An official website of the United States government
Here’s how you know
Official websites use .gov
A .gov website belongs to an official government organization in the United States.
Secure .gov websites use HTTPS
A lock
()
or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.
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.
Diamante proposes a quantum-resilient blockchain infrastructure that supports post-quantum cryptographic integrity and verifiable tokenization of environmental assets, aligning with SEC sustainability and digital asset frameworks.
The system enables transparent, auditable ESG disclosures through immutable transaction history, facilitating compliance with SEC reporting and disclosure requirements for digital assets.
Diamante’s framework demonstrates how tokenized sustainability markets can operate within evolving U.S. securities laws, supporting innovation while maintaining regulatory guardrails and market integrity.
The letter urges the SEC to disclaim or clarify its BarnBridge DAO conclusions, arguing that smart‑contract pools—being software rather than legal persons—cannot “issue,” “sell,” or manage assets as required to qualify as investment companies under the Investment Company Act.
It requests clarification of what, if any, “securities” existed in BarnBridge, noting the order’s lack of analysis identifying which assets in the pools—including stablecoins and third‑party LP tokens—could lawfully be treated as “investment securities.”
It asks the SEC to confirm that EtherDelta is limited to its facts, emphasizing that its conclusions depended on Coburn’s unilateral control and do not apply to decentralized protocols lacking centralized custody, discretion, or governance authority.
The document recommends that custody of digital assets in decentralized markets should be regulated differently from traditional markets, emphasizing technology-neutral standards, robust cryptographic key management, and operational resilience, with tailored requirements for multi-signature, MPC custody, and self-custody arrangements.
The framework treats tokenization as an operational change, not a change in legal categorization, and urges regulators to adapt existing risk categories for tokenized securities, focusing on transparency, operational integrity, and dispute resolution regardless of ledger type.
Regulations should permit temporary commingling of customer assets for operational reasons (e.g., settlement, forks), but require prompt disaggregation, robust internal controls, audit trails, and prohibit rehypothecation except with explicit customer consent.
Charlie Uchill, CERES Coin, LLC - CERES Whitepaper Sep 2025
The GENIUS Act (signed July 18, 2025) provides a statutory definition of "payment stablecoins" and explicitly excludes securities issued by SEC-registered investment companies under Section 8(a) of the Investment Company Act of 1940, allowing CERES Coin to operate as a compliant security and not as a payment stablecoin.
CERES Coin is SEC-registered and patent-protected, enabling unrestricted peer-to-peer transfers and yield generation, while remaining outside the scope of securities laws applicable to non-yield-bearing, 1:1 USD-backed stablecoins, as clarified by the SEC’s April 4, 2025 Statement on Stablecoins.
CERES Coin’s structure and SDVOSB certification (Service-Disabled Veteran-Owned Small Business) enhance eligibility for federal and state set-aside contracts, aligning with government-focused missions and compliance with federal procurement regulations.
Charlie Uchill, CERES Coin, LLC - Ceres Coin Yield Stripping
The yield-stripped derivative securities (SNAP Yield-Stripped Shares) are structured as a separate class of shares in a registered money market fund (MMF), qualifying as securities under the Investment Company Act of 1940 and explicitly excluded from the payment stablecoin definition under the GENIUS Act.
The structure leverages SEC Rule 18f-3 for multi-class funds and Rule 18f-4 for derivatives, ensuring compliance by allocating income via class-specific fees that absorb yield, maintaining $1 NAV stability and avoiding classification as a payment stablecoin or triggering OCC/PPSI requirements.
Implementation requires amending MMF registration, SEC filings, and board-approved allocation methods, with ongoing legal review and potential SEC no-action relief to justify class-specific fees as bona fide for services such as blockchain administration and fraud detection.
Securitize’s issuer-sponsored tokenization model ensures that tokenized public equities are issued directly by the issuer, conferring the same legal rights (voting, dividends, corporate actions) as traditional securities, with all investors KYC-verified and transfers governed by smart contracts for compliance.
Wrapped token and derivative models introduce additional counterparty risk, lack equivalent ownership rights, and often fail to meet KYC/AML and transfer restriction requirements, raising significant regulatory concerns and potential for non-compliance with U.S. securities laws.
Securitize’s model operates fully within existing securities regulations and does not seek exemptions, contrasting with other models that may rely on regulatory arbitrage or require exemptive relief, and advocates for modernization of certain rules to accommodate blockchain solutions.
Public Offerings, Security Status, Tokenization, Trading
The letter emphasizes that digital asset markets involve transactions between spot commodities and securities, necessitating a novel regulatory framework distinct from traditional finance.
CoinRoutes warns that imposing traditional market regulations (e.g., tick size, fee caps) on crypto markets could increase trading costs and reduce competitiveness, potentially pushing liquidity to less regulated international venues.
Effective monitoring of manipulative behaviors like momentum ignition requires integrated surveillance across both spot and derivative crypto markets—something not currently achieved in traditional equity markets.
Private blockchains operated by companies should be governed by internal corporate structures (e.g., boards), ensuring accountability and operational continuity.
Coins used within private blockchains for governance and utility purposes should not be classified as securities if not offered to institutional investors or traded on public exchanges.
Transparent transaction visibility on private blockchains can reduce the need for external regulatory oversight while maintaining stakeholder trust.
The proposal applies the Howey Test to IoT-enabled tokens, affirming that most tokenized physical assets—especially those offering fractional ownership and income rights—qualify as securities under U.S. federal law, thereby triggering SEC jurisdiction and compliance obligations.
The framework mandates that smart contracts embed securities law requirements, including automated enforcement of Regulation D holding periods, accredited investor verification, and transfer restrictions, ensuring immutable compliance with federal securities regulations.
A proposed Self-Regulatory Organization (SRO), under SEC supervision, would certify and oversee oracle operators, requiring them to meet technical, operational, and financial standards, including minimum capitalization, bonding, and compliance with AML/KYC and reporting obligations.
Bank Policy Institute, Association of Global Custodians, and Financial Services Forum
The SEC should not expand the definition of “qualified custodian” to include entities like state-chartered trust companies unless they are subject to regulatory oversight and prudential standards equivalent to those applied to banks.
Investment advisers should not be permitted to self-custody client crypto assets without full compliance with the Investment Advisers Act and related custody rules, as this would expose investors to heightened risks and conflicts of interest.
Any changes to the custody framework for crypto assets must maintain the core principles of asset segregation, separation of functions, and proper control to ensure investor protection and market stability.
