CTF Written Submission
Comment Letter Re: Public Offerings of Digital Assets (Questions 7–9) Submitted in Response to Commissioner Peirce’s Statement “There Must Be Some Way Out of Here”
June 13, 2025
- The Commission should prioritize disclosure-based solutions over creating new regulatory silos for digital assets, specifically through tailored guidance or interpretive relief under Reg CF and Reg A.
- Tailored disclosures are essential for meaningful investor protection in crypto asset offerings, and should be required across all exemptions and registrations, including protocol-level details, token characteristics, governance, and liquidity.
- Regulation A remains underutilized by token issuers, and practical barriers such as uncertainty around eligible crypto assets, conflicting accounting requirements, and delays in qualification timelines need to be addressed.
Last Reviewed or Updated: June 13, 2025