SEC Targets Consensys for Brokerage Activities in Lido and Rocket Pool Investments

VI. CONSENSYS ALSO ACTS AS A BROKER WITH RESPECT TO THE LIDO AND ROCKET POOL INVESTMENT CONTRACTS.

324. Through its MetaMask Staking program, Consensys also acts as a broker by effecting transactions in the Lido and Rocket Pool investment contracts for the account of others.

325. As alleged above, Consensys solicits potential investors, holds itself out as a place to buy and sell the investment contracts, and recommends which of the two investment contracts will offer the highest rewards.

326. Consensys then effects the transaction on the investor’s behalf.

327. Specifically, as noted, Consensys through the MetaMask Staking software handles the investor’s assets by removing the investor’s ETH from the investor’s MetaMask wallet and transferring it to the MM Staking Router Smart Contract, which, in turn, transfers it to the Lido or Rocket Pool proxy smart contract.

328. Finally, Consensys’s software, transfers the acquired token—stETH or rETH—into the investor’s MetaMask Wallet.

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