Crypto Task Force Written Input - Recommendations to the Crypto Task Force to Propose a Framework and Address “Security Status” and “Scoping Out”
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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Before proceeding, please note: If you are not a current client of Perkins Coie, please do not include any information in this e-mail that you or someone else considers to be of a confidential or secret nature. Perkins Coie has no duty to keep confidential any of the information you provide. Neither the transmission nor receipt of your information is considered a request for legal advice, securing or retaining a lawyer. An attorney-client relationship with Perkins Coie or any lawyer at Perkins Coie is not established until and unless Perkins Coie agrees to such a relationship as memorialized in a separate writing.
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Before proceeding, please note: If you are not a current client of Perkins Coie, please do not include any information in this e-mail that you or someone else considers to be of a confidential or secret nature. Perkins Coie has no duty to keep confidential any of the information you provide. Neither the transmission nor receipt of your information is considered a request for legal advice, securing or retaining a lawyer. An attorney-client relationship with Perkins Coie or any lawyer at Perkins Coie is not established until and unless Perkins Coie agrees to such a relationship as memorialized in a separate writing.