Dec. 01, 2021
To Whom It May Concern: As an investor, I have been directly harmed by the SEC's 'regulation by enforcement' approach, most especially with respect to cryptocurrencies. I implore the Commission to desist from this approach in relation to this new asset class. It does not conform to the regulatory framework of older asset classes (such as the Howey test) and attempting to force it into that paradigm is stifling innovation and threatens to undermine the United States' status as a global leader in financial progress. I do not believe the SEC is the proper regulatory body for digital assets in the first place. But if the Commission insists upon playing a role in the space, Commissioner Peirce's safe harbor approach is a much better path--one that encourages innovation while maintaining the Commission's stated purpose of protecting investors. The current (haphazard) selection of winners and losers by lawsuit is directly contrary to that stated purpose. Such a a clear, broadly applicable set of rules are in the interest of all investors. Regulation by enforcement does not provide such clarity--quite the opposite. Thank you for your time and attention. -- Cordially, C. Dodd Harris IV Attorney at Law