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
Consensys Software Inc.

Re: Staking Services Revenue Recognition Accounting Guidance 		Custody, Regulatory Sandbox, Security Status, Trading
  • Current application of ASC 606 results in misleading gross revenue recognition for staking service providers, treating them as principals rather than agents.
  • Consensys requests SEC guidance to recognize only service fees as revenue, reflecting the economic reality of staking services.
  • Misleading gross revenue treatment impacts financial transparency, investor understanding, and regulatory compliance for staking service providers.
John A. Zecca, Nasdaq, Inc.

Digital Assets Sandbox Comment 		Custody, Regulatory Sandbox, Tokenization, Trading
  • Sandboxes should have clear objectives, focused scope, transparent procedures, prudent guardrails, and appropriately timed durations and exit procedures.
  • The existing market structure and regulatory regime, including Regulation NMS, can accommodate many elements needed to tokenize securities, making a sandbox unnecessary for this purpose.
  • Sandbox exemptions may be useful for digital assets that exhibit some but not all attributes of securities and to address friction points in the current system for trading tokenized securities
Alan Konevsky, tZERO Group, Inc.

Re: Crypto Task Force Meeting with tZERO Group, Inc. – Follow-Up Notes 		Custody, Safe Harbor, Security Status, Trading
  • Establish permanent guidance and rules for broker-dealer self-custody of digital asset securities, building on the SPBD Statement.
  • Clarify the manner in which broker-dealers can retail, custody, and quote non-security crypto assets on alternative trading systems.
  • Issue new guidance to clarify the definition of a digital asset security and its compliance requirements.
BSV Blockchain Association

Public Comment for the SEC Conference - "Emerging Trends in Asset Management" 		Custody, Public Offerings, Security Status, Tokenization, Trading
  • The BSV Blockchain Association advocates for a regulatory framework that distinguishes between digital assets serving as data infrastructure or utility tokens and those operating as financial instruments.
  • The Association supports the development and recognition of "digital commodities" where an asset's value is derived from its underlying blockchain system's utility rather than speculative activity.
  • The BSV Blockchain's Digital Asset Recovery (DAR) framework integrates legal due process with blockchain operations, allowing for lawful asset recovery without altering historical blocks.
Nilmini Rubin, Hedera

Subject: Comments on the SEC Crypto Task Force’s Questions Concerning Safe Harbor from Registration 		RFI Responses, Safe Harbor, Security Status, Tokenization
  • The Hedera Council supports the establishment of a token safe harbor to provide regulatory certainty and transparency for new and existing companies in the digital asset industry.
  • The Council suggests modifying the definition of Network Maturity to include decentralized governance coordinated through a legal entity, termed as a "Decentralized Wrapper," to protect participants from general liability.
  • The Council advocates for retroactive availability of the safe harbor contingent upon full compliance with disclosure requirements to enhance market transparency and investor protection.
ReFiESG Labs LLC

R-TaaS — Regenerative Tokenization as a Service One-Pager Overview 		Tokenization, Trading

  • R-TaaS (Regenerative Tokenization as a Service) allows tokenization of real-world ESG assets onto the ReFiESG Blockchain using ESG-backed Digital Twins.
  • The system uses pre-minted, asset-linked tokens (UBID, PAT, NZN) to anchor real-world value in a programmable, regenerative economic system.
  • R-TaaS provides budgetary liquidity without debt, enables true ESG monetization, and creates proof-of-impact financial systems.
ReFiESG Labs LLC

Pre-Whitepaper: The Rise of ESG 2.0 Humanity’s Final Financial Upgrade Regenerative Tokenization of Everything, Forever. Tokenizing Life, Earth & Governance through ESG-Backed Digital Twins The New Operating System for a Post-Debt, Post-AI World. 		Custody, Public Offerings, Tokenization
  • The ReFiESG Standard introduces a new financial system backed by human existence, aiming to support 144 trillion future humans and last for at least 1,000 years.
  • The ReFiESG Blockchain is designed as a Layer Ø Absolute Zero Covenant Chain, ensuring that all value is anchored in verified human life through Proof of Humanode State (PoHs).
  • The ReFiESG Dynasty Trust secures the pre-minted 144 trillion PAT tokens, governed by a multisig structure involving the Founder and 24 Universal Mothers, ensuring transparent and accountable distribution of regenerative value.
     
ReFiESG Labs LLC

Policy Brief: Esgatocurrencies – A Regenerative Currency System for a Post-Debt, Post-AI Civilization 		Custody, Regulatory Sandbox, Tokenization, Trading

  • Esgatocurrencies are non-tradable, non-inflationary, and backed by real-world ESG assets.
  • The ReFiESG protocol requires SEC No-Action Relief or sandbox recognition, federal/state-level permission for Treasury DAOs, and approval of Debt-for-Esgatocurrency programs.
  • Esgatocurrencies enable sovereign UBI distribution and post-AI income models, governed by public Treasury DAOs.
     
Kecheng Lai, Knowpia Inc.

Recommendation Letter - From End User Distribution to Social Mining: Evolving Frameworks for Token Dissemination and Community Engagement in the Digital Asset Economy 		Safe Harbor, Security Status, Tokenization, Trading
  • The "End User Distribution" concept is designed to distribute digital commodities without constituting an offer or sale of a security or commodity.
  • "Social Mining" allows users to earn tokens through non-financial contributions, directly linking token issuance to platform value creation.
  • The STO+ framework proposes a dual-nature token model, where tokens transition from utility to security status based on specific conditions.
Rebecca Kacaba, DealMaker

Re: Securities and Exchange Commission’s (“SEC” or “Commission”) Crypto Task Force (the “Task Force”) Invitation For Public Commentary Regarding Public Offerings Of Crypto Assets, Safe Harbor From Registration and Tokenization 		Public Offerings, RFI Responses, Safe Harbor, Tokenization, Trading
  • DealMaker emphasizes that Regulation A provides a strong foundation for crypto asset offerings and suggests removing the $75 million cap to better accommodate high-growth, capital-intensive sectors.
  • The letter advocates for adaptable disclosure requirements tailored to crypto assets, focusing on risk and ongoing managerial efforts to enhance investor protection.
  • DealMaker supports clear guidance on secondary market trading for tokenized assets, including federal preemption of state law compliance for secondary trading through registered systems.