CTF Written Submission

Re: Response to the Crypto Task Force’s Request for Comment: Regarding Decentralized Autonomous Organizations

May 27, 2025
  • DEF and UF support Commissioner Peirce's proposal for a non-exclusive safe harbor (Rule 195) that would provide a time-limited exemption from registration requirements under the Securities Act of 1933 for offers and sales of cryptocurrency assets during the development of a blockchain project.
  • DEF and UF argue that a DAO with dispersed control over governance should not have its network tokens or transactions considered as securities under the Howey test.
  • DEF and UF emphasize that blockchain records eliminate informational asymmetries, making traditional disclosure requirements unnecessary for sufficiently decentralized networks.

Last Reviewed or Updated: May 27, 2025