Subject: FW: Draft FY 2026 – FY 2030 SEC Strategic Plan, File No. DSP-3

-----Original Message-----

Re: Draft FY 2026 – FY 2030 SEC Strategic Plan, File No. DSP-3

Dear Chair:

Commenting in connection with the filing of Better Markets' comment letter on the Securities and Exchange Commission's (SEC's) Draft Strategic Plan:  The problem with the SEC's Draft Strategic Plan is its preoccupation with what it calls innovation, which appears to be a euphemism for rewriting its rules to benefit the crypto industry.
Innovation is important, but not at the expense of investor protection.
The innovation the SEC claims it is advancing is simply the legitimation of crypto assets, and the SEC exists not to promote the interests of the industry it regulates but to protect investors.

The SEC's fixation with innovation is especially odd because ‘innovation' is barely mentioned in the statutes that the SEC enforces.
The word ‘innovation' is entirely absent from the Securities Act of 1933, the Investment Company Act of 1940, and the Investment Advisers Act of 1940. And its only mention in the Securities Exchange Act of 1934 is with respect to joint rules with the CFTC to permit the offer and sale of securities futures products. That is one mention of ‘innovation'
in almost 600 pages of legislative text.

Conversely, the Exchange Act references the ‘protection of investors'
over 200 times. The need to consider the ‘protection of investors'
appears another 125 times across the three other statutes. Yet the SEC's Draft Strategic Plan pays investor protection only lip service, as it contains fewer references to investor protection than it does to ‘innovation' and crypto.

The Draft Strategic Plan's approach to enforcement further betrays the SEC's longstanding commitment to investor protection. One of the plan's goals is to refocus enforcement on frauds and manipulations and only those involving ‘clear violations of established law.' But, as our comment letter shows, Congress intended the SEC to prosecute all frauds—both conventional schemes and novel or atypical deceptions. And the SEC has long enforced all the federal securities laws' provisions, including violations of the registration requirements, which it has always considered among the most serious of violations. The strategic plan's suggestion that only cases involving traditional fraud deserve attention may serve the interests of the crypto industry, but it is inconsistent with the SEC's historic mission.
Full letter:
https://bettermarkets.org/wp-content/uploads/2026/07/Better-Markets-Comment-Letter-SEC-Strategic-Plan.pdf

Yours sincerely.
Robert E. Rutkowski