Key Highlights
- Coin Center asked the SEC to prioritize formal rulemaking over individualized no-action letters and exemptive relief, warning case-by-case decisions can fragment the market.
- The group pushed for a formal safe harbor via notice-and-comment, arguing truly decentralized networks can’t “petition” for exemptions and shouldn’t be shut out of tokenization.
- On tokenized securities, Coin Center urged the SEC to revisit transfer agent requirements, saying on-chain systems may allow issuers to handle recordkeeping directly and that privacy-preserving chains can still support compliance access.
Coin Center is pressing the U.S. Securities and Exchange Commission to make crypto market clarity “durable” by writing policy into broadly applicable rules rather than relying on one-off staff relief that, in its view, could quietly pick winners.
In a March 5 letter submitted to the SEC’s Crypto Task Force docket, Coin Center Executive Director Peter Van Valkenburgh addressed SEC Chair Paul Atkins and Commissioner Hester Peirce, saying the agency’s recent posture at ETHDenver signaled a “welcome shift” toward prospective rulemaking and public participation.
“Rulemaking wherever possible,” not selective relief
Coin Center’s first request is straightforward: make rules, don’t govern through exceptions.
The group argued that no-action letters and exemptive relief can deliver short-term certainty, but risk “fragmentation,” “uneven treatment,” and implicit merit-based regulation particularly if relief is granted selectively to projects or intermediaries with the time and legal resources to ask for it.
Coin Center also framed the stakes as structural: decentralized networks, by definition, often don’t have a single issuer or sponsor that can approach regulators for tailored relief. In that scenario, the letter warns, market participants could be denied access to “superior systems” simply because no identifiable party can seek regulatory sign-off.
Call for a notice-and-comment safe harbor
To solve that, Coin Center urged the SEC to create a formal safe harbor through the standard notice-and-comment process positioning it as a legitimacy and durability play, not just a crypto carveout.
The letter argues a safe harbor would allow tokenization subject to investor protections across both permissionless and permissioned systems, and would better match how broad market rules are typically designed: general, prospective, and evenly applied.
Transfer agents, tokenized securities, and “unnecessary reintermediation”
Coin Center’s second major suggestion targets plumbing: transfer agent modernization for tokenized securities.
The group asked the SEC to consider whether blockchain-based systems could, in some cases, reduce or eliminate the need for a separate transfer agent. In an on-chain model where securities are recorded directly on a blockchain, Coin Center says the issuer could bear the recordkeeping obligations itself drawing an analogy to how stablecoin issuers already manage key obligations.
Coin Center also pushed back on a common compliance assumption: that transparency is required for oversight. The letter says privacy-preserving chains now exist and can support credential verification, “view keys,” and selective access for regulators or third parties while protecting user safety and commercial confidentiality.
More broadly, it urged the SEC to resist what it called “unnecessary reintermediation” the tendency to force new technology into old mandated middlemen. Instead, Coin Center argues enforcement responsibility should sit with the “least cost avoider,” often the issuer, which can deploy compliant logic and embed trading constraints directly into the instrument via code.
Why this matters now
The letter lands as the SEC’s Crypto Task Force continues to collect industry input and as SEC leadership publicly signals an intent to move toward clearer crypto frameworks. The Coin Center submission is posted on the SEC’s official “Crypto Task Force Written Input” page, which the agency says is shared publicly “without modification.”
In its ETHDenver remarks, Atkins described a shift in approach and background on his leadership, while Peirce who chairs the Crypto Task Force has emphasized drawing clearer lines and tailoring frameworks for crypto markets.
What to watch next
Coin Center is effectively asking the SEC to prove its “clarity” agenda with formal proposals:
- Whether the SEC initiates notice-and-comment rulemaking on a safe harbor concept (instead of relying on staff relief).
- Whether “transfer agent modernization” evolves into specific rule proposals that recognize on-chain recordkeeping models.
- Whether the SEC explicitly acknowledges privacy-preserving compliance tooling as compatible with tokenized securities oversight.
Also Read: SEC Issues Landmark Guidance on Crypto Asset Regulatio
