The Blockchain Association wants objective criteria for determining when tokens no longer qualify as investment contracts and protections for good-faith market participants. The group propose
The Blockchain Association has asked the U.S. Securities and Exchange Commission (SEC) to revise proposed crypto rules covering token exemptions, fundraising and secondary-market trading. In its comment letter, the group urged clearer standards for determining when tokens move beyond investment contracts. It also called for stronger protections for market participants and fewer barriers for crypto startups.
https://twitter.com/BlockchainAssn/status/2112685080770400654?s=20The association wants objective indicators for determining when an issuer’s essential managerial efforts have ended. These should include publicly available source code and no single party able to censor transactions or rewrite network rules.
Additionally, it argues that responsibility should follow control. Projects should answer for activities they control, while third-party applications and community activity should remain outside their responsibility. Exchanges and liquidity providers acting in good faith on project filings should also receive protection.
The group also proposed allowing trading platforms and other qualified third parties to file for tokens already issued. Such filings, it said, should not constitute an admission that a token previously qualified as a security.
The association urged the SEC to raise the Startup Exemption limit to $10 million and the Fundraising Exemption limit to $150 million. It also wants airdrops and network rewards excluded from startup exemption calculations.
Furthermore, it proposed allowing onchain transparency to replace audited financial statements. On market access, the group called for stronger federal preemption to prevent conflicting state requirements.
Its proposal would cover qualifying tokens issued before the rules take effect and trading based on project filings. The association also urged the SEC to address intermediary registration, establish tailored rules for trading venues, and support 24-hour trading and self-custody.
Separately, the Blockchain Association asked the U.S. Treasury to clarify proposed GENIUS Act rules covering decentralized finance software, foreign stablecoin issuers and liability.
The group wants officials to distinguish customer-facing financial businesses from self-custody software and validators. It also argues that liability for unlawful stablecoin issuance should require actual knowledge and meaningful assistance, rather than ordinary secondary-market activity.
For foreign-issued stablecoins, the association favors requirements based on accessible regulatory information. Treasury has not adopted these requested changes, and the proposed rules remain subject to regulatory consideration.
