TD Cowen Warns Crypto Market Structure Bill Could Slip to 2027 Amid Political Gridlock

Highlights:

• The crypto market structure bill could be delayed until 2027 as US political incentives favor waiting.
• Disputes over conflict-of-interest rules for senior officials continue to block progress on the bill.
• Senate vote math allows Democrats to slow the bill until the remainder after the 2026 midterm elections.

TD Cowen has warned that the crypto market structure bill could face delays until 2027 due to political realities in Washington. The firm expects implementation to stretch into 2029. According to its analysis, current incentives do not favor quick action. As a result, lawmakers continue to move cautiously.

TD Cowen said U.S. crypto market structure legislation could see progress this year, but is more likely to pass in 2027, with final rules potentially taking effect as late as 2029. The note said a key hurdle is debate over conflict-of-interest provisions, with Democrats seeking…

— Wu Blockchain (@WuBlockchain) January 6, 2026

Despite that outlook, a legislative path still exists this year. Congressional staff have worked on technical language for several months. Therefore, the groundwork for negotiations already exists. Talks could advance quickly if party leaders decide to engage. However, political timing remains the key obstacle.

Democrats might be willing to wait as long as they feel that they can make gains during the 2026 midterm elections. House control might change regulatory leverage. The prospect of this lowers the immediate pressure to compromise. Consequently, the leadership may delay difficult decisions. This strategy keeps options open ahead of the election cycle.

Republicans, however, continue to push for faster clarity. They argue that markets need defined rules sooner. However, this pressure has not changed the broader political balance. The committees have slowed activity as a result, and the preparation has not translated into floor votes.

The past legislative examples support a slower process. The GENIUS Act followed a multi-year implementation timeline. Lawmakers often design financial laws with delayed enforcement. This approach reduces immediate political risk. Therefore, long timelines now appear normalized in Washington.

Crypto Market Structure Bill Runs Into Conflict-of-Interest Roadblock

The conflict-of-interest provisions in the crypto market structure bill have emerged as the main point of friction. Democrats want strict limits on crypto ownership by senior officials and families. They argue these limits protect market credibility. The proposal has drawn strong resistance from President Donald Trump. This disagreement has stalled negotiations.

Trump has opposed any provision that would take effect during his term. Analysts say immediate enforcement would end talks. Bloomberg estimated Trump-linked crypto ventures generated about $620 million. These ventures include World Liberty Financial and related family projects. As a result, scrutiny around exemptions has intensified.

The Trump family also holds a stake in American Bitcoin, and lawmakers have raised concerns about that involvement. Attention has also focused on the TRUMP and MELANIA memecoins. These tokens launched shortly before Trump took office. Democrats view these issues as justification for strict rules.

Republicans, however, are seeking flexibility on enforcement timing. They argue that a delayed application could preserve negotiations. TD Cowen outlined one compromise option. The conflict provision could take effect three years after enactment. That delay would push enforcement beyond the next inauguration.

🚨 JUST IN: 🇺🇸 Senate Banking Committee confirms Bitcoin and crypto market structure bill will not advance in 2025

Markup now expected in early 2026

h/t @EleanorTerrett pic.twitter.com/a1TWUvaTg0

— Bitcoin Archive (@BitcoinArchive) December 15, 2025

Under that approach, the rule would not apply to Trump. Democrats may resist such a concession. TD Cowen said Democrats would likely demand equal delays across the full crypto market structure bill. That trade would shift the entire timeline as both sides continue to weigh the political cost.

Senate Vote Math and Timing Shape What Comes Next

The Senate rules add further pressure to the process. Lawmakers must overcome a 60-vote filibuster threshold. Republicans need backing from at least seven Democrats. In practice, analysts expect eight or nine votes. Some Republicans may also oppose the bill.

This dynamic makes Democratic leverage stronger. Lawmakers have time to postpone action on the crypto market structure bill until midterms. Regulatory control could be influenced by a subsequent enactment as well. If Democrats win the White House, agencies could influence final rules. Timing, therefore, carries strategic value. Senate committees still plan to review the issue later this year. Lawmakers will also focus on the CLARITY Act in upcoming discussions. A bipartisan meeting is scheduled before the MLK recess.