Crypto Task Force Written Input

Please find written input submissions to the Crypto Task Force below. The written input is posted without modification. We hope sharing the submissions will help encourage productive dialogue and continued engagement. Please note that the “Key Points” and “Topics” are AI generated. AI can make mistakes, and the Key Points and Topics are not a replacement for you reading the submissions. The Crypto Task Force has not reviewed these AI-generated summaries for accuracy or completeness. If you believe a Key Point or Topic is inaccurate, please email the Crypto Task Force at crypto@sec.gov. The written input provided to the SEC and posted on this page does not necessarily reflect the views of the Crypto Task Force or others in the U.S. Securities and Exchange Commission.

Date Written Input Topic(s) Key Points
Rebecca Kacaba, DealMaker

Re: Securities and Exchange Commission’s (“SEC” or “Commission”) Crypto Task Force (the “Task Force”) Invitation For Public Commentary Regarding Public Offerings Of Crypto Assets, Safe Harbor From Registration and Tokenization 		Public Offerings, RFI Responses, Safe Harbor, Tokenization, Trading
  • DealMaker emphasizes that Regulation A provides a strong foundation for crypto asset offerings and suggests removing the $75 million cap to better accommodate high-growth, capital-intensive sectors.
  • The letter advocates for adaptable disclosure requirements tailored to crypto assets, focusing on risk and ongoing managerial efforts to enhance investor protection.
  • DealMaker supports clear guidance on secondary market trading for tokenized assets, including federal preemption of state law compliance for secondary trading through registered systems.
Joris Delanoue, Fairmint, Inc.

Comment on SEC Crypto Task Force and Framework for Onchain Equity Securities Markets 		Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • Fairmint, Inc. proposes a framework for onchain equity securities markets that emphasizes protocol-level standardization, real-time regulatory observability, and modernized investor protections.
  • The framework includes recommendations for regulatory sandboxes to enable compliant DeFi experimentation and non-custodial broker-dealer frameworks for programmable securities.
  • Fairmint advocates for the recognition of self-custody rights with embedded compliance protections, allowing investors to hold securities directly while maintaining regulatory oversight.
Antonio Lanotte, INATBA

DeFi Self-Regulation: A Proposal for the Industry 		Custody, Regulatory Sandbox, Security Status, Tokenization, Trading
  • The report proposes a structured DeFi self-regulation framework to ensure security, compliance, and long-term sustainability while preserving innovation.
  • It emphasizes the need for real-time financial reporting, decentralized governance models, and standardized security audits to mitigate risks.
  • The report highlights the importance of voluntary self-regulation to achieve market safety standards without hindering industry growth and competitiveness.
Patrick Kirby, Crypto Council for Innovation

RE: Comments on the SEC Crypto Task Force’s Questions Concerning the Security Status of Crypto Assets 		RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The Crypto Council for Innovation (CCI) emphasizes the need for comprehensive legislation for digital assets and blockchain technology to provide clarity, allow for responsible innovation, and protect investors.
  • CCI proposes a regulatory taxonomy for crypto assets based on control, financial returns, and standardization, suggesting that many crypto assets do not implicate securities laws and should not be regulated under them.
  • CCI highlights the importance of recognizing the transformative potential of crypto in improving and empowering the lives of global consumers and encourages collaborative engagement between regulators and the industry.
     
Ripple

Letter on Regulatory Sandboxes 		Custody, Regulatory Sandbox, Tokenization, Trading
  • Regulatory sandboxes allow digital asset products to operate in a controlled environment while subject to regulatory oversight.
  • Sandboxes should simulate production-like conditions, enabling firms to test products under real market environments.
  • Insights from sandboxes should feed into rulemaking processes, providing regulatory certainty for firms post-sandbox.
Vanguard Global Holdings LLC

RE: Letter to the Crypto Task Force 		Regulatory Sandbox, Security Status, Tokenization
  • The letter urges the SEC to create a clear, adaptable framework to evaluate early-stage blockchain projects along the centralization-decentralization spectrum.
  • It proposes phased registration options, provisional classifications, or defined regulatory timelines to support the natural transition from centralized to decentralized models.
  • The letter emphasizes the importance of regulatory fairness to democratize access to blockchain technology and foster innovation.
Deon Ho, My Fusion International Pte. Ltd

Written Input on Tokenization and Investor Transparency from FusionPay 		Security Status, Tokenization, Trading
  • FusionPay provides transparent, verifiable sales reports through on-chain transaction recording.
  • Decentralized crowdfunding with built-in audit trails allows businesses to tokenize and sell future sales to investors.
  • Smart contract-based revenue distribution minimizes fraud and offers investor protections through automation.
Lilya Tessler, Sidley Austin LLP on behalf of Ava Labs, Inc. and Owl Explains

Supplemental Submission Proposing a Nature of the Activity Test to Determine Whether Infrastructure Providers Need to Register as Securities Intermediaries 		Custody, RFI Responses, Security Status, Tokenization, Trading
  • The submission proposes a nature of the activity test to determine whether infrastructure providers need to register as securities intermediaries.
  • The test aligns with existing statutory definitions, the Howey framework, and decades of SEC Staff no-action guidance for analogous activities.
  • The submission argues that infrastructure providers should not be misclassified merely because their activities take place on the blockchain or involve crypto assets.
Charles W. Mooney, Jr., University of Pennsylvania Carey Law School

Potential Exemptive Order: Tokenization of Traditional Securities 		Custody, Regulatory Sandbox, Safe Harbor, Tokenization, Trading
  • The potential SEC exemptive order for tokenized securities could unintentionally entrench the monopoly of the current intermediated securities holding infrastructure.
  • The current intermediated holding system imposes substantial costs on issuers and investors, which could be alleviated by a direct-holding model.
  • An independent study is recommended to assess the current securities holding infrastructure and explore potential reforms, including the implementation of a direct-holding model.
DeFi Education Fund and Uniswap Foundation

Re: Response to the Crypto Task Force’s Request for Comment: Regarding Decentralized Autonomous Organizations 		RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • DEF and UF support Commissioner Peirce's proposal for a non-exclusive safe harbor (Rule 195) that would provide a time-limited exemption from registration requirements under the Securities Act of 1933 for offers and sales of cryptocurrency assets during the development of a blockchain project.
  • DEF and UF argue that a DAO with dispersed control over governance should not have its network tokens or transactions considered as securities under the Howey test.
  • DEF and UF emphasize that blockchain records eliminate informational asymmetries, making traditional disclosure requirements unnecessary for sufficiently decentralized networks.