CTF Written Submission

Ripple

Jan. 9, 2026
  • SEC authority should hinge on enforceable promises and legal claims, not mere expectations of profit or passive economic interest. Without privity or contractual rights, speculation does not create securities status.
  • Securities regulation should apply to primary distributions where privity exists (e.g., ICOs), not to perpetual secondary-market trades. Treating every issuer sale as a capital raise creates legal fictions and operational paralysis.
  • Regulatory focus should target cases where an issuer or affiliated group retains unilateral control over network rules or token functionality, as this may constitute an ongoing obligation. Control must be objectively defined; mere influence or inventory holdings do not qualify.

Last Reviewed or Updated: Jan. 9, 2026