CTF Written Submission

James Walker, Lowell Ness, Arthur Greenspan, Valeska Pederson Hintz, Zeeve Rose, Perkins Coie LLP

April 23, 2025
  • The document proposes a framework for distinguishing securities transactions from non-securities transactions, emphasizing the importance of analyzing the facts and circumstances of each transaction separately rather than in the aggregate.
  • It suggests that crypto assets should be treated as commodities unless they provide holders with rights to a share of profits or a return on investment, in which case they should be considered securities.
  • The document recommends that certain crypto assets, such as payment stablecoins and meme coins, should not be treated as securities if they are offered and sold in a manner consistent with specific guidelines.

Last Reviewed or Updated: April 23, 2025