Coin Center urges SEC to prioritize rulemaking over case-by-case relief for crypto

Criptolog » Coins » Coin Center urges SEC to prioritize rulemaking over case-by-case relief for crypto

In a detailed policy push aimed at reshaping how Washington approaches crypto, advocacy group Coin Center has urged the U.S. Securities and Exchange Commission (SEC) to move away from piecemeal, case-by-case decisions and toward robust, transparent rulemaking tailored to open blockchain networks.

Addressing the regulator’s leadership in early March 2026, Coin Center argued that today’s approach—largely built around one-off no‑action letters and bespoke exemptions—may offer short‑term clarity to a few firms but ultimately produces a patchwork of outcomes, uneven treatment and regulatory uncertainty for the broader market.

Coin Center’s March 5 letter to SEC leadership

In a letter dated March 5, 2026, sent to SEC Chair Paul Atkins and Commissioner Hester Peirce, Coin Center laid out a series of recommendations designed to align securities oversight with the technical and governance realities of open blockchain systems. The organization positioned its proposals as a way to increase predictability for innovators while preserving the agency’s investor protection mandate.

According to the letter, individualized no-action relief and narrow exemptions can certainly help specific projects, but they are inherently limited. Because these tools depend on who has the time, money and incentive to petition the SEC, they may skew outcomes toward better-resourced actors and leave comparable projects with fewer avenues to operate legally.

Coin Center warned that this dynamic can lead to fragmentation across the industry, where similar technologies receive different regulatory treatment based largely on which entities manage to secure tailored relief. Over time, the group suggested, such an approach risks undermining the perception of fairness and consistency that is essential for capital markets.

Instead, the advocacy group pressed the SEC to put its weight behind formal, generally applicable rulemaking. In its view, clear rules adopted through standard administrative processes are not only more future‑proof but also better suited to environments where there may be no single company or promoter to stand in for a decentralized network as a whole.

The case for prioritizing rules over ad hoc relief

Coin Center emphasized that many open blockchain networks, especially those run by distributed communities, lack a central sponsor that can readily step forward to negotiate bespoke arrangements with regulators. If access to compliant paths relies too heavily on one-off approvals, these projects may be effectively locked out, even when their structure is compatible with policy goals.

From the group’s perspective, a well‑defined rulebook that accommodates decentralized architectures would level the playing field between large incumbents and smaller or non‑traditional actors. Rather than rewarding those best positioned to lobby for waivers, a formal framework would allow any qualifying project to operate under the same predictable conditions.

Coin Center also floated the idea of a structured safe harbor created via public rulemaking procedures. Such a mechanism, it argued, could give token projects clearer guidance on how to launch, mature and, where appropriate, transition away from securities status—without depending on opaque case-by-case negotiations.

Beyond fairness, the organization linked rulemaking to durability. Rules adopted through notice-and-comment processes are subject to broad input and create a public record, which can make them more resilient to political swings and leadership changes than informal, individualized decisions.

Under this vision, formal standards would continue to evolve, but they would do so through transparent, participatory procedures rather than through a steady stream of ad hoc exemptions that may be hard for outsiders to interpret or anticipate.

Blockchain systems and the role of transfer agents

Coin Center did not limit its remarks to process. The letter also invited the SEC to reconsider some of the traditional roles that intermediaries play in securities markets, especially where blockchain-based records can function as authoritative ledgers of ownership.

In particular, the group questioned whether legacy transfer agents remain necessary in environments where tokenized securities are natively recorded on a blockchain. In such designs, issuers themselves could maintain the canonical record of holders via the network’s ledger, effectively assuming responsibilities usually associated with transfer agents.

The letter pointed to the way many stablecoin issuers already operate as an example of this model in practice. Issuers commonly treat the blockchain ledger as the definitive source for balances and transfers, tracking ownership and adjustments directly through the protocol’s state rather than relying on separate, off-chain books kept by a third party.

Coin Center suggested that, as more securities become tokenized, regulations might adapt to recognize issuer-ledger structures as a compliant alternative to the traditional transfer agent framework. That shift, it argued, could reduce complexity and cost, particularly for issuers that are already deeply integrated with blockchain infrastructure.

At the same time, the organization did not call for stripping away accountability. It acknowledged that issuers could still choose to hire specialized service providers for recordkeeping or operational support, but it argued that such arrangements should be optional rather than mandated in every case.

Privacy, transparency and regulatory access on-chain

Another theme in Coin Center’s message concerned how much transparency is truly necessary on public ledgers to satisfy compliance expectations. The group argued that equating regulatory compliance with fully visible transaction histories is both outdated and technologically unnecessary.

Today’s privacy-preserving tools, the letter explained, make it possible to shield sensitive user data on-chain while still offering regulators targeted visibility when legally required. Techniques such as credential-based systems, viewing keys and other cryptographic methods can give authorized parties access to specific information without exposing everything to the world.

Under this kind of architecture, issuers or responsible entities can maintain ongoing oversight of their tokenized instruments while granting regulators controlled windows into the data to monitor compliance or investigate issues. The broader public, however, would not necessarily see granular personal details.

By embracing these tools, Coin Center argued, the SEC could support systems that respect individual privacy and data protection norms without compromising its ability to enforce securities laws. The key, in its view, is to recognize that transparency and compliance do not have to be synonymous with universal, permanent public disclosure of all transactional data.

This perspective fits into a wider discussion within the crypto community about how to balance openness with confidentiality in financial infrastructure. Coin Center’s contribution to that debate is to underline that the law can accommodate selective transparency, and that regulators can explicitly encourage architectures that separate what must be visible from what can remain private.

Avoiding unnecessary reintermediation in crypto markets

Zooming out, Coin Center urged the SEC to be wary of what it described as “unnecessary reintermediation” in markets built on blockchain rails. In its view, many tasks historically handled by brokers, exchanges and transfer agents can now be executed through automated code in combination with identity tools controlled by the users themselves.

Smart contracts and programmable tokens, the letter noted, are capable of embedding eligibility checks, trading constraints and other compliance conditions directly into the instruments. That means certain regulatory requirements can be enforced by the technology itself rather than by human intermediaries watching over each transaction.

Coin Center argued that, where this sort of automation can reliably deliver on policy goals, rules should not insist on reinstating legacy middlemen purely out of habit. Instead, oversight frameworks should focus on outcomes—such as protecting investors and preserving market integrity—while remaining flexible about who or what performs the underlying functions.

This does not mean, the group stressed, that intermediaries will vanish. There will still be roles for service providers, particularly when it comes to interaction with traditional financial systems or specialized operational tasks. But Coin Center urged that their involvement be driven by cost-effectiveness and real added value, not by regulatory requirements that ignore what automated systems can already do.

To that end, the organization encouraged the SEC to think carefully about where accountability should sit in blockchain-based arrangements. Rather than automatically defaulting to every familiar type of middleman, the agency could consider how responsibility might be assigned in ways that reflect the actual structure and incentives of these new systems.

Assigning responsibility to the most efficient cost avoider

On the question of who should ultimately bear regulatory responsibility, Coin Center endorsed a principle centered on the “least-cost avoider” of compliance failures. Put simply, the party best positioned to prevent violations efficiently should generally be the one tasked with overseeing relevant obligations.

In many blockchain-based setups, the group contended, that party will be the issuer of the tokenized asset. Issuers often control or heavily influence core parameters of the system, such as how tokens can be created, transferred or redeemed, and are therefore uniquely placed to ensure that legal requirements are built into the instrument’s design.

Even so, Coin Center made clear that issuers should retain the option to delegate specific tasks to third-party vendors when it is economically sensible. What it hopes to avoid is a regulatory model that forces issuers to employ intermediaries regardless of whether they meaningfully reduce risk or cost.

By structuring responsibility around the least-cost avoider, the letter argued, the SEC can encourage architectures that meet its objectives in the most efficient way, leaving room for competitive solutions and technical innovation. This approach, Coin Center suggested, would be more adaptive than simply trying to map decades-old securities plumbing onto a very different technological base.

Coin Center’s outreach underscores a broader tension in how regulators approach crypto: whether to fold it into the existing framework through a series of incremental, one-off accommodations, or to craft updated rules that recognize the distinctive features of open blockchain networks. By urging the SEC to favor formal rulemaking, reconsider mandatory intermediaries and embrace privacy-preserving compliance tools, the group is effectively asking for a more systematic reset—one that, in its view, could provide clearer guardrails for industry participants while keeping core investor protections intact.