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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.
The Hook Manager Framework (HMF) enables adaptable, on-chain enforcement of compliance policies in DeFi protocols, ensuring regulatory alignment and systemic risk reduction.
Compliance logic is separated from the core protocol, allowing upgradability and flexible, jurisdiction-specific enforcement without disrupting core protocol code.
The framework supports on-chain auditability and transparency, creating real-time, immutable audit trails accessible to regulators and third-party monitors.
The Hook Manager framework enables the implementation of complex business rules through modular, customizable, and upgradeable policy-specific hook contracts.
The proposed decentralized governance model, potentially utilizing the UNI token, oversees the registration and management of policy hooks, ensuring community alignment.
The architecture enhances security by isolating concerns and facilitates features critical for institutional adoption and Real-World Asset (RWA) integration.
Non-custodial trading interfaces (NTIs) should not be considered "brokers" or "exchanges" under federal securities laws as they do not control or custody user funds, solicit transactions, or provide personalized investment recommendations.
NTIs act solely as technological tools that enable users to draft and optimize transactions without intermediating trades or exercising control over the underlying protocol.
The SEC is requested to issue guidance confirming that NTIs are not required to register as brokers or exchanges, ensuring clarity and fostering innovation in non-custodial platforms.
Figure Markets Holdings, Inc. and Figure Certificate Company
The use of YLDS trading pairs as a settlement mechanism for non-security crypto transactions does not require the registration of the Crypto Platform as a broker, securities exchange, or alternative trading system (ATS).
YLDS are registered under the U.S. Securities Act of 1933 and the Investment Company Act of 1940, providing holders with protections and disclosures under federal securities laws.
The Crypto Platform facilitates peer-to-peer transactions in non-security crypto assets, and the use of YLDS as a settlement mechanism is optional and does not constitute "effecting" transactions in securities.
Figure Markets Holdings, Inc. and Figure Certificate Company
FCC is not required to perform AML/KYC on counterparties to peer-to-peer transactions involving YLDS, as FCC is not a "financial institution" under the Bank Secrecy Act (BSA) and FinCEN regulations.
Even if FCC were subject to BSA/AML requirements, peer-to-peer transaction counterparties are not considered "customers" of FCC under the relevant FinCEN rules applicable to mutual funds.
Requiring FCC to perform AML/KYC on peer-to-peer transaction counterparties would impose significant compliance costs and place FCC at a competitive disadvantage compared to other stablecoin issuers.
The Global Digital Assets & Cryptocurrency Association
Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
The Information Guidelines propose a comprehensive disclosure framework for digital asset tokens, aiming to establish transparency and consistency in information disclosure to enable informed decision-making in the digital asset market.
The guidelines align with existing U.S. laws and regulations, as well as global regulatory regimes like MiCA, to promote consistent global adoption of information disclosure practices.
The guidelines provide flexibility for adaptation to different regulatory regimes and industry standards, supporting innovation, market integrity, and capital formation.
The SEC should recognize modern disclosure platforms under state manual exemption regimes to replace outdated paper-based publishers, facilitating lawful secondary trading of tokenized and exempt securities.
The SEC should permit broker-dealers and ATSs to rely on structured digital disclosures under Rule 15c2-11, enhancing compliance and transparency in secondary markets.
The SEC should extend federal preemption to secondary trading of securities from issuers current in Reg A reporting, particularly when such reporting is conducted via structured platforms like GUARDD.
Blaine Luetkemeyer, American Consumer and Investor Institute
The SEC should provide clear guidance and a streamlined no-action path for blockchain-based clearance and settlement systems to facilitate innovation without compromising regulatory oversight.
The SEC should clarify that when a token represents an already-registered or exempt security, the token itself does not require separate SEC registration, reducing regulatory friction while maintaining oversight over the underlying financial instrument.
The SEC should establish a formal registration pathway for staking services that do not fit neatly within existing securities frameworks, including modified reporting requirements that address staking-specific concerns.
Antonio Lanotte, Global Blockchain Business Council
The EU market in cryptoassets (MiCA) regulation introduces specific rules for stablecoins, requiring issuers to meet capital and governance requirements and comply with AML, custody, and operational rules.
The DLT pilot regime allows for the creation of DLT-based trading venues and settlement systems, providing temporary exemptions from certain EU financial rules to test innovations.
Luxembourg's Blockchain Law IV explicitly recognizes and regulates the use of DLT for issuing, registering, and transferring dematerialized securities, introducing a "control agent" to monitor and verify transactions in real time.
Interop Labs urges the SEC to distinguish between centralized and decentralized interoperability networks and to issue guidance or a safe harbor exempting decentralized, non-custodial systems from intermediary registration requirements.
The document proposes principles for evaluating decentralization, including open-source protocols, public accessibility, permissionless operation, immutability, and distributed governance.
Interop Labs emphasizes that decentralized interoperability networks reduce systemic vulnerabilities and uphold investor protections through protocol-level safeguards.
