CTF Written Submission

Re: Safe Harbor from Registration

May 21, 2025
  • The letter urges the Commission to align its safe harbor efforts with similar provisions in market structure legislation to avoid regulatory confusion.
  • It requests interpretive guidance clarifying that common communications about network milestones do not create a reasonable expectation of profit and do not constitute investment contracts.
  • The letter emphasizes that crypto assets sold under the safe harbor should not be considered securities themselves, and secondary trading of these assets should not be treated as investment contract transactions.

Last Reviewed or Updated: May 22, 2025