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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.
Interop Labs urges the SEC to distinguish between centralized and decentralized interoperability networks and to issue guidance or a safe harbor exempting decentralized, non-custodial systems from intermediary registration requirements.
The document proposes principles for evaluating decentralization, including open-source protocols, public accessibility, permissionless operation, immutability, and distributed governance.
Interop Labs emphasizes that decentralized interoperability networks reduce systemic vulnerabilities and uphold investor protections through protocol-level safeguards.
Matthew Comstock, Willkie Farr & Gallagher LLP, on behalf of The Digital Chamber
The Digital Chamber (TDC) advocates for a technology-neutral, principles-based approach to broker-dealer custody of crypto assets, emphasizing exclusive control over private keys through secure key management practices.
TDC requests the SEC to amend Rule 15c3-3 to allow broker-dealers to establish possession or control of crypto asset securities using various approaches and technologies, including third-party vendors.
TDC urges the SEC to confirm that broker-dealers can use Section 3(a)(6) Banks as control locations for crypto asset securities and to amend Rule 15c3-3 to explicitly include crypto asset securities.
Anderson P.C. supports an activity-based regulatory framework over asset-based classification, advocating for the bifurcation of "security" definitions under the '33 and '34 Acts to provide clearer compliance pathways for digital assets.
The letter urges the SEC to issue interpretive guidance affirming decentralized oracle networks (DONs) as legitimate and reliable price benchmarks under fair value accounting standards and SEC rules.
Anderson P.C. recommends a tailored disclosure framework for network tokens, emphasizing transparency about tokenomics, governance, security audits, contributor incentives, and decentralization milestones.
Securities Industry and Financial Markets Association (SIFMA)
SIFMA recommends that the SEC adopt clear, consistent, and consensus-driven taxonomies and classification approaches for digital assets to provide greater clarity to market participants.
SIFMA urges the SEC to apply traditional regulatory principles around custody to digital assets, including the separation of financial activities, segregation of client assets, and ensuring proper control of assets.
SIFMA supports the SEC's efforts to provide guidance scoping-out non-securities digital assets and digital asset activities, emphasizing a technology-neutral approach.
The utility and real-world use case of a digital asset should be a primary determining factor in whether the asset is deemed a "security" under U.S. federal securities laws.
Digital assets with utility and real-world use cases are more appropriately regulated by the Commodity Futures Trading Commission (CFTC) rather than the Securities and Exchange Commission (SEC).
The regulatory approach should avoid excessively complicated, multi-part legal tests and instead focus on practical, usable, and reasonable legal standards.
Ravi Srivastava, Chief Technology Officer, Akemona, Inc.
Tokenized securities should be treated as traditional securities, with permissioned assets transferable across whitelisted wallets using smart contracts to enforce lawful transfers and track ownership changes.
Permissionless public blockchains should be allowed for the issuance, trading, and tracking of tokenized securities, with relevant market participants responsible for evaluating the security and soundness of the infrastructure.
Broker-dealers should be allowed to engage in a full array of activities, including custody, trading, and settlement of tokenized securities, without the need for segregation or special licensure.
The document emphasizes the need for the SEC to differentiate between Bearer Digital Asset Securities (BDAS) and Tokenized Securities in its regulations, as the risks associated with BDAS do not apply to Tokenized Securities.
It argues that Tokenized Securities should be treated like traditional securities if they incorporate key safety attributes, such as maintaining a redundant secondary record on the blockchain and not being issued in bearer form.
The document urges the SEC to provide new interpretive guidance or no-action relief to allow broker-dealers to use issuers or transfer agents as control locations for Tokenized Securities, facilitating scalable solutions for clearing and custody.
Permissionless or open, public blockchains, including decentralized finance (DeFi), are best positioned to enable the SEC to meet its policy goals relating to capital and digital asset markets.
Safe harbor exemptive relief should extend to the Securities and Exchange Act of 1934, as well as the Securities Act of 1933, and incorporate specific considerations related to DeFi.
The SEC should implement a regulatory sandbox for securities tokenization on open blockchains to develop a new regulatory architecture leveraging open blockchains and complementary technologies.
James Wigginton, Coalition for Cooperative Blockchain Organizations
The advent of Decentralized Autonomous Organizations has ushered in a new era of collaborative innovation and community-drive governance.
In the pursuit of establishing web3 as a transformative force, three fundamental principles must be addressed: transparent, dencentralized technology; durable game incentives with aligned economics; and an unchangeable ethos of benevolence toward all stakeholders.
Limited Cooperative Associations emerge as the keystone that harmonizes with the fundamental principles of stability, aligned incentives, and a benevolent ethos.
