KoreInside Comments on Proposed Regulation Crypto Assets
October 19, 2026
Vanessa A. Countryman, Secretary
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
Re: Regulation Crypto Assets; File No. S7-2026-27; Release Nos. 33-11434 and 34-106150
Dear Secretary Countryman:
KoreInside appreciates the opportunity to comment on the proposed Regulation Crypto Assets. We provide technology infrastructure supporting participants in private capital markets. Our comments reflect the operational relationships among issuers, investors, regulated intermediaries, and the systems that maintain disclosures, payments, transactions, and records.
We support the Commission's objective of creating workable capital formation pathways for covered investment contracts while protecting investors. We recommend advancing the proposed framework with targeted changes that make its protections dependable throughout the investment lifecycle. An issuer's exemption, a participant's legal rights, and the responsibilities of those handling a transaction must remain understandable as assets move between systems or a project changes regulatory status.[1]
Our principal recommendation is to recognize a practical infrastructure model that combines durable, verifiable records; reusable evidence of identity, capacity, and eligibility; and coordinated transaction processing with current authorization checks. These capabilities can connect the disclosure an investor receives, the authority for an action, the resulting payment and asset movements, and the evidence retained afterward. We recommend technology-neutral guidance that enables issuers and responsible intermediaries to assemble these capabilities through compatible services, with obligations appropriate to their activities. The recommendations below explain how this model can make capital formation more practical while protecting participants throughout the investment lifecycle.
1 Preserve the distinction between an asset and its legal rights
Requests for Comment 5-8, 15-16, 45, and 126
The proposed definition of a covered investment contract appropriately distinguishes a non-security crypto asset from the investment contract involving that asset. It excludes crypto assets that are themselves securities and investment contracts involving other assets. That boundary should remain explicit in the final rule and related forms.[2]
The Commission should clarify that tokenization, wrapping, migration to another network, or a change in how ownership is recorded does not by itself alter an instrument's substantive legal character. An equity interest, note, or other security should not lose the protections applicable to it merely because it is represented by a token or associated with an arrangement eligible for Regulation Crypto Assets. Similarly, Rule 400 should not categorically extend to notes or other separately enumerated securities. Any broader treatment should receive its own substantive analysis and opportunity for public comment.
Where an offering combines a crypto asset with equity, debt, or another interest, issuers should identify the components and their respective rights. A single investment contract covering both a non-security crypto asset and another asset would not qualify under the proposed definition. Separately structured transactions must each satisfy their applicable requirements, including integration principles. We support the proposal's nonexclusive approach. The presence of one eligible component should not confer exempt status on another component that does not qualify.
This clarity is equally important when reporting requirements end. A determination that an investment contract has ceased to exist for securities-classification purposes should not be presented as canceling contractual obligations, property interests, or claims arising from earlier conduct. Investors should be able to distinguish a change in prospective regulatory treatment from a change in what they own or may enforce.
2 Recognize different architectures and assign responsibility by function
Requests for Comment 4, 8, 11, and 26-30
The final rules should expressly accommodate public, permissioned, and hybrid distributed-ledger architectures, including arrangements that combine on-chain execution with off-chain records or compliance processes. The proposal does not expressly exclude these architectures. Confirmation would help participants avoid treating public visibility or a particular network governance model as a prerequisite for eligibility.[3]
For example, a permissioned ledger operated by identified, accountable participants can support a shared, tamper-evident record with access appropriate to each participant's role and lawful regulatory oversight. It can coexist with public-network representations and protected off-chain evidence where governing rights, authorized changes, and reconciliation are clear. Where representations reference the same entitlement, coordinated controls can prevent a position committed in one system from being treated as independently available in another. The final release should recognize this as a permissible implementation approach and evaluate record integrity, access controls, and transfer safeguards by how they operate.
The definition of an associated crypto network should cover the network or networks materially involved in the asset's issuance, operation, recording, or transfer. Its present focus on where an asset is generated, minted, or mined can leave uncertainty about migrations, bridges, linked representations, and separate execution or settlement systems. The issuer should identify the native asset, any representations of it, and the material dependencies connecting them. Incidental service providers need not become associated networks.
The Commission should also distinguish an offering exemption from the obligations arising when a person performs a regulated activity. The proposal does not require an intermediary for every offering, and it does not resolve requests for exemptions from the definitions of exchange, broker, or dealer.[3] The final release should preserve lawful direct issuance while explaining that otherwise applicable requirements follow the activities actually performed.
Under Rule 103, issuers should identify who performs the material functions relevant to their arrangement, such as solicitation or execution, control of investor assets, maintenance of entitlement records, settlement, and resolution of exceptions. Responsibilities should remain clear when functions are outsourced or automated. No single business model needs every category of intermediary, but investors should not encounter a responsibility gap because several organizations or software components participate.
The Commission should clarify or revise the broad definition of related person and its disclosure application. Providing ordinary services on arm's-length terms should not alone make a technology, hosting, screening, payment, or recordkeeping vendor an insider. The definition and guidance should focus on material influence, economic interests, privileged powers, and conflicts, while preserving disclosure of critical vendor dependencies. A provider that exercises substantive control or participates in a regulated activity should remain subject to the requirements relevant to those facts. Common use of a provider or technical standard should not, standing alone, establish affiliation among otherwise independent issuers.
3 Make disclosures durable and keep material information current
Requests for Comment 27-33, 64-69, 88-90, and 116-117
We support principles-based disclosures supplemented by a concise set of comparable factual fields and nonexclusive examples. These should cover the issuer's commitments, investor rights, material control powers, economic arrangements, and dependencies. The proposal already accommodates inapplicable or not reasonably available information; standardized fields should preserve that flexibility while requiring a clear explanation when an important item is unknown.[4]
The website disclosure approach in Rule 200 needs a durable evidentiary foundation. As proposed, detailed startup disclosures may reside outside EDGAR, material changes generally receive annual updates, and the public-access obligation ends at the earlier of the four-year endpoint or the transition filing. These provisions can leave investors unable to retrieve the information supplied when they invested, particularly after a project or its service provider closes.[5]
We recommend that the final rule require complete, dated versions of material disclosures and amendments to remain publicly retrievable through a stable location, with a change history and links from the relevant SEC filing. An EDGAR attachment or a durable, publicly accessible archive could satisfy this requirement. An issuer-hosted website may serve as the convenient access point, with arrangements that preserve the record if the issuer or host ceases operating. Investors should receive a downloadable copy of the disclosure relevant to their transaction.
The preservation obligation should continue for a specified, proportionate period after the issuer exits the exemption. We suggest six years after the later of the issuer's last sale under the exemption or its transition filing, subject to longer obligations otherwise applicable. This is a proposed retention period, not a description of an existing requirement. The Commission should assess its burden, particularly where inexpensive static archives can satisfy it. Public disclosure archives should remain separate from confidential customer and compliance records.
A practical implementation can link retained documents to a time-ordered, tamper-evident record of disclosure versions, responsible parties, authorizations, and material events. Corrections should identify the superseded entry and authorized change while preserving the relevant history. This allows investors and authorized reviewers to connect the information supplied with subsequent decisions and outcomes. Cryptographic hashes can support version verification; they do not establish truth, replace readable originals, or ensure future access. Equivalent methods should remain available. A docket comment reporting unavailable historical token-launch documents reinforces the importance of retaining accessible source material; our recommendation does not depend on treating that commenter's measurements as representative of all offerings.[6]
Annual updates should be supplemented by prompt notice of material events affecting investor rights, funds, control, or the project's ability to perform its commitments. Examples include material asset loss, a serious security compromise, changes in administrative authority, prolonged inability to transfer or withdraw, material bridge or custody failure, and abandonment of promised development. We suggest an initial startup update within four business days after determining materiality, followed by updates as material facts become available. This uses the same four-business-day interval as proposed Form 1-UC, with a different trigger: proposed Rule 305(a)(4) measures its deadline from the occurrence of a specified event. For startup issuers, this should be a short event notice, not a full periodic report. A materiality determination should be made without unreasonable delay. Similar crypto-specific examples should inform Form 1-UC.[7]
Public disclosure should explain material risks, assessment scope, significant findings, and remediation status while protecting private keys and personal data and avoiding unnecessary disclosure of exploitable technical details or proprietary implementation information. Rule 103(b)(6) already limits source-code links to code the issuer has made publicly available. That distinction should be preserved. Where additional material detail is required, issuers should use applicable confidential-treatment procedures rather than omit material facts merely because they are proprietary.[4]
Electronic delivery should remain practical. For significant lifecycle changes, known holders should receive notice through their agreed channels, with durable access to the relevant document; public distribution and arrangements with intermediaries should address other holders. The Commission should clarify evidence standards for the recipient or authorized representative, document version, notice, availability, and remediation of known delivery failures. A server's acceptance of a message, an automated opening or link scan, and an investor's affirmative acknowledgment are different events. Compliance should not depend on proving that every recipient read and understood every notice. Where acknowledgment is legally required, its content and evidence should be retained. The existing access-equals-delivery approach should be reconciled with these standards rather than replaced with universal click-through requirements.[8]
4 Preserve retail access with proportionate safeguards
Requests for Comment 37-42, 55, 76, 78, 123, and 152
We support access for non-accredited investors and a compliance process that small issuers can administer. The proposed Fundraising Exemption applies its purchaser investment limit to both tiers and permits reliance on purchaser representations absent knowledge that they are untrue. The Startup Exemption has no corresponding individual investment limit.[9]
We recommend retaining the fundraising approach and assessing a modest, graduated exposure safeguard for non-accredited investors making capital-raising purchases under the Startup Exemption. A $5 million issuer ceiling does not limit any particular investor's loss. Calibration should consider exposure and compliance cost, using familiar income or net-worth representations where appropriate. Token distributions for use, participation, or compensation need separate treatment so that an investment safeguard does not unintentionally obstruct ordinary network activity. The Commission should explain the evidence supporting the calibration rather than adopt an arbitrary cap.
Startup disclosures should also include a short, dated, unaudited account of available resources, material financial obligations, intended expenditures, and the assumptions underlying the period for which available resources are expected to support the project. This would help investors assess whether promised work is plausibly funded without imposing a full audit or public-company reporting package on every early-stage project.
Identity, wallet control, investor eligibility, and authority to undertake a particular transaction should be treated as distinct questions. A signature may demonstrate control of a key without establishing the signer's legal identity or capacity. Guidance should recognize optional reusable credentials covering verified individuals and entities, relevant investor attributes, and the authority of representatives. Their issuer, scope, relevant date, expiration or revocation status, and binding to the relevant participant and account or wallet should be clear.[10]
With an appropriate legal basis and permission to share, a participant could supply the necessary verified attributes to another responsible firm without repeatedly circulating complete identification or financial files. The recipient should assess whether that evidence satisfies the requirements of its own activity, obtain updates where needed, and retain its applicable responsibilities and supporting records. Reuse should not automatically import the verification requirements of a different offering exemption.
Personal identification documents and underlying financial information should not be placed on publicly readable ledgers as a condition of participation. Relevant attributes may be conveyed through appropriately scoped attestations, with protected evidence available to authorized parties. Where law requires eligibility, screening, or authorization checks, the responsible party should use information appropriate to the transaction and address material changes before completion. A verified identity, historical whitelist, or unexpired credential should not conclusively authorize a later transaction. Procedures to correct errors and recover compromised access should support continued lawful participation.
Holder-count guidance should likewise distinguish addresses, record holders, and beneficial owners. One person may use several wallets; an intermediated wallet may represent several persons. The Commission should clarify the application of Rule 305(c) and its incorporated holder-of-record rules without substituting wallet counts for the legal standard or permitting account structures to evade it.[11]
Finally, we support consistent bad-actor safeguards and the proposal's reasonable-care provisions. Rule 104 would generally exclude pre-effective-date disqualifying events from disqualification while requiring disclosure.[12] The Commission should reconsider a blanket new starting date where a person remains subject to a relevant, operative disqualifying order. Applicable lookback periods, fair-notice considerations, and individualized waiver procedures can preserve proportionality. At a minimum, prior events must be clearly disclosed as proposed, and the final release should state that the new exemption does not override existing orders or restrictions.
5 Explain ownership controls and settlement responsibilities
Requests for Comment 27-31, 34-36, 116, 150, and 153
Rule 103's treatment of asset rights, governance, security, and the on-chain and off-chain ecosystem provides a basis for practical operational disclosures.[4] We recommend nonexclusive examples addressing the following matters where material to the arrangement:
· Which record establishes or evidences the holder's entitlement, how it relates to other records, and how inconsistencies are resolved.
· Who holds or controls investor funds, assets, or keys; the applicable segregation arrangements; and the material consequences of a custodian's or provider's failure.
· Who may authorize, prevent, reverse, correct, mint, burn, or reissue a position, the legal limits on those powers, and the procedures for disputed actions or key loss.
· How linked or wrapped representations reconcile to the underlying interest and how the arrangement prevents unauthorized duplicate claims or balances.
· How the payment and asset legs are completed, when settlement is treated as final, and who bears responsibility when one leg fails or remains pending.
· What continuity, recovery, complaint, and record-transfer arrangements protect holders if an issuer, network, or service provider stops operating.
These disclosures should match the actual legal and technical model. A protocol-defined asset need not be forced into a corporate share-register structure, and the rule need not prescribe a universal transfer agent or centralized database. Where several records represent the same interest, however, holders need a clear account of which rules or records govern and how conflicts will be resolved.
The final guidance should distinguish identity verification, transaction authorization, execution, and settlement confirmation. Successful code execution establishes only what the code actually performed. It does not necessarily establish the participant's authority, discharge an off-chain obligation, or complete a payment over a separate rail. Material bank, payment-provider, bridge, or custody dependencies should therefore be disclosed together with exception-handling responsibilities.
An illustrative transaction could connect the relevant disclosure version, investor instructions, identity and entity-authority evidence, applicable restrictions, payment instruction, and asset instruction under a common transaction reference. Before an action becomes irreversible, the responsible participant would validate the required authorization for the relevant parties, asset, quantity, and action using current information and address material changes since an earlier check. The workflow would stop a step that lacks required approval and route material exceptions to the responsible party. Connected systems would record which steps are pending, completed, rejected, or require intervention, and reconcile the result with the governing entitlement record or applicable protocol rules. Retry controls should prevent duplicate instructions and reconcile uncertain outcomes before resubmission. Partial failures would have an identified responsible party and resolution procedure.
This coordination can operate through standard interfaces across independently chosen service providers, with accountable human review where needed. It can preserve the evidence of who decided and acted, support reconciliation of linked representations on later permitted transfers, and keep confidential records accessible only to authorized parties. Each participant would retain responsibility for its own functions. The final guidance should recognize such coordinated infrastructure as a means of implementing applicable protections without requiring every step to occur on one ledger or every function to be supplied by one organization.
Liquidity disclosures should distinguish technical transferability, legal eligibility to resell, access to an execution venue, availability of counterparties, and completed settlement. Disclosure of insider allocations, release schedules, contractual restrictions, and material liquidity arrangements should explain resulting conflicts. A transferable token or offering exemption does not itself supply a buyer or ensure an executable price.
6 Require a supported transition and preserve protective controls
Requests for Comment 70-74 and 124-132
We support a nonexclusive, workable means of demonstrating that a covered investment contract has ceased to exist for the applicable securities-classification purpose. Rule 400 should retain a reasoned analysis supporting the issuer's certification. Its completion and permanent-cessation pathways require visibly different explanations, because completion of promised work and abandonment can have very different consequences for holders.[13]
The relevant transition disclosure should identify the issuer's material promises, the work completed, any commitments left unperformed, and the evidence supporting the selected pathway. Consistent with Rule 400(a), it should confirm that the issuer is neither making nor intending new representations or promises of essential managerial efforts. It should address remaining discretionary powers, economic dependencies, material contractual obligations, the responsible contact, and the asserted effective date. A concise commitment-to-evidence schedule could make the analysis useful without requiring a lengthy legal opinion for every project. Independent legal or technical review may be appropriate for complex or materially conflicted determinations, with its scope and limitations disclosed.
Contemporaneously maintained records of commitments, changes, and outcomes can supply the factual basis for that schedule through ordinary operations. This makes the infrastructure useful across the project's lifecycle. Recorded evidence supports the responsible party's substantive analysis; it does not itself determine legal status.
For permanent abandonment, the disclosure should plainly identify non-performance and explain remaining funds or assets, wind-down arrangements, existing refund or return obligations, and available avenues for claims. It should not characterize abandonment as successful completion. The final rule should expressly preserve accrued claims and otherwise enforceable obligations; no automatic new refund entitlement need be created to require disclosure and performance of existing obligations.
The Commission should clarify that routine cybersecurity, recordkeeping, compliance, account recovery, and correction activities do not by themselves establish continuing essential managerial efforts. Maintaining a control that prevents an unlawful transfer or remedies an erroneous record should not alone disqualify an otherwise eligible project from the safe harbor.
The release's discussion of activities after network functionality should nonetheless be applied according to economic substance. It describes a broad range of post-functionality security, maintenance, improvement, and network-effect services as nonessential.[14] Functionality alone should not insulate continuing discretionary work on which the project's promised economic benefits materially depend. The final release should distinguish protective or ministerial services from indispensable managerial activity, including circumstances involving retained control over economically significant decisions. Describing an activity as maintenance, or assigning it to a service provider, should not resolve that inquiry.
The same analysis should apply across governance models. Eligibility should not depend on removing compliance controls, abandoning recovery mechanisms, or reaching an abstract decentralization score. Where an issuer specifically promised a governance change, its performance of that promise remains relevant. The Commission should also explain how genuinely new managerial promises after a transition are evaluated, without treating every security update or ordinary operational service as a new securities offering.
7 Provide usable status information and calibrated reliance protection
Requests for Comment 128-134 and 140-143
The proposal states that Rule 400 would govern the Commission's administration of the securities laws, that the Commission could challenge an inaccurate certification, and that other parties could still assert that a crypto asset is subject to an investment contract or otherwise is a security.[15] These limitations create an implementation problem: investors and responsible intermediaries need a workable basis for decisions without repeating an entire legal and technical investigation for each transaction.
Form TR also has several uses, including leaving the Startup Exemption and suspending reporting. Filing it does not necessarily establish reliance on Rule 400 or cessation of an investment contract.[11] The form and public filing record should prominently distinguish the filing's purpose, the issuer's asserted conclusion, any SEC action, and any subsequent correction, withdrawal, or superseding filing. SEC receipt or an automated status display should never be described as Commission approval of the underlying conclusion.
We recommend a public, machine-readable status record linked to the supporting filings. It should identify the issuer, relevant arrangement, subject asset and material network identifiers, applicable exemption, reporting status, last filed and next due dates, transition basis, and effective timestamps. Part I of Form 1-CRYPTO already contemplates structured XML; compatible fields should extend across the relevant notices and transition records.[16] Such a record should report facts and attributed assertions, not purport to adjudicate legal status. A token name or symbol alone is insufficient to identify the relevant arrangement.
The Commission should establish, within its authority, protection for independent participants who reasonably rely on specified public information, conduct diligence appropriate to their role, and address material warning signs. The standard should avoid liability resting solely on an issuer's undisclosed failure that a diligent participant could not reasonably detect. It should preserve responsibility for knowing or reckless misconduct and unreasonable disregard of material red flags. Ordinary investors should not face the same diligence demands as a regulated intermediary. These recommendations build on transition and reliance concerns raised by Rialto Markets and the public-record concerns raised by Davis Polk.[17]
Where a filing is corrected or a claimed transition is challenged, the framework should support prompt notices and orderly handling of open orders, existing custody positions, unsettled transactions, records, and customer communications. Prospective suspension of new activity may be appropriate while protective settlement or return of assets continues under applicable requirements. The final rules should distinguish issuer misconduct from reasonable conduct by other participants and avoid automatically unsettling completed bona fide transactions where lawful reliance protection can be provided.
The Commission should expressly describe the limits of any protection it adopts. Coordination with other relevant authorities could reduce inconsistent treatment, but an SEC rule should not be presented as binding private claimants, courts, or other regulators beyond its legal reach. Filing-based compliance should make the governing facts easier to establish while preserving appropriate remedies.
8 Avoid a reporting and resale cliff for existing holders
Requests for Comment 66-74, 123, and 136-143
The proposal expressly contemplates a startup issuer reaching four years while its covered investment contract continues. Filing Form TR then ends startup disclosure obligations, and secondary-market state preemption would no longer apply on that basis.[18] Existing holders may therefore lose both a continuing information source and a practical route for resale even though the underlying investment relationship remains unresolved.
We recommend retaining the four-year limit for new offers and sales under the Startup Exemption while allowing a proportionate continuation route for outstanding interests. An issuer could elect to maintain identified disclosures, material-event updates, and a public contact so that eligible resales retain preemption under clearly specified conditions. This option should not reset the fundraising period, increase the offering limit, or excuse an expired exemption for new sales. Where a project has ceased operating, preserved disclosures, a final condition report, and identified custody or claims contacts should support an orderly wind-down.
We support a nationally usable framework for eligible offerings and secondary transactions, with the state antifraud and other retained authorities identified in the proposal. Preemption should remain distinct from federal resale eligibility, contractual restrictions, and the permissions required for a person's intermediary activities. Likewise, extending state preemption to the same covered investment contract initially sold through another exemption should not be described as eliminating federal restrictions applicable to those holdings.
Rule 500(b) limits its secondary-transaction provision to persons other than issuers, underwriters, or dealers. The Commission should clarify how qualifying investor resales executed through an agency broker are treated and whether separate relief is needed for principal dealer transactions. Investors should be able to distinguish preemption for their resale from the treatment of a dealer's own transaction and from registration requirements governing the intermediary.
Currentness conditions should be objectively usable. The proposal already excludes Form 1-UC current reports from the Rule 500 currentness test because outsiders may not know whether a reportable event occurred.[18] We support this recognition of information limits. A specified public record, reasonable reliance, prompt correction notices, and a bounded opportunity to cure remediable filing defects would be preferable to imposing unknowable conditions on innocent holders. Fraud or an immediate threat to investor assets should remain grounds for prompt protective action.
For fungible assets issued through different routes, the Commission should explain which distinctions legally matter and what evidence reasonably establishes them. Tracing every unit's entire history after lawful pooling may be impracticable. Common arrangement-level disclosures can support reliance where appropriate, while records needed to enforce genuine holding-specific restrictions must remain available. The rules should not assume that blockchain transaction history alone answers either question.
9 Recognize reusable infrastructure and compatible standards
Requests for Comment 95-99 and 145-154
We recommend common, openly documented data definitions and export formats for issuer and offering identification, material disclosures, authority records, and regulatory-status events. Participants should be able to use different service providers and networks without losing necessary records or reinterpreting the same facts at every handoff. Equivalent existing records should satisfy overlapping requirements where legally permissible; a new label should not require duplicating the underlying evidence.
Implementation guidance should illustrate how modular services, integrated into participants' existing systems, can satisfy these objectives. Usable forms, clear status definitions, and worked examples should connect disclosure versions, scoped identity attributes, authorization records, transaction status, and provider handoffs. Examples should cover ordinary offerings, multi-network arrangements, custody relationships, genuine completion, and abandonment. Compliance obligations should scale with funds raised, discretionary control, custody exposure, and operational complexity. No particular vendor, ledger, identity system, or independent certification service should be mandatory merely as a consequence of choosing this exemption.
The Commission should also explain material differences in investor protection and compliance burden between this framework and existing offering routes, and consider compatible improvements where risks and legal constraints permit. That work should preserve the scope boundary described above. It should help issuers select the route suited to their actual rights and financing needs, while maintaining meaningful protection for investors across technologies.
These changes would make the proposed framework more usable for issuers and intermediaries and more dependable for investors. We appreciate the Commission's consideration of our comments.
Respectfully submitted,
KoreInside
Dr. Kiran Garimella Oscar A Jofre
Co-Founder, CTO/CSO Co-Founder, CEO
References
1. Securities and Exchange Commission, Regulation Crypto Assets, Release Nos. 33-11434 and 34-106150, File No. S7-2026-27, August 18, 2026, conformed to Federal Register version, pp. 1-3 and 28-31. References below use the printed page numbers of this release. https://www.sec.gov/files/rules/proposed/2026/33-11434.pdf
2. Proposal, pp. 35-43, especially footnote 116; proposed Rules 100 and 101(a)-(b); Requests for Comment 5-8 and 15-16. For equity-security treatment and the scope of Rule 400, see p. 73 footnote 192, Request 45 at p. 77, and Request 126 at p. 167.
3. Proposal, pp. 34-35, 38-41, 60-64, p. 73 footnote 192, and p. 214; proposed Rules 100 and 103(b)(4)-(9). Requests for Comment 4, 8, 11, and 26-30.
4. Proposal, pp. 52-65; proposed Rule 103(a) and (b). Source-code qualification appears at pp. 61-62 and in Rule 103(b)(6). The Fundraising Exemption's confidential-treatment provision appears in proposed Rule 300(d), discussed at p. 127.
5. Proposal, pp. 88-95; proposed Rule 200(d)-(e); Requests for Comment 64-74. The proposal separately requires prompt correction of material Form NOR errors or changes under Rule 200(c)(3); see p. 86.
6. Chain Of Title LLC, letter dated October 12, 2026, pp. 1-4. The letter reports its own observations and expressly states limitations; it does not recommend a particular rule outcome. https://www.sec.gov/comments/S7-2026-27/s7202627-1090979-3829387.pdf
7. Proposal, p. 154, proposed Rule 305(a)(4); Requests for Comment 116-117 at p. 157. The four-business-day startup event notice recommended here is an additional proposal by this commenter.
8. Proposal, pp. 115-120; proposed Rule 300(c)(2); Requests for Comment 88-90. See particularly the electronic-delivery discussion and footnote 291 at p. 119.
9. Proposal, p. 74 footnote 194 and Request for Comment 55 at p. 84; pp. 115-117 and proposed Rule 300(c)(2)(i)(C)-(D), operative text at p. 335; Requests 76, 78, and 152.
10. The Insumer Model LLC, letter dated September 25, 2026, pp. 1-2, addresses optional third-party confirmations, wallet linkage, and the limits of key-control evidence. https://www.sec.gov/comments/S7-2026-27/s7202627-1074599-3724028.pdf
11. Proposal, pp. 159-161; proposed Rule 305(c)-(d); Request for Comment 123. Form TR and its different filing purposes appear at pp. 397-399.
12. Proposal, pp. 67-70; proposed Rule 104; Requests for Comment 37-42. The proposal includes purchaser disclosure for relevant pre-effective-date events, reasonable-care provisions, and incorporated exceptions and waiver procedures.
13. Proposal, pp. 92-96 and 162-169; proposed Rule 400; Form TR, pp. 397-399. Requests for Comment 70-74 and 124-132. Footnote 217 at p. 92 states that neither the Commission nor its staff is required to review or act on the transition report.
14. Proposal, pp. 54-57 and p. 164 footnote 365; proposed Rule 400(a); Requests for Comment 131-132. See also p. 73 footnote 193 regarding decentralization and the issuer's actual promises.
15. Proposal, pp. 166-167; discussion of the conditions and legal reach of Rule 400.
16. Proposal, pp. 128-130; Requests for Comment 95-99; proposed Form 1-CRYPTO Part I.
17. Rialto Markets LLC, undated letter received October 7, 2026, pp. 2-4, https://www.sec.gov/comments/S7-2026-27/s7202627-1086359-3792106.pdf; Davis Polk & Wardwell LLP, letter dated October 15, 2026, pp. 1-8, https://www.sec.gov/comments/S7-2026-27/s7202627-1094859-3845526.pdf. These references identify relevant concerns; this letter does not adopt every recommendation in either submission.
18. Proposal, pp. 169-182, especially pp. 178-179 and footnotes 391-392; proposed Rule 500; Requests for Comment 136-143. The startup disclosure endpoint is separately discussed at p. 92.