CTF Written Submission

Re: There Must Be Some Way Out of Here

April 3, 2025
  • Kiln argues that Proof-of-Stake (PoS) blockchain activities, such as staking, do not involve the offer and sale of securities under the Securities Act and Exchange Act.
  • Kiln emphasizes that staking rewards are protocol-defined and not derived from the managerial efforts of others, thus falling outside the scope of the Howey test for investment contracts.
  •  Kiln supports regulatory clarity that distinguishes between core blockchain infrastructure activities and traditional securities transactions.

Last Reviewed or Updated: April 3, 2025