United States Compliance

It is our intention that the Defi Trading Club will operate as an investment club or series of investment clubs. An investment club is generally a group of people who pool their money to invest together. Club members generally study different investments and then make investment decisions together—for example, the group might buy or sell based on a member vote. Club meetings may be educational, and each member may actively help make investment decisions. – Guidance from the SEC Website It is our interpretation that the issuance of the Defi Trading Club (DTC) token is not a security because: Generally, a membership interest is an investment contract if members invest and expect to make a profit from the efforts of others. If every member in an investment club actively helps decide what investments to make, the membership interests in the club would probably not be considered securities. – Guidance from the SEC Website. Furthermore we put forward that a membership interest shall be characterized as a digital consumer asset as defined in W.S. 34-29-101, if designated as such in the organization’s articles of organization or operating agreement, which it is. We also contend that Defi trading Club meets the SEC exclusion from registering as an investment company for the following reasons:

1. The initial offering of the DTC token is not an issuance of a security for the reasons listed above.

2. The initial offering of the DTC token is not available to the public and is only being offered in our existing limited crypto community.