tally provides token infrastructure for the most successful teams in crypto. We help teams launch, govern, and operate token-based systems at institutional scale. If you’re interested in launching with Tally, schedule a free sales consultation.