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CTF Written Submission

Re: Crypto Task Force Input: Security Status and Safe Harbor from Registration

March 16, 2025

Cumberland DRW LLC supports a safe harbor provision, provisionally named Rule 195, to address the complexities of applying the Howey test to cryptoassets.
Secondary-market cryptoasset transactions generally do not involve investment contracts, as they do not result in pooling of funds in a common enterprise.
Transactions in the native token of a decentralized network should not be viewed as securities transactions.

Re: Crypto Task Force Input: Security Status and Safe Harbor from Registration (PDF, 280.2 KB)

Last Reviewed or Updated: April 3, 2025

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Re: Crypto Task Force Input: Security Status and Safe Harbor from Registration

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Re: Crypto Task Force Input: Security Status and Safe Harbor from Registration