Crypto Task Force Written Input

Please find written input submissions to the Crypto Task Force below. The written input is posted without modification. We hope sharing the submissions will help encourage productive dialogue and continued engagement. Please note that the “Key Points” and “Topics” are AI generated. AI can make mistakes, and the Key Points and Topics are not a replacement for you reading the submissions. The Crypto Task Force has not reviewed these AI-generated summaries for accuracy or completeness. If you believe a Key Point or Topic is inaccurate, please email the Crypto Task Force at crypto@sec.gov. The written input provided to the SEC and posted on this page does not necessarily reflect the views of the Crypto Task Force or others in the U.S. Securities and Exchange Commission.

Date Written Input Topic(s) Key Points
Ravi Srivastava, Chief Technology Officer, Akemona, Inc.

Subject: Recommendations for Enhancing Regulation Crowdfunding (Reg CF) Through Blockchain Technology 		Custody, Tokenization, Trading
  • Enable secondary trading of tokenized Reg CF securities via public blockchains to enhance liquidity and reduce counterparty risk.
  • Allow CEO-certified financial statements for raises up to $500,000 to lower capital-raising costs for startups.
  • Permit smart contract-based escrow in place of qualified custodians for raises up to $1 million to reduce costs and improve efficiency.
Unit 410, LLC

Request for Regulatory Guidance – Qualified Self-Custody 		Custody, RFI Responses, Safe Harbor, Security Status
  • Proposes a Qualified Self-Custodian (QSC) framework for Registered Investment Advisers (RIAs) to self-custody digital assets when traditional Qualified Custodian (QC) options are unavailable.
  • Emphasizes the need for RIAs to document their fiduciary judgment and implement safeguarding principles to protect investors while self-custodying digital assets.
  • Requests interim regulatory guidance and potential rulemaking to address the regulatory gap and facilitate secure, legal, and practical self-custody solutions for digital assets.
Securitize, Inc.

Re: Responses to Crypto Task Force Questions related to Tokenized Securities 		Custody, Safe Harbor, Security Status, Tokenization, Trading
  • Tokenized securities should be treated as traditional securities, with permissioned assets transferable across whitelisted wallets using smart contracts to enforce lawful transfers and track ownership changes.
  • Permissionless public blockchains should be allowed for the issuance, trading, and tracking of tokenized securities, with relevant market participants responsible for evaluating the security and soundness of the infrastructure.
  • Broker-dealers should be allowed to engage in a full array of activities, including custody, trading, and settlement of tokenized securities, without the need for segregation or special licensure.
Deloitte & Touche LLP

Re: Crypto Task Force Written Input 		Custody, RFI Responses, Security Status, Trading
  • Deloitte encourages the SEC to align its work with the President’s Working Group on Digital Asset Markets to propose a Federal regulatory framework for digital assets.
  • Deloitte emphasizes the need for a principles-based framework rooted in established laws and regulations to ensure predictability and adaptability as the digital asset market evolves.
  • Deloitte highlights the importance of coordination among regulators and standard setters to avoid regulatory fragmentation and reduce the risk of regulatory arbitrage.
Donna Redel, Ivo Entchev, Olta Andoni, and Stephen Rutenberg, Crypto Policy Working Group

Letter to the Crypto Task Force 		Custody, Security Status, Trading
  • Self-custody wallets are not considered custodians under U.S. securities law as users retain exclusive control over their private keys and assets.
  • Self-custody wallets do not meet the definition of an exchange under the Securities Exchange Act of 1934, as they do not match orders or facilitate securities trading among multiple participants.
  • Self-custody wallets are not brokers under the Exchange Act, as they do not solicit transactions, route orders, match trades, or hold funds in escrow on behalf of clients.
North Capital Private Securities Corporation

RE: Custody of Tokenized Securities by Clearing and Carrying Broker-Dealers 		Custody, Tokenization, Trading
  • The document emphasizes the need for the SEC to differentiate between Bearer Digital Asset Securities (BDAS) and Tokenized Securities in its regulations, as the risks associated with BDAS do not apply to Tokenized Securities.
  • It argues that Tokenized Securities should be treated like traditional securities if they incorporate key safety attributes, such as maintaining a redundant secondary record on the blockchain and not being issued in bearer form.
  • The document urges the SEC to provide new interpretive guidance or no-action relief to allow broker-dealers to use issuers or transfer agents as control locations for Tokenized Securities, facilitating scalable solutions for clearing and custody.
Plume Network Inc.

Subject: Comments on the SEC Crypto Task Force’s “There Must Be Some Way Out of Here” Request for Input Questions 		Regulatory Sandbox, RFI Responses, Safe Harbor, Tokenization
  • Permissionless or open, public blockchains, including decentralized finance (DeFi), are best positioned to enable the SEC to meet its policy goals relating to capital and digital asset markets.
  • Safe harbor exemptive relief should extend to the Securities and Exchange Act of 1934, as well as the Securities Act of 1933, and incorporate specific considerations related to DeFi.
  • The SEC should implement a regulatory sandbox for securities tokenization on open blockchains to develop a new regulatory architecture leveraging open blockchains and complementary technologies.
John A. Zecca, Nasdaq, Inc.

Re: Nasdaq’s Crypto ETP Response to the February 21, 2025 Statement by Commissioner Hester Peirce Entitled “There Must Be Some Way Out of Here” 		Crypto ETPs, Safe Harbor, Security Status, Trading
  • Nasdaq supports a balanced framework that enables innovative crypto ETP offerings while maintaining regulatory safeguards to protect investors and market integrity.
  • Nasdaq urges the SEC to modernize its approach and support the development of the digital asset ecosystem on national securities exchanges along more consistent lines.
  • Nasdaq recommends that the SEC work with national securities exchanges and market participants to establish clear and consistent standards for evaluating crypto ETP proposals.
Blockchain Association

Re: Written Input Regarding Trading-Related Topics 		Custody, RFI Responses, Security Status, Trading
  • The Blockchain Association (BA) advocates for an incremental, flexible approach to regulating crypto asset trading, emphasizing the need for the SEC to adapt existing rules to accommodate technological and market innovations.
  • BA suggests that the SEC should not impose requirements for investors to transact through intermediaries, and should leverage blockchain technology to enhance market efficiency and transparency.
  • BA recommends specific updates to SEC rules, including relief from certain timing requirements for trade confirmations, modifications to net capital rules for broker-dealers, and allowing blockchain-based books and records for regulatory purposes.
Center for Audit Quality

Re: Commissioner Hester M. Peirce’s Statement There Must Be Some Way Out of Here 		Custody, Security Status, Trading
  • The CAQ supports increased regulatory clarity related to crypto assets and commends the establishment of the Crypto Task Force to advance this objective.
  • The CAQ encourages the SEC to coordinate with the Financial Accounting Standards Board (FASB) and Public Company Accounting Oversight Board (PCAOB) to provide additional accounting and auditing guidance for crypto assets.
  • The CAQ highlights the importance of stakeholder education on crypto assets for capital markets stakeholders, including investors and board members.