CTF Written Submission

RE: Asset-Based Classification; Decentralization; Regulatory Status of Technology Functions; Treatment of Infrastructure Providers

April 23, 2025
  • The document proposes a high-level framework for token classification based on the nature of the asset, advocating for an asset-based approach to evaluating tokens under federal securities laws.
  • It explains why technology functions inherent to the operation of blockchains do not constitute or result in securities and why infrastructure providers on blockchain networks are not securities intermediaries.
  • The submission discusses the importance of regulatory clarity and consistency across different technologies and regulatory agencies, emphasizing that the nature of the asset should determine its legal and regulatory treatment.
     

Last Reviewed or Updated: April 23, 2025