1. Jason Brett, "Congress Has Introduced 50 Digital Asset Bills Impacting Regulation, Blockchain and CBDC Policy," Forbes, May 19, 2022.
2. Paul Kiernan, "More Crypto Market Turmoil Is Predicted by SEC Chairman Gary Gensler," Wall Street Journal, May 18, 2022; and Isabelle Lee, "The CFTC Chief Said His Agency Should Oversee Crypto in a Challenge to SEC's Gensler," Markets Insider, October 27, 2021.
3. This paper addresses cryptocurrencies that do not endeavor to peg their price to another asset (e.g., a fiat currency) either by maintaining collateral reserves or using an algorithmic method. In this paper, "cryptocurrency" specifically refers to nonpegged cryptocurrencies and is used interchangeably with "token." For recommendations for regulating reserve-backed stablecoins, see Norbert J. Michel and Jennifer J. Schulp, "A Simple Proposal for Regulating Stablecoins," Cato Institute Briefing Paper no. 128, November 5, 2021.
4. See Elisabeth A. Keller, "Introductory Comment: A Historical Introduction to the Securities Act of 1933 and the Securities Exchange Act of 1934," Ohio State Law Journal 49 (1988): 343–44.
5. See, e.g., Lummis-Gillibrand Responsible Financial Innovation Act, S. 4356, 117th Cong. (2022); Digital Commodity Exchange Act of 2022, H.R. 7614, 117th Cong. (2022); Clarity for Digital Tokens Act of 2021, H.R. 5496, 117th Cong. (2021); and Strategic Hub for Innovation and Financial Technology, "Framework for 'Investment Contract' Analysis of Digital Assets," Securities and Exchange Commission, modified April 3, 2019. See also Jack Solowey, "Don't Put the Cart before the Horse When Regulating Crypto," Cato at Liberty (blog), Cato Institute, May 18, 2022.
6. See Hester M. Peirce, "On the Spot: Remarks at 'Regulatory Transparency Project Conference on Regulating the New Crypto Ecosystem: Necessary Regulation or Crippling Future Innovation?'" (transcript of speech, Washington, DC, June 14, 2022).
7. See Peter Van Valkenburgh, "Framework for Securities Regulation of Cryptocurrencies," Coin Center, August 2018.
8. 15 U.S.C. § 77b(a)(1).
9. SEC v. W. J. Howey Co., 328 U.S. 293, 298–99 (1946).
10. These problems often are labeled an information asymmetry and agency problem. See Paul G. Mahoney, "The Economics of Securities Regulation: A Survey," working paper, Law and Economics Research Paper Series 2021-14, University of Virginia School of Law, August 2021, pp. 8–9. See also Keller, "Historical Introduction to the Securities Act of 1933 and the Securities Exchange Act of 1934," pp. 338–39.
11. In 2019, the Securities and Exchange Commission's Strategic Hub for Innovation and Financial Technology (FinHub) published a framework for assessing whether a cryptocurrency purchaser is relying on the efforts of others, but it did not provide conclusive guidance. FinHub, "Framework for 'Investment Contract' Analysis of Digital Assets." See also Solowey, "Don't Put the Cart before the Horse When Regulating Crypto."
12. United Housing Foundation Inc. v. Forman, 421 U.S. 837, 852 (1975). See SEC v. Glenn W. Turner Enters. Inc., 474 F.2d 476, 481-82 (9th Cir. 1973). See also FinHUB, "Framework for 'Investment Contract' Analysis of Digital Assets"; and Basil V. Godellas, "When It Comes to Analyzing Utility Tokens, the SEC Staff's 'Framework for "Investment Contract" Analysis of Digital Assets' May Be the Emperor without Clothes (Or, Sometimes an Orange Is Just an Orange) (Part IV)," Non-Fungible Insights: Blockchain Decrypted (blog), Winston & Strawn LLP, December 18, 2019.
13. This test is based on the "Bahamas Test" proposed by professors M. Todd Henderson and Max Raskin, which asks: "If there is a minting and selling of an instrument, as opposed to open mining of it, is there either an explicit or implicit contract to build and manage software such that if there were a breach of that contract, the project would fail? . . . Said differently: if the sellers fled to the Bahamas or ceased to show up to work—like Satoshi Nakamoto—would the project still be capable of existing?" M. Todd Henderson and Max Raskin, "A Regulatory Classification of Digital Assets: Toward an Operational Howey Test for Cryptocurrencies, ICOs, and Other Digital Assets," Columbia Business Law Review 2019 no. 2 (2019): 461.
14. To the extent decentralization exists on a spectrum, Bitcoin arguably sits at one pole as the "gold standard," as its anonymous creator, Satoshi Nakamoto, did not promise performance at the point of sale or otherwise. Nonetheless, other cryptocurrencies can pass this proposal's test, depending on their development stage, and decentralize over time, as Ethereum arguably did. See Henderson and Raskin, "Regulatory Classification of Digital Assets," pp. 470–73. See also "Ether Sale," History of Ethereum, Ethereum, last updated July 14, 2022.
15. Hester M. Peirce, "Running on Empty: A Proposal to Fill the Gap between Regulation and Decentralization" (transcript of speech, Chicago, February 6, 2020).
16. Commissioner Peirce proposed an innovative solution to this problem: a safe harbor delaying by three years the application of key securities law provisions to decentralizing projects, provided that the projects made certain disclosures and after three years either achieved decentralization or registered under the Securities Exchange Act. Hester M. Peirce, "Token Safe Harbor Proposal 2.0," Securities and Exchange Commission, April 13, 2021. The proposed Clarity for Digital Tokens Act of 2021 sought to codify the safe harbor. Clarity for Digital Tokens Act of 2021, H.R. 5496, 117th Cong. (2021).
17. Mining tokens according only to a distributed validation protocol would not be a sale in which a third party made a promise to the recipient regarding future performance. See Henderson and Raskin, "Regulatory Classification of Digital Assets," pp. 452–53; and Van Valkenburgh, "Framework for Securities Regulation of Cryptocurrencies."
18. See Peirce, "Token Safe Harbor Proposal 2.0"; Securities Clarity Act, H.R. 4451, 117th Cong. (2021); and Lummis-Gillibrand Responsible Financial Innovation Act, S. 4356, 117th Cong. (2022). Congress should make conforming amendments, including for secondary market sales of qualifying intangible assets not to be subject to inapplicable securities laws, such as by amending 15 U.S.C. § 78c to exclude from the definitions of "exchange," "broker," "issuer," and "dealer" persons who otherwise would be subject to those definitions but conduct their ordinary business with respect to intangible assets qualifying for the tailored registration under 15 U.S.C. § 77c(a)(15). These persons should remain subject to those definitions with respect their activities that fall within such definitions but do not involve qualifying intangible assets.
19. These disclosures are based on Commissioner Hester M. Peirce's safe harbor proposal. Peirce, "Token Safe Harbor Proposal 2.0." For another "fork" of the disclosures described under Peirce's proposal, see lex-node, "SafeHarbor X," GitHub, January 8, 2022. See also Chris Brummer, Trevor I. Kiviat, and Jai R. Massari, "What Should Be Disclosed in an Initial Coin Offering," in Chris Brummer, Cryptoassets: Legal and Monetary Perspectives (Oxford, UK: Oxford University Press, 2019); and Carol R. Goforth, "Cinderella's Slipper: A Better Approach to Regulating Cryptoassets as Securities," Hastings Business Law Journal 17, no. 2 (February 2021): 329.