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
ReFiESG Labs LLC

Pre-Whitepaper: The Rise of ESG 2.0 Humanity’s Final Financial Upgrade Regenerative Tokenization of Everything, Forever. Tokenizing Life, Earth & Governance through ESG-Backed Digital Twins The New Operating System for a Post-Debt, Post-AI World. 		Custody, Public Offerings, Tokenization
  • The ReFiESG Standard introduces a new financial system backed by human existence, aiming to support 144 trillion future humans and last for at least 1,000 years.
  • The ReFiESG Blockchain is designed as a Layer Ø Absolute Zero Covenant Chain, ensuring that all value is anchored in verified human life through Proof of Humanode State (PoHs).
  • The ReFiESG Dynasty Trust secures the pre-minted 144 trillion PAT tokens, governed by a multisig structure involving the Founder and 24 Universal Mothers, ensuring transparent and accountable distribution of regenerative value.
     
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.
Etherfuse, Brogan Law PLLC

Toward a Framework for Tokenized Sovereign Bonds 		Custody, Public Offerings, Regulatory Sandbox, RFI Responses, Security Status, Tokenization, Trading
  • Etherfuse Stablebonds are tokenized bonds backed by sovereign bonds maintained in audited, transparent collateral reserves and are legally offered in Mexico through a resolution from the Mexican financial authority (CNBV).
  • Etherfuse prohibits U.S. Persons from accessing Stablebonds, implementing geofencing and KYC checks to ensure compliance with this limitation.
  • The document proposes that the SEC provide exemptive relief under Section 28 of the Securities Act of 1933 to allow unregistered offering of certain sovereign bonds classified as "Qualifying Foreign Government Securities" (QFGSs).
The Global Digital Assets & Cryptocurrency Association

Token Information Guidelines as a Workable Solution 		Public Offerings, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The Information Guidelines propose a comprehensive disclosure framework for digital asset tokens, aiming to establish transparency and consistency in information disclosure to enable informed decision-making in the digital asset market.
  • The guidelines align with existing U.S. laws and regulations, as well as global regulatory regimes like MiCA, to promote consistent global adoption of information disclosure practices.
  • The guidelines provide flexibility for adaptation to different regulatory regimes and industry standards, supporting innovation, market integrity, and capital formation.
GUARDD, Inc.

Comment Letter – Tokenization, Secondary Trading, and Structured Disclosure Compliance Frameworks 		Custody, Public Offerings, Tokenization, Trading
  • The SEC should recognize modern disclosure platforms under state manual exemption regimes to replace outdated paper-based publishers, facilitating lawful secondary trading of tokenized and exempt securities.
  • The SEC should permit broker-dealers and ATSs to rely on structured digital disclosures under Rule 15c2-11, enhancing compliance and transparency in secondary markets.
  • The SEC should extend federal preemption to secondary trading of securities from issuers current in Reg A reporting, particularly when such reporting is conducted via structured platforms like GUARDD.
PricewaterhouseCoopers LLP

Letter to the Crypto Task Force 		Custody, Public Offerings, RFI Responses, Security Status
  • PwC emphasizes the need for a framework that identifies how the characteristics of different crypto assets (e.g., stablecoins, non-fungible tokens) determine their security status.
  • PwC suggests leveraging existing public offering rules with necessary modifications for crypto assets that meet the definition of a security.
  • PwC recommends expanding custody-related regulations to provide adequate investor protection for crypto assets, even if they do not meet the definition of a security.
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.
     
John A. Zecca, Nasdaq, Inc.

Re: What’s in a Name? A Stock by Any Other Name ... Nasdaq Inc.’s Response to “There Must Be Some Way Out of Here” 		Custody, Public Offerings, Regulatory Sandbox, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The document emphasizes the need for a clear and predictable taxonomy for digital assets to ensure consistent regulation and avoid market distortions.
  • It advocates for a regulatory framework that balances innovation with investor protection, suggesting a light-touch regime for digital assets posing lower risks.
  • The document proposes the establishment of a temporary safe harbor for digital assets not yet clearly classified, allowing them to go to market quickly while pending definitive regulatory classification.
Kecheng Lai, Knowpia Inc.

Recommendation Letter - Supplementary Clarification No. 6: STO+ and the Future Economies of Tokenized Security 		Public Offerings, Security Status, Tokenization, Trading
  • The STO+ model integrates functional utilities, application scenarios, or community governance features into security tokens, combining "securities" with "utility" in a dual-role token.
  • STO+ projects require compliance with securities laws and additional disclosure of token utility and platform tokenomics.
  • STO+ is particularly suitable for Web3 platforms, community-driven projects, and real-world industries with utility-based tokenization.