The Blockchain Association has asked the U.S. Securities and Exchange Commission (SEC) to revise its proposed crypto rules covering token exemptions, fundraising, and secondary-market trading. In a comment letter, the industry group urged clearer standards for determining when tokens move beyond investment contracts, stronger protections for market participants, and fewer barriers for crypto startups. Comment letters are a formal part of U.S. rulemaking: agencies review outside feedback before deciding whether to adopt, revise, or withdraw a proposal, giving the group a structured channel to shape the text before it is finalized.

The organization is seeking objective criteria for determining when tokens no longer qualify as investment contracts, along with safeguards for good-faith market participants. It also proposes raising the SEC's fundraising limits to $10 million for startups and $150 million for fundraising exemptions, and wants tailored crypto trading rules, stronger federal preemption, and clearer Treasury guidance on decentralized finance (DeFi) software and foreign stablecoins. Taken together, the requests touch the core mechanics of how crypto projects launch, raise funds, and reach secondary markets in the United States.

Clearer Token Standards Sought

At the center of the comment letter is a call for objective indicators for determining when an issuer's essential managerial efforts have ended. Proposed benchmarks include publicly available source code and the absence of any single party able to censor transactions or rewrite network rules. Those benchmarks map onto the Supreme Court's Howey test — the long-standing standard under which a transaction is an investment contract when buyers reasonably expect profits derived from the efforts of others — with the association proposing concrete, technology-based markers for when that reliance ends.

The association also argues that responsibility should follow control. Under its proposal, projects would answer for activities they control, while third-party applications and community activity would remain outside their responsibility. Exchanges and liquidity providers that act in good faith on project filings should likewise receive protection.

In addition, the group proposed allowing trading platforms and other qualified third parties to file for tokens that have already been issued. Such filings, it said, should not constitute an admission that a token previously qualified as a security.

Higher Fundraising Limits Proposed

The association urged the SEC to raise the Startup Exemption limit to $10 million and the Fundraising Exemption limit to $150 million. It also wants airdrops and network rewards excluded from startup exemption calculations, and proposed allowing onchain transparency to replace audited financial statements. Audited statements are among the costliest recurring obligations for early-stage companies, while onchain records are publicly viewable and update in real time.

On market access, the group called for stronger federal preemption to prevent conflicting state requirements — a reference to the state-by-state patchwork, including money transmitter licensing regimes, that U.S. crypto firms have long had to navigate. Its proposal would cover qualifying tokens issued before the rules take effect, as well as trading based on project filings. The association further urged the SEC to address intermediary registration, establish tailored rules for trading venues, and support 24-hour trading and self-custody.

Treasury Faces Separate Questions Over GENIUS Act Rules

Separately, the Blockchain Association asked the U.S. Treasury to clarify proposed GENIUS Act rules covering decentralized finance software, foreign stablecoin issuers, and liability. The GENIUS Act is the federal stablecoin statute signed into law in 2025, and Treasury's implementing proposals determine how its obligations reach software developers, overseas issuers, and secondary-market participants. The group wants officials to distinguish customer-facing financial from self-custody software and validators. It also argues that liability for unlawful stablecoin issuance should require actual knowledge and meaningful assistance, rather than ordinary secondary-market activity.

For foreign-issued stablecoins, the association favors requirements based on accessible regulatory information. Treasury has not adopted the requested changes, and the proposed rules remain subject to regulatory consideration. Whether either agency folds these recommendations into final rules will help set the operating baseline for U.S. token issuance, trading venues, and stablecoin activity.