1210-AC38 comment 2477 Democracy Defenders Fund 05292026

Summary: Democracy Defenders Fund (DDF), a non-profit organization, opposes the proposed rule because it argues the rulemaking process is structurally compromised by the President's personal financial conflicts of interest in the digital asset market. They contend that the President's financial stakes and executive orders effectively strip the Department of Labor of its ability to engage in impartial, reasoned decision-making, making the proposed rule arbitrary and capricious.