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
CoinShares International Limited

RE: It’s Time to Modernize the RIC Tax Rules 		Crypto ETPs, Crypto Lending, Custody, Public Offerings, Safe Harbor, Security Status, Tokenization, Trading
  • Ease the asset diversification requirements in Subchapter M to allow more flexibility for funds.
  • Expand the types and amounts of income that funds can receive without losing regulated investment company (RIC) status.
  • Modify the RIC excise tax distribution requirements to reduce compliance costs impacting investment returns.


 
CoinShares International Limited

RE: Letter to Crypto Task Force 		Crypto ETPs, Custody, Public Offerings, Security Status, Trading
  • CoinShares International Limited discussed the structure and regulatory compliance of their European digital asset ETPs, highlighting their fully collateralized and bankruptcy-remote nature.
  • CoinShares emphasized the importance of staking rewards for investors in spot proof of stake digital asset ETPs and recommended that the SEC avoid setting arbitrary limits on staking percentages.
  • CoinShares requested the SEC to revoke the 2018 open letter from Division of Investment Management Director Dalia Blass, which constrains registered investment advisors' ability to invest in digital assets.
PraSaga Foundation

SagaStandards: Transforming Finance with a Global Standards Registry 		Custody, Public Offerings, Regulatory Sandbox, Security Status, Tokenization, Trading
  • Implementation of open standards for tokenized finance to enhance transparency and reduce fraud.
  • Potential savings of $155B-$316B annually through reduced transaction fees, fraud, and operational costs.
  • Collaboration with international standards organizations (ISO, FIX, XBRL, ISDA) to align financial reporting and trading standards.
     
Superstate Inc.

Response to Crypto Task Force: Digital Transfer Agent -- Moving Securities and Markets from Analog to Digital 		Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The letter emphasizes that existing securities regulations are fully consistent with the tokenization and integration of blockchain technology within the securities markets.
  • It highlights the role of digital transfer agents in enabling the integration of registered and exempt securities by recording and tracking ownership within decentralized finance (DeFi).
  • The letter asserts that tokenized securities, supported by digital transfer agents, can improve market transparency, efficiency, and corporate governance while ensuring re
Solana Policy Institute (by Lowenstein Sander LLP)

Public blockchain infrastructure for on-chain equities issuance and trading 		Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • Covered Blockchain Networks and Validators do not fall within the definitions of "clearing agencies," "exchanges," or "brokers" under the Exchange Act.
  • Validators on a Covered Blockchain Network do not act as intermediaries in the payment or delivery of securities and do not perform the intermediary functions characteristic of a CCP or clearing agency.
  • The on-chain infrastructure ensures that securities transactions are direct, transparent, and settled on a gross, peer-to-peer basis, with no centralized intermediation, custody, or netting.
Solana Policy Institute

Response to the Crypto Task Force’s Request for Comment: Regarding Project Open 		Custody, Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The Solana Policy Institute argues that validators on the Solana network do not trigger registration requirements under securities laws.
  • Phantom Technologies Inc. asserts that non-custodial wallet software does not require broker-dealer registration.
  • Orca Creative claims that its AMM protocols do not function as securities intermediaries.
Crowdfunding Professional Association

Comment Letter Re: Public Offerings of Digital Assets (Questions 7–9) Submitted in Response to Commissioner Peirce’s Statement “There Must Be Some Way Out of Here” 		Public Offerings, RFI Responses, Security Status, Tokenization, Trading
  • The Commission should prioritize disclosure-based solutions over creating new regulatory silos for digital assets, specifically through tailored guidance or interpretive relief under Reg CF and Reg A.
  • Tailored disclosures are essential for meaningful investor protection in crypto asset offerings, and should be required across all exemptions and registrations, including protocol-level details, token characteristics, governance, and liquidity.
  • Regulation A remains underutilized by token issuers, and practical barriers such as uncertainty around eligible crypto assets, conflicting accounting requirements, and delays in qualification timelines need to be addressed.
Securities Industry and Financial Markets Association (SIFMA)

RE: Request for Comment on There Must Be Some Way Out of Here 		Custody, Public Offerings, RFI Responses, Security Status, Tokenization, Trading
  • Issuer disclosures under the 1933 and 1934 Acts should be extended to new categories of securities transactions, including digital assets.
  • The separation of functions and limits on vertical integration must be maintained to ensure investor protection and fair and orderly markets.
  • Direct retail issuance of SEC-regulated products should not be permitted.
Van Eck Associates Corporation

Letter to the Crypto Task Force 		Crypto ETPs, Custody, Public Offerings, Security Status
  • The letter addresses the regulatory framework for digital assets and emphasizes the need for clear guidelines to ensure compliance.
  • It highlights the importance of investor protection and the role of regulatory bodies in overseeing digital asset transactions.
  • The letter calls for collaboration between industry stakeholders and regulators to develop a robust and adaptable regulatory environment.
BSV Blockchain Association

Public Comment for the SEC Conference - "Emerging Trends in Asset Management" 		Custody, Public Offerings, Security Status, Tokenization, Trading
  • The BSV Blockchain Association advocates for a regulatory framework that distinguishes between digital assets serving as data infrastructure or utility tokens and those operating as financial instruments.
  • The Association supports the development and recognition of "digital commodities" where an asset's value is derived from its underlying blockchain system's utility rather than speculative activity.
  • The BSV Blockchain's Digital Asset Recovery (DAR) framework integrates legal due process with blockchain operations, allowing for lawful asset recovery without altering historical blocks.