According to the bill, developers and infrastructure providers will be excluded from the federal definition of money transmitters as long as they do not have legal rights or unilateral ability to move users' digital assets. Cynthia Lummis stated that developers who merely write code and maintain open-source infrastructure should not be classified as money transmitters without touching, controlling, or accessing user funds. Ron Wyden stated that forcing developers who write code to follow the same rules as exchanges or brokers is technically infeasible and could infringe on privacy and freedom of speech.

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