via http://gbatemp.net/?page=2

If you haven't been following the 3DS scene over the past few weeks you may have missed out on the release of the 1st 3DS-mode homebrew. Yes, that is correct, a new era of homebrew and development is upon us. The method for executing homebrew code requires a ROP (Return Oriented Programming) exploit. Once the exploit is installed, from any 3DS compatible DS-Mode flash kit, a homebrew compiled Launcher.dat can be executed via familiar methods. The exploit requires 3DS firmware 4.1-4.5.

The ROPLoader by Fierce Waffle does not require encryption and it frees us from the malicious tyranny of the Gateway team. A recent build script by Kane49 allows coders to compile C code. While things are moving slowly, they are progressing in a positive direction.