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
Kecheng Lai, Knowpia Inc.

Recommendation Letter 		Security Status, Tokenization
  • Recommendation for exemption from locking period for Social-Mined Tokens (ST+) under STO+ classification.
  • Definition and distinction between ST (Security Token) and ST+ (Social Mining Token).
  • Proposal for regulatory distinction where ST+ tokens retain utility-only classification during non-tradable, in-platform phase.
Andreessen Horowitz, a16z

Re: Recommendations Regarding a Safe Harbor and Crowdfunding Regime for Collectible Tokens (NFTs) 		RFI Responses, Safe Harbor, Security Status
  • The document recommends the creation of a safe harbor to exclude ordinary transactions of collectible tokens from federal securities laws.
  • It proposes new crowdfunding regulations for transactions of collectible tokens that may engender risks addressed by federal securities laws.
  • The document emphasizes that collectible tokens generally do not have the inherent characteristics of securities and should not be subject to federal securities laws.
Figure Markets

Submission to SEC Crypto Task Force 		Crypto Lending, Custody, Public Offerings, Regulatory Sandbox, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The SEC should clarify the security status of crypto assets like stablecoins, wrapped tokens, and NFTs to foster innovation and protect investors.
  • Tailored disclosure requirements for specific non-security crypto asset categories should be established to ensure transparency and investor protection.
  • A safe harbor provision, such as Rule 195, should be considered to encourage blockchain development within regulatory parameters.
Alternative Investment Management Association (AIMA)

Re: AIMA written input to the SEC’s Crypto Task Force 		Crypto ETPs, Crypto Lending, Custody, Public Offerings, Regulatory Sandbox, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • AIMA recommends the SEC adopt a clear, principles-based regulatory approach toward crypto assets, recognizing their diverse nature and use cases.
  • AIMA urges the SEC to provide clear custody guidelines for RIAs and other institutional investors, emphasizing the need to withdraw the proposed Safeguarding Rule.
  • AIMA suggests that the SEC consider adopting a version of Rule 195 to provide clarity on when a token sale ceases to be an investment contract and when a network achieves sufficient decentralization.
Asia Web3 Alliance Japan

Proposal for U.S.–Japan Collaboration on Tokenized Economy and Web3 Innovation 		Regulatory Sandbox, Safe Harbor, Tokenization, Trading
  • The proposal emphasizes the need for regulatory clarity and interoperability of frameworks to support the development of compliant and inclusive tokenized markets.
  • It suggests the creation of a U.S.–Japan Tokenization and Web3 Regulatory Collaboration Program to harmonize token classification frameworks and promote regulatory interoperability.
  • The proposal advocates for the introduction of a safe harbor mechanism in Japan, similar to the U.S. model, to allow startups to test projects in a controlled sandbox environment with a path to full compliance.
Lido Labs Foundation

Re: Response to RFI of Crypto Task Force 		RFI Responses, Safe Harbor, Security Status
  • Governance tokens provide essential utility for decentralized blockchain networks and should not be classified as securities.
  • Liquid staking tokens (LSTs) are akin to warehouse receipts for commodities and do not implicate federal securities laws.
  • The SEC should provide legal clarity on the status of LSTs to ensure market certainty.
Bruce Tupper, CoinRegTech

RE: SEC Crypto 2.0 Formation of New Crypto Task Force 		Custody, RFI Responses, Security Status, Tokenization, Trading
  • The SEC should address investor protection and market structure issues involving digital asset securities facilitated by off-chain transactions on trading platforms.
  • The SEC and CFTC should jointly authorize and regulate a digital asset repository of transactions (DART) to record both on-chain and off-chain transactions and associated customer ownership.
  • The SEC should revise the Exchange Act rules to require timely reporting of all transactions deemed digital asset securities to enhance market oversight.
Kecheng Lai, Knowpia Inc.

Recommendation Letter 		Security Status, Tokenization, Trading
  • STO+ tokens are designed to mirror preferred stock characteristics, entitling holders to dividend distributions without direct ownership or operational management rights.
  • All token transactions are recorded transparently on decentralized blockchain smart contracts, ensuring a fully auditable, secure, and traceable transaction history.
  • Trading of STO+ tokens will occur exclusively on U.S.-based, SEC-compliant token exchanges to ensure ongoing regulatory adherence and oversight.
Ronald Hale

Letter to the Crypto Task Force 		Custody, Public Offerings, Regulatory Sandbox, Security Status, Tokenization, Trading
  • The proposed framework introduces the "Satoshi test" to classify crypto assets, focusing on investment of value, centralized control, expectation of returns, efforts of others, decentralization level, and transparency.
  • Regulatory components include guidelines for development and governance, classification of coins and tokens, oversight of economic activities like staking and mining, funding mechanisms, and standards for trading platforms and wallets.
  • Recommended investor protection measures include education campaigns, dispute resolution mechanisms, compensation funds or insurance for fraud victims, and international collaboration to address cross-border crypto issues.
     
Cindy Hart, EROS Risk Consulting

Letter to the Crypto Task Force 		Regulatory Sandbox, Security Status, Tokenization, Trading
  • Federal securities law and other federal and state regulations would apply based on the actual trading activity performed, requiring an interagency framework to factor in emerging risks.
  • The framework should consider identifying the full spectrum of risks, performing regulatory mapping, and providing interpretive guidance on activities that qualify for exemption.
  • Interagency participation is crucial in comprehensively identifying risks based on each agency's mission, including investment activity, registered investment advisors, financial crimes, accounting standards, safety and soundness, tax implications, and consumer regulations.