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
Alluvial Finance, Inc.

Empowering Global Participation in Securing the Decentralized Internet 		Crypto ETPs, Crypto Lending, Safe Harbor, Security Status, Trading
  • Institutional staking participants should manage and disclose risks from validator concentration and lock-up periods.
  • Clear guidance that Liquid Staking Tokens (LSTs) are not securities will unlock U.S. innovation and adoption.
  • Adaptable regulatory guidance will support competition, innovation, and resilient staking solutions.
DeFi Education Fund

Re: Token Safe Harbor Guiding Principles 		RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • The Safe Harbor should be technology-agnostic, focusing on substance over form and associated risks rather than specific technologies.
  • Eligibility criteria for the Safe Harbor should be broad and inclusive, accommodating a wide range of technologies and projects.
  • Disclosure requirements should be carefully calibrated to provide material information to token holders while being commercially feasible for initial development teams.
OpenZeppelin

Recommendations Regarding Independent Security Audit Reports 		Custody, RFI Responses, Safe Harbor, Security Status, Tokenization, Trading
  • Implement mandatory third-party security audits for blockchain protocols to ensure compliance with security standards and reduce risks.
  • Require detailed documentation of protocols, including governance mechanisms, technical specifications, and security measures.
  • Establish a global organization to formalize auditing standards and certify qualified auditors for blockchain technology.
Neel Maitra, Dechert LLP

Crypto Asset Custody By Investment Advisers After The Sec’s Proposed Safeguarding Rule 		Custody, Safe Harbor, Security Status, Tokenization, Trading
  • The SEC's proposed Safeguarding Rule aims to expand the Custody Rule by requiring RIAs to maintain all client assets, including crypto assets, with qualified custodians.
  • The Safeguarding Rule introduces new definitions for "possession or control" of assets and specifies several assurances that RIAs must receive from custodians.
  • The Rule proposes exemptions for certain assets, such as privately offered securities and physical assets, from the qualified custodian requirement, provided specific conditions are met.
     
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.
     
Chelsea Pizzola, Cumberland DRW

Re: Crypto Task Force Input: Secondary-Market Trading 		RFI Responses, Safe Harbor, Security Status, Tokenization, Trading

  • Cumberland believes that many secondary-market transactions in native crypto assets are not securities transactions, even if the crypto asset was initially offered and sold as part of an investment contract.

  • Cumberland supports adoption of Commissioner Peirce’s proposed safe harbor or similar relief to alleviate concerns for primary issuance and secondary-market trading of Natively Digital Securities.

  • Cumberland suggests that the SEC should consider providing interpretive or no-action relief from certain aspects of the tests for determining whether securities have a ready market, limited
Anonymous

Bitcoin: Look Again 		Safe Harbor, Security Status, Trading

  • Bitcoin should be reconsidered as a security under the Howey Test, given its nature as an investment contract and the collective for-profit undertaking of the Bitcoin network.

  • The SEC should disavow previous statements that include concepts of decentralization to justify limited regulation of digital assets, as Bitcoin and other network tokens are not decentralized.

  • Other network tokens, similar to Bitcoin, also pass the Howey Test and should be considered securities, requiring full and fair disclosure for investors and the public.
Margaret Rosenfeld, Everstake, Inc.

Letter to the Crypto Task Force 		Custody, RFI Responses, Safe Harbor, Security Status, Trading

  • Everstake requests clear guidance affirming that staking and appropriately structured non-custodial staking services do not constitute securities offerings.
  • The letter outlines why staking and non-custodial staking services meet the criteria of an investment contract under the Howey Test.
  • Everstake urges the Commission to issue formal guidance regarding the application of federal securities laws to non-custodial staking services.
     
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.
Dimitry Jean-Noel II

RE: Securing Digital Dollar Dominance: A Comprehensive Framework for Stablecoin Regulation and Innovation 		Custody, Regulatory Sandbox, Safe Harbor, Security Status, Tokenization, Trading
  • The framework mandates 100% reserve backing with high-quality liquid assets, including cash, Treasury bills, and overnight reverse repurchase agreements.
  • It requires stablecoin issuers to maintain robust liquidity management, including stress testing and contingency funding plans.
  • The framework establishes clear redemption rights for stablecoin holders, ensuring they can redeem at par value within specified timeframes.