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
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.
Nilmini Rubin, Hedera

Subject: Comments on the SEC Crypto Task Force’s Questions Concerning Safe Harbor from Registration 		RFI Responses, Safe Harbor, Security Status, Tokenization
  • The Hedera Council supports the establishment of a token safe harbor to provide regulatory certainty and transparency for new and existing companies in the digital asset industry.
  • The Council suggests modifying the definition of Network Maturity to include decentralized governance coordinated through a legal entity, termed as a "Decentralized Wrapper," to protect participants from general liability.
  • The Council advocates for retroactive availability of the safe harbor contingent upon full compliance with disclosure requirements to enhance market transparency and investor protection.
ReFiESG Labs LLC

R-TaaS — Regenerative Tokenization as a Service One-Pager Overview 		Tokenization, Trading

  • R-TaaS (Regenerative Tokenization as a Service) allows tokenization of real-world ESG assets onto the ReFiESG Blockchain using ESG-backed Digital Twins.
  • The system uses pre-minted, asset-linked tokens (UBID, PAT, NZN) to anchor real-world value in a programmable, regenerative economic system.
  • R-TaaS provides budgetary liquidity without debt, enables true ESG monetization, and creates proof-of-impact financial systems.
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.
     
Kecheng Lai, Knowpia Inc.

Recommendation Letter - From End User Distribution to Social Mining: Evolving Frameworks for Token Dissemination and Community Engagement in the Digital Asset Economy 		Safe Harbor, Security Status, Tokenization, Trading
  • The "End User Distribution" concept is designed to distribute digital commodities without constituting an offer or sale of a security or commodity.
  • "Social Mining" allows users to earn tokens through non-financial contributions, directly linking token issuance to platform value creation.
  • The STO+ framework proposes a dual-nature token model, where tokens transition from utility to security status based on specific conditions.
Rebecca Kacaba, DealMaker

Re: Securities and Exchange Commission’s (“SEC” or “Commission”) Crypto Task Force (the “Task Force”) Invitation For Public Commentary Regarding Public Offerings Of Crypto Assets, Safe Harbor From Registration and Tokenization 		Public Offerings, RFI Responses, Safe Harbor, Tokenization, Trading
  • DealMaker emphasizes that Regulation A provides a strong foundation for crypto asset offerings and suggests removing the $75 million cap to better accommodate high-growth, capital-intensive sectors.
  • The letter advocates for adaptable disclosure requirements tailored to crypto assets, focusing on risk and ongoing managerial efforts to enhance investor protection.
  • DealMaker supports clear guidance on secondary market trading for tokenized assets, including federal preemption of state law compliance for secondary trading through registered systems.
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.