In a formal submission made this month, the cryptocurrency advocacy group Coin Center has encouraged the U.S. Securities and Exchange Commission to refine its approach to digital asset oversight. Addressed to Chairman Paul Atkins and Commissioner Hester Peirce, the letter commends the pair for their collaborative comments at the recent ETHDenver event.
It highlights how their outlined priorities signal a promising evolution toward forward-looking regulations, greater stakeholder input, and consistent policy application across crypto markets.
In a letter to the SEC, Coin Center suggests the agency:
1) Prioritize rulemaking over case by case no-action letters
2) Consider whether open blockchains obviate the need for transfer agents altogether (and to resist rent seeking state-mandated intermediation) pic.twitter.com/a4OWl2kaLO
— Neeraj K. Agrawal (@NeerajKA) March 17, 2026
Guided by its core objective of safeguarding decentralized, open-source blockchain systems and Americans’ ability to utilize them without restrictions or surveillance, Coin Center presents two practical recommendations alongside a broader strategic vision.
The think tank stresses that these ideas aim to foster genuine innovation while upholding investor safeguards.
First, the organization strongly advocates shifting emphasis from individualized no-action letters and case-specific exemptions toward broad rulemaking processes.
While temporary relief measures can deliver quick guidance in the near term, they often lead to inconsistent outcomes, hidden judgments on project merits, and disparities among participants.
Coin Center argues that the real strength of blockchain networks stems from their role as shared public utilities, akin to foundational infrastructure rather than proprietary corporate offerings.
Granting exemptions on a selective basis inevitably tilts the competitive landscape toward entities with greater resources and lobbying power.
The letter explains that highly decentralized platforms, equipped with protections against self-dealing, hidden operations, and other risks, frequently outperform traditional permissioned setups that rely on trusted third parties.
Allowing tokenization under appropriate investor protections for both system types would be ideal, but only systematic rulemaking can achieve this equitably and prospectively.
Truly autonomous networks rarely seek special approvals, and market users deserve access to superior technologies without barriers imposed by the absence of a sponsoring intermediary.
Establishing a clear safe-harbor framework through public notice-and-comment procedures would deliver enduring transparency, legitimacy, and stability.
Second, Coin Center invites regulators to evaluate whether advanced blockchain solutions could render conventional transfer agents obsolete in certain tokenized security scenarios.
When assets are registered directly on distributed ledgers, issuers might assume recordkeeping duties themselves, mirroring current practices among stablecoin providers.
The group cautions against presuming that full on-chain visibility is essential for regulatory adherence.
Modern privacy-focused chains deliver significant advantages for protecting user data and business secrets while incorporating tools like credential checks, selective viewing permissions, and controlled access mechanisms.
These enable issuers to maintain oversight and share information with authorities or partners as required.
Ultimately, recordkeeping responsibilities should remain with the original issuer, who retains flexibility to outsource tasks voluntarily rather than under compulsory rules.
Expanding this perspective, the submission calls for rejecting avoidable layers of intermediation.
Securities regulations function best as universally applicable standards, with enforcement targeted at the most efficient party enabled by permissionless technology.
In many instances, issuers themselves can integrate compliance logic and maintain records, choosing to delegate only when beneficial.
Functions once handled by brokers, dealers, exchanges, or transfer agents can now occur through self-executing smart contracts and sovereign identity systems activated precisely when investors engage with assets.
Key restrictions—such as buyer eligibility or minimum trade standards—can be coded directly into the security and upheld automatically, eliminating the need for manual oversight.
Coin Center acknowledges that certain industry bodies might oppose this direction because their operations hinge on government-required intermediaries.
Such positions warrant scrutiny to distinguish legitimate concerns from attempts to safeguard profits derived from regulatory bottlenecks.
Whenever automated systems can reliably substitute for those points of control, policies should enable issuers to assume direct accountability instead of mandating superfluous participants.
Drawing a historical parallel, the aim is to craft guidelines ensuring secure connections, much like telephone rules that once avoided forcing every call through an obligatory, costly operator.
The letter closes by acknowledging the Commission’s dedication to constructive dialogue and expresses Coin Center’s readiness to support ongoing efforts. This input arrives amid discussions on adapting legacy securities frameworks to blockchain ecosystems, potentially paving the way for more efficient, inclusive, and innovation-driven markets.