SEC-CFTC Harmonization Initiative Written Input Log

This written input was submitted through the Written Input Form and is posted without modification. Sharing submissions will help encourage productive dialogue and continued engagement. Note that the “Key Points” column is AI-generated. AI can make mistakes, and the Key Points are not a replacement for reading the entire submissions. Staff has not reviewed these AI-generated summaries for accuracy or completeness. If a Key Point is inaccurate, please email Harmonization@sec.gov and Harmonization@cftc.gov. This written input does not necessarily reflect the views of staff at either the Securities and Exchange Commission or the Commodity Futures Trading Commission.

Date Written Input Key Points
sFOX, Inc.

Re: Notice of Intent to Participate in the "Project Crypto" Innovation Exemption Pilot Program
  • sFOX seeks to participate in the SEC’s “Project Crypto” Innovation Exemption Pilot to enable supervised secondary trading of tokenized real‑world assets (RWAs), including both tokenized commodities and tokenized securities.
  • The firm commits to compliance with all Pilot‑imposed limits, including adherence to AML/KYC requirements, provision of periodic regulatory reporting, and maintaining market‑integrity monitoring for tokenized securities activity.
  • sFOX proposes to act solely as an intermediary and trading venue—without originating or tokenizing RWAs—partnering with third‑party tokenization platforms while operating under existing MSB and trust‑company regulatory authorities.
Veda Tech Labs Inc.

Re: Recommendations Regarding Recognition of Vaults as Satisfying SEC Qualified Custody and CFTC Segregation Requirements for Digital Assets
  • The letter argues that non‑custodial smart‑contract vaults can satisfy SEC qualified custody and CFTC segregation requirements when they eliminate unilateral withdrawal authority, embed programmatic redemption rights, and cryptographically segregate client entitlements.
  • It proposes that the SEC and CFTC adopt a guardrail‑based compliance pathway under which a vault qualifies only if it meets seven structural conditions, including constrained governance, independent auditability, and the absence of affiliated routing incentives.
  • It recommends coordinated SEC‑CFTC rulemaking under the 2026 MOU to create a unified vault‑based custody standard, ensuring consistent treatment of customer asset protection across both agencies. 
Thomas P. Gallagher, Miami International Holdings, Inc.

Letter Regarding Potential SEC-CFTC Harmonization Initiatives
  • Advocates for time‑bound, coordinated SEC–CFTC processes to resolve jurisdictional questions for hybrid products, including escalation mechanisms and the use of targeted exemptive relief to reduce uncertainty and enable innovation
  • Urges streamlining of SEC SRO rule filings, emphasizing use of existing statutory flexibility to accelerate approvals, particularly for routine and fee filings, and aligning processes more closely with the CFTC’s shorter review timelines.
  • Calls for expanded cross‑margining arrangements and strengthened inter‑agency staff coordination, highlighting cross‑margining’s risk‑management and capital‑efficiency benefits and supporting regular SEC–CFTC engagement through enhanced MOUs and public roundtables.
Paradigm Operations LP

Why Close SEC–CFTC Coordination Is Key to Unlocking U.S. Market Innovation
  • Fragmented SEC–CFTC oversight creates duplicative rules, inconsistent definitions, and uncertainty, raising compliance costs and slowing market innovation.
  • Coordinated regulation provides aligned rulebooks, clearer guardrails for digital‑asset products, and stronger systemic‑risk monitoring through shared data.
  • Joint action could unlock new market structures and products—such as equity perpetuals, unified margining, and integrated securities/commodities platforms—while keeping innovation in the U.S.

Last Reviewed or Updated: March 26, 2026