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
Joris Delanoue, Fairmint, Inc.

Comment on SEC Crypto Task Force and Framework for Onchain Equity Securities Markets
Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • Fairmint, Inc. proposes a framework for onchain equity securities markets that emphasizes protocol-level standardization, real-time regulatory observability, and modernized investor protections.
  • The framework includes recommendations for regulatory sandboxes to enable compliant DeFi experimentation and non-custodial broker-dealer frameworks for programmable securities.
  • Fairmint advocates for the recognition of self-custody rights with embedded compliance protections, allowing investors to hold securities directly while maintaining regulatory oversight.
Antonio Lanotte, INATBA

DeFi Self-Regulation: A Proposal for the Industry
Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • The report proposes a structured DeFi self-regulation framework to ensure security, compliance, and long-term sustainability while preserving innovation.
  • It emphasizes the need for real-time financial reporting, decentralized governance models, and standardized security audits to mitigate risks.
  • The report highlights the importance of voluntary self-regulation to achieve market safety standards without hindering industry growth and competitiveness.
Patrick Kirby, Crypto Council for Innovation

RE: Comments on the SEC Crypto Task Force’s Questions Concerning the Security Status of Crypto Assets
RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The Crypto Council for Innovation (CCI) emphasizes the need for comprehensive legislation for digital assets and blockchain technology to provide clarity, allow for responsible innovation, and protect investors.
  • CCI proposes a regulatory taxonomy for crypto assets based on control, financial returns, and standardization, suggesting that many crypto assets do not implicate securities laws and should not be regulated under them.
  • CCI highlights the importance of recognizing the transformative potential of crypto in improving and empowering the lives of global consumers and encourages collaborative engagement between regulators and the industry.
     
Ernst & Young U.S. LLP

Re: SEC Crypto Task Force request for input
Custody, Security Status, Trading
  • The Financial Accounting Standards Board (FASB) issued guidance requiring entities to measure certain crypto assets at fair value and reflect changes in net income each reporting period.
  • Auditors should establish the relevance and reliability of information from public blockchains when using it as audit evidence.
  • Institutional custodians often issue SOC 1 Type 2 reports to provide information about internal controls relevant to customers' financial statements.
Ripple

Letter on Regulatory Sandboxes
Custody, Regulatory Sandbox, Tokenization, Trading
  • Regulatory sandboxes allow digital asset products to operate in a controlled environment while subject to regulatory oversight.
  • Sandboxes should simulate production-like conditions, enabling firms to test products under real market environments.
  • Insights from sandboxes should feed into rulemaking processes, providing regulatory certainty for firms post-sandbox.
Vanguard Global Holdings LLC

RE: Letter to the Crypto Task Force
Regulatory Sandbox, Security Status, Tokenization
  • The letter urges the SEC to create a clear, adaptable framework to evaluate early-stage blockchain projects along the centralization-decentralization spectrum.
  • It proposes phased registration options, provisional classifications, or defined regulatory timelines to support the natural transition from centralized to decentralized models.
  • The letter emphasizes the importance of regulatory fairness to democratize access to blockchain technology and foster innovation.
Jacklyn DeMar, The Anti-Fraud Coalition

Letter to the Crypto Task Force
Regulatory Sandbox, RFI Responses, Safe Harbor, Security Status, Trading
  • The TAF Coalition recommends that the SEC recognize some digital assets as securities and allocate sufficient resources to enforce crypto-related securities fraud.
  • The SEC's whistleblower program has been effective in identifying and prosecuting crypto fraud, resulting in significant monetary penalties and returns to harmed investors.
  • The SEC is uniquely positioned to combat securities fraud in the crypto industry due to its budget, expertise, and enforcement capabilities.
Ripple

Letter to the Crypto Task Force
Safe Harbor, Security Status, Trading
  • Judge Torres ruled that XRP itself is not a security, even though Ripple had previously sold some units of XRP as part of investment contracts.
  • The SEC's guidance should adhere to existing law to reduce market confusion and avoid reliance on vague concepts like "fully functional" or "sufficiently decentralized."
  • A well-designed safe harbor could provide meaningful protection to good-faith actors navigating genuine legal uncertainty.
Deon Ho, My Fusion International Pte. Ltd

Written Input on Tokenization and Investor Transparency from FusionPay
Security Status, Tokenization, Trading
  • FusionPay provides transparent, verifiable sales reports through on-chain transaction recording.
  • Decentralized crowdfunding with built-in audit trails allows businesses to tokenize and sell future sales to investors.
  • Smart contract-based revenue distribution minimizes fraud and offers investor protections through automation.
Lilya Tessler, Sidley Austin LLP on behalf of Ava Labs, Inc. and Owl Explains

Supplemental Submission Proposing a Nature of the Activity Test to Determine Whether Infrastructure Providers Need to Register as Securities Intermediaries
Custody, RFI Responses, Security Status, Tokenization, Trading
  • The submission proposes a nature of the activity test to determine whether infrastructure providers need to register as securities intermediaries.
  • The test aligns with existing statutory definitions, the Howey framework, and decades of SEC Staff no-action guidance for analogous activities.
  • The submission argues that infrastructure providers should not be misclassified merely because their activities take place on the blockchain or involve crypto assets.