November 3, 2026
SEC Updates FAQs Related to Crypto Assets
Yesterday, Corp Fin Staff updated its frequently asked questions on the application of the securities laws to certain crypto assets and crypto asset transactions and the Interpretive Release issued by the Commission in March. Questions 1.4, 1.5 and 1.6 were newly added.
Question 1.4: Addresses when the participants in a functional crypto system’s broad-based governance system are considered a “group of persons or entities” for the purpose of the definition of “central party.”
Question 1.5: Addresses what it means for a central party to “oversee participation” for purposes of the Interpretive Release’s description of a functional crypto system.
Question 1.6: Discusses the relationship between a “functional” crypto system and a “decentralized” crypto system.
– Meredith Ervine
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