Oct. 20, 2026
October 20, 2026 Vanessa A. Countryman Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Re: Regulation Crypto Assets, File No. S7-2026-27, Release Nos. 33-11434 / 34-106150 Dear Secretary Countryman: Insimbi is a transaction service provider building regulated payment infrastructure across fiat, stablecoins and markets. We support the Commission's move to a written framework for covered investment contracts and comment on three points: 1. Payment intermediaries need an explicit line. The proposal relieves issuers but is silent on intermediaries that route, curate or settle transactions in crypto assets that are not themselves securities. We ask the Commission to state that transmitting or settling a payment in a non-security crypto asset, without discretion over the asset or a promise of returns, does not by itself create an investment contract or broker/dealer status for the intermediary. 2. Rule 400's exit test should be usable by markets products. The end-of-essential-managerial-efforts test is the right idea. We ask for worked examples for functional, live systems (including market platforms) so a Form TR certification can be made on operational facts, not on a promise to decentralize later. 3. Counting airdrops, staking and use rewards toward the Rule 200 cap needs a valuation rule. At payment scale, use rewards are small, high-volume and price-volatile. We ask the Commission to specify valuation timing and a de minimis treatment, or the $5M cap becomes unmeasurable for exactly the startup-stage projects Rule 200 is meant for. We do not comment on investor caps or disclosure tiers beyond noting that Tier 2's audited-financial requirement is proportionate at $75M. Respectfully submitted, Avinesh Reddy Chief Executive Officer, Insimbi avizulu@insimbi.net -- insimbiinsimbi.net <http://insimbi.net> Umuntu ngumuntu ngabantu