Response to the Securities and Exchange Commission Staff’s April 2019 Digital Asset Guidance
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On April 3, 2019, the U.S. Securities and Exchange Commission staff released a “Statement on Framework for ‘Investment Contract’ Analysis of Digital Assets” and the first no-action letter for a blockchain-based token (“SEC Guidance”).
Rika Khurdayan and Max Dilendorf contributed to the Wall Street Blockchain Alliance – Legal Working Group’s Response to the SEC Guidance, which was published on May 16, 2019.
The report discusses many questions left open by the SEC Guidance, including the differences between digital “investment contracts” and digital “equity securities”, treatment of airdrops, the transition from security to non-security, the process of engaging the SEC’s FinHub and other questions. Check the full report HERE. -hyperlink the word here to take them to report