CTF Written Submission

American Consumer and Investor Institute

May 14, 2025
  • 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.

Last Reviewed or Updated: May 14, 2025