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
Joe Roets, Dragonchain

Dragonchain Feedback to Commissioner Hester M. Peirce article There Must Be Some Way Out of Here dated Feb. 21, 2025 		Regulatory Sandbox, Safe Harbor, Security Status
  • A proper regulatory taxonomy should distinguish between software licenses and utility tokens versus financial securities and investment vehicles.
  • Blockchain functions such as consensus mechanisms, smart contract execution, and decentralized identity management should not fall under securities regulations.
  • NFTs should not be presumed to be securities, as they are digital collectibles with use cases in gaming, identity, and authentication.
Sarah Brennan, Decentralization Research Center

2025 Safe Harbor Framework Overview 		Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The 2025 Safe Harbor Framework provides prospective and retroactive relief for token projects, including Rule 195 for new distributions and Rule 195T for historical distributions.
  • The framework includes an exit test for Network Maturity, ensuring that once achieved, the Initial Development Group lacks control to alter the fundamental characteristics of the Network and Token.
  • The framework imposes commitments on the Initial Development Group, including acceptance of SEC fraud jurisdiction, continuous public disclosure, and caps on sales and lock-ups.
Brian K. McGrail

Letter to the Crypto Task Force 		Crypto ETPs, Crypto Lending, Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • Switzerland's DLT Act introduced a legal basis for ledger-based securities and a regulatory license category for DLT trading facilities.
  • Singapore's Payment Services Act (PSA) 2019 brings cryptocurrencies under AML and CFT regulations, ensuring consumer protection while promoting innovation.
  • Japan's Payment Services Act (PSA) and Financial Instruments and Exchange Act (FIEA) recognize Bitcoin as a legal payment method and regulate crypto assets as financial instruments.
Shan Parsan

Policy for the Crypto Task Force: Fraud Prevention and Tracing Framework 		Crypto ETPs, Crypto Lending, Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • Mandatory KYC/AML compliance for all cryptocurrency exchanges.
  • Enforcement of the Financial Action Task Force (FATF) Travel Rule.
  • SEC registration requirement for all crypto exchanges operating in the U.S.
Joon Kim, JK Advisory LLC

Re: Cryptocurrency Task Force 		Crypto Lending, Custody, Safe Harbor, Security Status, Trading
  • The SEC should recognize decentralization as a spectrum and provide better guidance on what constitutes a "decentralized and functional" network.
  • Projects under the Grace Period should be allowed to engage in certain permitted activities to incentivize their return to the U.S.
  • Uniform disclosure standards should be established for crypto projects to protect investors.
Alan Konevsky, tZERO Group, Inc.

Re: SEC Crypto 2.0: Formation of New Crypto Task Force 		Crypto Lending, Custody, Safe Harbor, Security Status, Trading
  • The document emphasizes the need for a clear regulatory framework for digital assets to ensure the United States remains a global leader in the digital evolution, particularly in financial markets.
  • It advocates for updates to the Special Purpose Broker-Dealer (SPBD) Statement to allow SPBDs to custody non-security crypto assets and engage in non-custodial activities.
  • The document calls for a clear path for issuers to cure historical securities law violations for digital assets that were not issued in compliance with securities laws.
Digital Asset Holdings, LLC

Letter to the Crypto Task Force 		Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • The submission focuses on the tokenization of traditional securities, emphasizing the need for regulatory clarity to accelerate innovation while ensuring fair, orderly, and efficient capital markets.
  • The document highlights the importance of privacy, control, security, and transaction finality in blockchain-based books and records, advocating for the use of blockchain as permissible electronic books and records.
  • Recommendations include providing no-action relief for market participants conducting core market transactions with tokenized traditional securities, enabling real-time settlement and the use of tokenized securities as collateral.
Zack Dane, Revolve

Public Security Opinion 		RFI Responses, Security Status, Tokenization, Trading
  • The document discusses the need for tailored disclosure requirements for Real World Asset (RWA) backed digital assets versus speculative or enterprise-driven assets.
  • It emphasizes the importance of making Regulation A/A+ exemptions more widely available and less difficult to navigate.
  • The document suggests using single asset entities (LLC or similar) for titled RWAs to create a verifiable real-world entity to help with customer protection.
J.W. Verret, GMU Scalia Law School

Letter to the Crypto Task Force 		Regulatory Sandbox, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The document proposes a Memorandum of Understanding (MOU) between the SEC and CFTC to facilitate developer choice among various exemptions and pathways, promoting financial privacy, immutability, and decentralization.
  • It suggests the issuance of nine exemptive releases or rule proposals within one year, targeting specific patterns of public blockchain development and disbursal, rather than classifying tokens themselves.
  • The document advocates for the use of regulatory agreements or "contracts" as a flexible sandbox mechanism, providing tailored compliance obligations and safe-harbor conditions for individual innovators.
William R Stanek, WilliamRStanek.com

A Prudent Digital Assets Framework: Balancing Innovation, Consumer Protection, and Monetary Sovereignty 		Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • The document proposes a structured policy environment for digital assets in the United States to foster long-term economic growth, financial stability, and global competitiveness.
  • It emphasizes the need for regulatory clarity and standardized disclosures to ensure trust and market integrity.
  • The framework includes foundational principles such as transparency, monetary sovereignty, consumer and investor protections, responsible innovation, and global coordination.