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
Crowdfunding Professional Association (CfPA)

Re: Crowdfunding for Collectible Tokens (NFTs) 		Public Offerings, Safe Harbor, Security Status, Trading
  • The CfPA opposes creating a separate securities compliance framework for NFTs, advocating instead for the use of existing frameworks like Regulation Crowdfunding (Reg CF) and Regulation A.
  • The CfPA proposes a tailored "Form C-NFT" for NFT-based offerings, which would include specific disclosures and eliminate the requirement for GAAP financials in early-stage campaigns.
  • The CfPA emphasizes the need to maintain anti-fraud and ongoing disclosure protections to prevent deceptive marketing and ensure investor protection.
StartEngine

Recommendations from StartEngine on Regulatory Reforms to Support the Tokenization of Securities 		Custody, Public Offerings, Tokenization, Trading
  • Raise the Reg CF cap from $5 million to $50 million and the Reg A limit from $75 million to $250 million.
  • Permit the issuance and trading of tokenized securities under Reg CF, Reg A, and Reg D.
  • Waive Blue Sky compliance for all secondary transactions conducted on SEC-registered ATSs.
Cardano Foundation

Re: Comments on Commissioner Hester M. Peirce’s Statement / Crypto Task Force Questionnaire 		Custody, Public Offerings, Safe Harbor, Security Status, Tokenization
  • The Cardano Foundation advocates for a functional and risk-based taxonomy for blockchain assets, arguing against using decentralization as a criterion for determining whether a blockchain asset is a security.
  • The Foundation emphasizes the importance of regulatory interoperability, suggesting that the SEC align U.S. frameworks with international standards like MiCAR.
  • The Foundation proposes a technology-neutral approach to tokenization, highlighting its potential to enhance market efficiency and transparency.
Vanguard Global Holdings LLC

RE: Comment on Conditional and Time-Limited Exemptions for Blockchain Innovation – In Response to Acting Chair Mark T. Uyeda’s April 11, 2025 Remarks 		Public Offerings, Safe Harbor, Security Status, Tokenization, Trading
  • Proposal for a conditional exemption for Initial Coin Offerings (ICOs) to facilitate early-stage fundraising for blockchain projects.
  • Implementation of a mandatory basic registration system for entities operating under the exemption to ensure oversight and prevent misuse.
  • Establishment of a public-facing verification tool by the SEC to enhance transparency and investor protection.
     
Michael Guttentag, LMU Loyola Law School

RE: The Importance of Distinguishing Between Doctrinal and Functional Answers 		Public Offerings, Regulatory Sandbox, Security Status
  • The distinction between doctrinal and functional analysis is crucial for effective regulation of crypto assets.
  • Doctrinal analysis focuses on legal precedents and statutory interpretation, while functional analysis considers the practical effects of regulatory interventions.
  • Clear differentiation between doctrinal and functional answers can help in making sound policy choices for crypto asset regulation.
     
Metrika, Inc.

Re: Operational Risk Considerations for Digital Asset Innovation in Traditional Financial Markets 		Custody, Public Offerings, RFI Responses, Tokenization, Trading
  • Tokenization of traditional securities on blockchain protocols introduces new operational risks and challenges that need to be addressed to ensure robust investor protection and minimal disruption to capital formation.
  • The SEC should consider implementing specific digital asset custody requirements for investment advisers and broker-dealers, encompassing key management and risks inherent to blockchain networks.
  • Real-time risk management strategies are essential for investment advisers, broker-dealers, and custodians dealing with digital asset securities to promptly identify and respond to emerging threats
Grace H. Lin & Tris R. Sebesta, The George Washington University Law School

Change Is Calling: A Contemporary Commission To Confront Cryptic Crypto Conditions 		Custody, Public Offerings, Regulatory Sandbox, Security Status, Trading
  • The proposal suggests establishing a new agency, the Federal Digital Asset Commission (FDAC), to provide clear regulatory guidelines and oversight specifically tailored to digital assets.
  • FDAC will implement a tiered licensing structure for crypto-asset service providers (CASPs) and enforce compliance through audits, cybersecurity measures, and financial stability requirements.
  • The document emphasizes the importance of creating a digital asset classification framework to prevent prolonged disputes and ensure market regulation clarity.
DTI Foundation

Re: Public input following announcement of new crypto task force 		Crypto ETPs, Public Offerings, Security Status, Tokenization, Trading
  • The DTI Foundation emphasizes the importance of using the digital Token Identifier (DTI) for unambiguous identification of crypto assets within any future regulatory framework.
  • The DTI is recognized as a global ISO standard and is increasingly adopted for various regulatory reporting requirements in different jurisdictions.
  • The DTI Foundation offers a free service to download the entire DTI registry, ensuring transparency and accessibility for all stakeholders.
Kecheng Lai, Knowpia Inc.

RE: The Future is Here, Now! A Comprehensive Examination of the STO+ Framework and its Regulatory Implications 		Custody, Public Offerings, Regulatory Sandbox, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The STO+ token model aims to ensure compliance with existing legal frameworks while fostering innovation that benefits both investors and users.
  • The conversion mechanism between ST and ST+ tokens is designed to be lawful and beneficial to investors, aligning with existing securities law requirements.
  • The application of SEC Rule 144 one-year lock-up period to ST+ tokens is deemed inappropriate and counterproductive for the STO+ framework.
Vanguard Global Holdings LLC

RE: Contribution to Safe Harbor & Security Status 		Public Offerings, Safe Harbor, Security Status
  • Vanguard Global Holdings LLC supports the SEC initiative to create a clear regulatory framework for the cryptocurrency industry.
  • The company advocates for the creation of a "Safe Harbor" for crypto assets to provide a secure platform for ICOs and IDOs.
  • Vanguard Global Holdings LLC proposes that cryptographic tokens should be considered commodities rather than securities.