Subject: S7-25-20
From: Ashlynn Antrobus
Affiliation:

Apr. 14, 2023

I don't really understand why the SEC thinks that they can define they're mandate. That seems to me like the kind of thing that should be done by Congress, since they were the ones who defined it in the first place in 1934. The commission was created as a response to the Great Depression. When the price of cryptocurrencies fell last year, it did not spark an economic downturn. That should be enough reason why it should be considered outside of the scope of SEC authority. 
But beyond that, why are bitcoin, Solana, and Ethereum securities in the eyes of the SEC, but not yen, Lira, and euros? They are all currencies that fluctuate in value. Just because the first group aren't controlled by a government while the second group are, shouldn't matter. 
The SEC also claims that we're going to stations through which a person buys cryptocurrency are securities exchanges. These companies help people buy, sell store, and convert currency. We have a word for that already. That word is bank. Groups like Coinbase and Binance are banks. 
I have read that you're justification for considering them securities exchanges are the staking rewards. I don't follow this argument at all. What do you think that staking rewards are? In my view, they fulfill the same function as interest on savings. Banks require deposits order to lend money, which is how they make their money. The way to encourage those deposits is to share a percentage of their profits. Similarly, many credit cards offer cashback rewards to attract customers and encourage the use of the cards. Because, while we think of interest on carried balance as how credit card companies make money, The thing that makes them the most money are swipe fees. Every time you Use a credit card, the issuing bank charges a fee to the merchant. And some cards share a percentage of that fee to encourage users to generate more of those fees. 
Cryptocurrencies take time, effort, and money to run. Trust like government owned currencies. The difference is that the cost isn't born by taxpayers. Instead, it is paid by the users who are spending that money, through gas fees. Pretty much the same as a swipe fee, only the amount varies based on demand. A bank is the middle man for savings and lending, or swipe fees and cash back. But anyone can become a validator, the middleman in cryptocurrency transfers. Validators get the gas feed as payment for doing the work. Staking rewards are just these specialized banks doing bank like things, of encouraging users to use their banking services in a way that makes them more money. 


For these reasons, I do not believe that the SEC's proposed policy regarding cryptocurrency and cryptocurrency exchanges serves the public good or is within the authority of the SEC 


Ashlynn Antrobus 
(she/they)