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
Noah Axler, Injective Labs Inc.

Letter from Injective Labs Inc. 		Crypto Lending, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • Clarify that decentralized finance protocols do not constitute "exchanges" or "broker-dealers" under the Exchange Act if there is no meaningful human intermediation or custodial control.
  • Establish a safe harbor framework for DeFi trading and lending protocols that are progressing toward decentralization, modeled on Commissioner Peirce’s proposed Rule 195.
  • Exclude neutral frontend interfaces from broker-dealer rules if they merely facilitate user access to DeFi protocols without exerting control over user assets or transaction execution.
     
CoinList

Re: Response to Crypto Task Force Request for Comment and Request for No Action Relief 		RFI Responses, Security Status, Tokenization, Trading
  • The letter urges the SEC to recognize convertible digital instruments, such as SAFTs and token warrants, as "qualifying investments" under Rule 203(l)-1 of the Investment Advisers Act of 1940, arguing that these instruments are functionally and economically similar to traditional venture investments.
  • It highlights the operational and compliance burdens created by the current regulatory definitions, which exclude these digital asset structures, thereby hindering capital formation and innovation within the blockchain sector.
  • The letter proposes that regulatory clarity on the treatment of these digital assets would enhance U.S. competitiveness, bring more activity onshore, and prevent the exodus of innovation.
Courage Kimber, Crypto Education & Research

File No. SR-CboeBZX-2025-012 (Final Statement) 		Crypto ETPs, Security Status, Trading
  • Solana has experienced multiple network outages and degraded performance, raising concerns about its reliability and decentralization.
  • Solana is mentioned as an unregistered security in several SEC lawsuits, questioning the legitimacy of its ETF consideration.
  • The pending class action lawsuit claiming Solana is an unregistered security needs to be resolved before ETF approval.
Daniel Bruno Corvelo Costa

Complementary Strategic Report SEC Task Force / Cryptoassets 		Regulatory Sandbox, Security Status, Tokenization, Trading
  • Proposes adaptive regulatory mechanisms integrating high-trust identity layers, dynamic behavioral mapping, technical contract certification, contextual compliance, critical infrastructure protection, and civic transparency.
  • Suggests a distributed technical certification authority to validate smart contracts handling significant financial values, including analysis of hidden logical gates, failure predictability, manipulation traces, and compliance with cryptographic standards.
  • Recommends new regulatory criteria for entities moving digital value, ensuring non-imposing harmonization with global regulatory blocs to maintain effectiveness without stifling innovation.
Mohamed ElBendary

The Normative Theory of Web3 Commercial Integrity - Foundational Framework for Technology-Native Regulatory Clarity 		Regulatory Sandbox, Security Status, Tokenization, Trading
  • The framework provides a falsifiable method for system assessment, enabling empirical validation of compliance architectures and evidence-based policy development.
  • It bridges innovation and compliance by demonstrating how decentralized systems can achieve regulatory objectives through architectural design, reducing systemic risk and enhancing transparency.
  • The framework supports practical implementation through modular governance models, adaptable systems, and standardized evaluation for regulatory oversight.
Mohamed ElBendary

The Normative Theory of Web3 Commercial Integrity 		Custody, Public Offerings, Security Status, Tokenization, Trading
  • The paper introduces a normative theory centered on five interdependent principles: enforcement, trust, duty segregation, governance, and adaptability, which are collectively necessary to uphold investor protection, maintain efficient and orderly markets, and ensure transparent capital formation.
  • It emphasizes the importance of atomic on-chain rule enforcement, where all compliance rules are enforced within each transaction context to prevent execution-path-dependent violations and regulatory arbitrage.
  • The paper highlights the need for on-chain segregation of duties, ensuring that roles such as protocol developers, auditors, and compliance functions have distinct, verifiable identities to prevent governance failures and maintain system-wide accountability.
Daniel Bruno, Corvelo Costa

Strategic Technical Report 		Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • Immediate reinforcement of KYC/AML and real-time monitoring for exchanges, DEX, and DeFi protocols.
  • Prohibition of operation for platforms that do not implement minimum verification protocols.
  • Formation of a task force integrating SEC, Chainalysis, and blockchain forensic experts for immediate asset freezing linked to suspicious addresses.
Dylan Lowe, Davis Wright Tremaine LLP

RE: Comment on Regulatory Framework for Digital Assets and Tokenized Securities 		Custody, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization

  • The letter requests the SEC to issue interpretive guidance or no-action letters for tokenized insurance-backed bonds to provide legal clarity and support innovation.
  • It proposes the creation of a regulatory sandbox or pilot program for developing and testing tokenized insurance products in a controlled environment.
  • The letter recommends updating the SEC's "Framework for 'Investment Contract' Analysis of Digital Assets" to explicitly address tokenized real-world assets like insurance products.
     
Deborah Djeu, Arca

RE: “That’s Our Two Satoshis” - Fixing Token Valuations: Arca Proposes Adjusted Market Cap Standard 		Security Status, Tokenization, Trading
  • Arca proposes an adjusted market cap standard to address the incorrect calculation of market cap by other services.
  • The document emphasizes the need for a more effective methodology to account for the number of tokens actually issued, outstanding, and held back by the Treasury.
  • Arca introduces the term "Adjusted Market Cap" to provide a more accurate representation of a token's market value, considering factors like issued tokens, locked tokens, and tokens held by private investors.
Roberto Braceras, Fidelity Investments

Re: Request for Information on There Must Be Some Way Out of Here 		Crypto Lending, Custody, RFI Responses, Safe Harbor, Trading
  • Fidelity supports the withdrawal of the Joint Staff Statement on Broker-Dealer Custody of Digital Asset Securities and recommends identifying best practices for broker-dealers that custody digital assets.
  • Fidelity urges the SEC to clarify that a broker-dealer may offer its customers a fully-paid lending program for digital assets.
  • Fidelity recommends establishing a safe harbor to support secondary trading of digital assets that are not investment contracts.