On July 22, 2026, SEC Commissioner Hester Peirce issued a statement titled “Headstands and Summervaults,” identifying on-chain vaults and lending strategies as potential subjects of existing securities law. This report by Tiger Research examines the parties likely to be affected and how the industry is responding. Key Takeaways Applied broadly, the legal reasoning could extend beyond vaults and curators to discretionary products generally, a segment representing approximately $25.9 billion in TVL.