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
Securities Industry and Financial Markets Association (SIFMA)

Request for Comment on There Must Be Some Way Out of Here 		Custody, RFI Responses, Security Status, Tokenization
  • 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.
     
Mysten Labs, Inc.

Mysten Labs’ Response to “There Must Be Some Way Out of Here”: The Paramount Importance of Utility to the Security Status of Digital Assets 		RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • 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.

Subject: Recommendations for Enhancing Regulation Crowdfunding (Reg CF) Through Blockchain Technology 		Custody, Tokenization, Trading
  • Enable secondary trading of tokenized Reg CF securities via public blockchains to enhance liquidity and reduce counterparty risk.
  • Allow CEO-certified financial statements for raises up to $500,000 to lower capital-raising costs for startups.
  • Permit smart contract-based escrow in place of qualified custodians for raises up to $1 million to reduce costs and improve efficiency.
Securitize, Inc.

Re: Responses to Crypto Task Force Questions related to Tokenized Securities 		Custody, Safe Harbor, Security Status, Tokenization, Trading
  • 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.
North Capital Private Securities Corporation

RE: Custody of Tokenized Securities by Clearing and Carrying Broker-Dealers 		Custody, Tokenization, Trading
  • 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.
Plume Network Inc.

Subject: Comments on the SEC Crypto Task Force’s “There Must Be Some Way Out of Here” Request for Input Questions 		Regulatory Sandbox, RFI Responses, Safe Harbor, Tokenization
  • 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

Navigating DAO Legality (Opolis) 		Tokenization
  • 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.
     
Charles V. Callan, Broadridge Financial Solutions

Subject: Comments on the SEC Crypto Task Force’s February 21, 2025 Request for Information (“RFI”) 		Custody, Public Offerings, RFI Responses, Security Status, Tokenization, Trading
  • Broadridge supports the development of tailored disclosure requirements for crypto assets to enhance investor protection and suggests that disclosures should include both traditional financial information and crypto-specific details.
  • The letter emphasizes the importance of frequent updates on material information for crypto assets, with a recommendation for monthly updates or updates as changes occur.
  • Broadridge highlights the need for greater financial literacy education to help investors understand the unique attributes and risks associated with crypto assets.
Solana Policy Institute, Superstate Inc., and Zagreus Services LLC (dba Orca Creative)

RE: Project Open - Proposing the Open Platform for Equity Networks 		Custody, Public Offerings, Regulatory Sandbox, Security Status, Tokenization, Trading
  • The SEC is requested to exercise its exemptive authority under Section 28 of the Securities Act of 1933 and Section 36 of the Securities Exchange Act of 1934 to permit the issuance and trading of equity securities on public blockchain networks.
  • Project Open Token Shares would be issued via a registration statement filed with the SEC and subject to periodic reporting requirements under the '34 Act.
  • All Token Shares must be held in either non-custodial/self-custodial trader wallets or sub-wallets created for a trader and held by a Broker-Dealer or other appropriate third-party custodian.
     
Lee W. McKnight, Syracuse University School of Information Studies

Distinguishing Jokers from Thieves. Rug Pullers vs SEC Crypto Policies 3.0: Nolo Contendere by Regulatory Design 		RFI Responses, Security Status, Tokenization, Trading
  • The document emphasizes the need for the SEC to consider AI-powered automation and efficiency gains in market oversight mechanisms to improve investor protection.
  • It suggests that the SEC should support demonstrations of exploratory instances of new tools to encourage entrepreneurs and reassure investors.
  • The document highlights the importance of a clear and consistent regulatory framework to encourage innovation and protect investors in digital asset markets.