We write in response to your February 21, 2025, request for public input on some of the difficult questions facing the Crypto Task Force in its effort to determine how to distinguish securities transactions from non-securities transactions (Task Force Statement).
We offer these comments as practitioners in the Fintech practice at Perkins Coie LLP who regularly advise clients on compliance with the securities laws relating to crypto assets. We intend to provide two submissions. This first submission introduces the framework that we recommend as the Crypto Task Force contemplates a reasonable approach to regulatory oversight of crypto assets.
This submission will also address questions 1, 2 and 5 under “Security Status” and “Scoping Out”. Our follow-on submission will address questions 3, 4, and 6 through 9.
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