Subject: File No. S7-04-23
From: Mike C.

The Commission Lacks Sufficient Legal Basis to Prohibit the Trading of Crypto Non-Securities on Exchanges and alternative swapping/trading platforms. The Proposed Rule would require crypto trading platforms that trade securities to register with the Commission as exchanges. While I understand the Commission's desire for proper oversight of securities trading, I respectfully believe that the Commission lacks a firm legal basis to then prohibit these newly-registered exchanges and ATSs from also trading non-security crypto assets. The proposal asserts, without citing statutory authority, that upon registration exchanges and ATSs must cease trading all non-securities such as Bitcoin, Ether, and stablecoins. However, our research found no clear language in the Exchange Act or related laws that grants the Commission authority to impose such a prohibition. Stablecoins in particular are vital to the efficient functioning of crypto platforms. Without them, trades would require slow, costly cash settlement. Stablecoins enable frictionless trading and are extensively used across major crypto platforms. Bitcoin, Ether, and stablecoins combined account for a substantial portion of the estimated $900 billion global crypto market. Thus, prohibiting their trade on exchanges would significantly disrupt the crypto market and harm American consumers and investors. Given the profound economic impacts, I respectfully request that the Commission point to unambiguous statutory authority before imposing regulations that would ban the trading of non-security crypto assets on exchanges and platforms. While crypto securities merit appropriate oversight, the Commission should avoid overreach into non-securities trading absent explicit Congressional authorization.