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
PraSaga Foundation

SagaStandards: Transforming Finance with a Global Standards Registry
Custody, Public Offerings, Regulatory Sandbox, Security Status, Tokenization, Trading
  • Implementation of open standards for tokenized finance to enhance transparency and reduce fraud.
  • Potential savings of $155B-$316B annually through reduced transaction fees, fraud, and operational costs.
  • Collaboration with international standards organizations (ISO, FIX, XBRL, ISDA) to align financial reporting and trading standards.
     
Kevin Jacobs, Phantom Technologies, Inc.

Response to the Crypto Task Force’s Request for Comment: Regarding Project Open
Custody, Security Status, Tokenization, Trading
  • Phantom Technologies, Inc. argues that its self-custody crypto wallet does not perform broker activities and thus should not require SEC registration under Section 15(a) of the Exchange Act.
  • The company advocates for the SEC to use its exemptive and/or no-action authority to create a regulatory framework for Token Shares tailored to decentralized finance (DeFi).
  • Phantom supports the Project Open initiative, which proposes a framework for the issuance and trading of Token Shares in compliance with existing securities laws.
Superstate Inc.

Response to Crypto Task Force: Digital Transfer Agent -- Moving Securities and Markets from Analog to Digital
Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The letter emphasizes that existing securities regulations are fully consistent with the tokenization and integration of blockchain technology within the securities markets.
  • It highlights the role of digital transfer agents in enabling the integration of registered and exempt securities by recording and tracking ownership within decentralized finance (DeFi).
  • The letter asserts that tokenized securities, supported by digital transfer agents, can improve market transparency, efficiency, and corporate governance while ensuring re
Orca Creative

Response to thCrypto Task Force’s Request for Comment: Regarding Project Open
Custody, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • Orca Protocol is not classified as an exchange, broker, dealer, or clearing agency under the Exchange Act.
  • Orca Protocol operates autonomously and does not involve third-party custody, discretionary control, or intermediation.
  • Orca Protocol supports a principle-based regulatory framework that emphasizes transparency, autonomy, and user control.
Solana Policy Institute (by Lowenstein Sander LLP)

Public blockchain infrastructure for on-chain equities issuance and trading
Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • Covered Blockchain Networks and Validators do not fall within the definitions of "clearing agencies," "exchanges," or "brokers" under the Exchange Act.
  • Validators on a Covered Blockchain Network do not act as intermediaries in the payment or delivery of securities and do not perform the intermediary functions characteristic of a CCP or clearing agency.
  • The on-chain infrastructure ensures that securities transactions are direct, transparent, and settled on a gross, peer-to-peer basis, with no centralized intermediation, custody, or netting.
Solana Policy Institute

Response to the Crypto Task Force’s Request for Comment: Regarding Project Open
Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The Solana Policy Institute argues that validators on the Solana network do not trigger registration requirements under securities laws.
  • Phantom Technologies Inc. asserts that non-custodial wallet software does not require broker-dealer registration.
  • Orca Creative claims that its AMM protocols do not function as securities intermediaries.
Securities Industry and Financial Markets Association (SIFMA)

RE: Request for Comment on There Must Be Some Way Out of Here
Custody, Public Offerings, RFI Responses, Security Status, Tokenization, Trading
  • Issuer disclosures under the 1933 and 1934 Acts should be extended to new categories of securities transactions, including digital assets.
  • The separation of functions and limits on vertical integration must be maintained to ensure investor protection and fair and orderly markets.
  • Direct retail issuance of SEC-regulated products should not be permitted.
Ethena Labs, S.A.

Re: Response To Crypto Task Force Request For Comment
Custody, Regulatory Sandbox, RFI Responses, Security Status, Tokenization
  • Ethena Labs argues that synthetic dollars, like other stable value tokens, should not be regulated as securities, as they are designed for transactional and consumptive purposes rather than speculative or investment-oriented uses.
  • The submission highlights that the SEC's Statement on Stablecoins does not apply to synthetic dollars like USDe, which are backed by cryptocurrencies and delta-neutral hedging strategies rather than fiat currencies.
  • Ethena Labs recommends that the SEC provide clear guidance recognizing that stable value tokens, including synthetic dollars, are not securities and should be regulated under a consumer protection regime.
Cindy Hart, EROS LLC

Written Input over Crypto Activity Roundtable
Custody, Security Status, Trading
  • The letter recommends the SEC issue interpretative guidance related to corporate governance practices, particularly for investor and consumer protection.
  • It highlights the need for guidance that aligns governance practices with the nature and risk profile of activities conducted by organizations.
  • The letter suggests that such guidance could reference leading industry standards and frameworks to enhance accountability and provide a legal basis for recourse in cases of governance failures.
FusionPay

Re: FusionPay Tokenomic Whitepaper
Custody, Security Status, Tokenization, Trading
  • FusionPay's token system is designed to avoid securities classification under frameworks like MAS (Singapore).
  • The protocol is non-custodial, meaning no wallet keys or assets are ever held by the protocol.
  • FTE token holders have governance rights, including voting on protocol upgrades, treasury allocations, and incentive programs.