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
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.
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
Van Eck Associates Corporation

Letter to the Crypto Task Force 		Crypto ETPs, Custody, Public Offerings, Security Status
  • The letter addresses the regulatory framework for digital assets and emphasizes the need for clear guidelines to ensure compliance.
  • It highlights the importance of investor protection and the role of regulatory bodies in overseeing digital asset transactions.
  • The letter calls for collaboration between industry stakeholders and regulators to develop a robust and adaptable regulatory environment.
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.
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.