Response to S7-2026-27 Comments on US SEC’s Proposed Rule: Regulation Crypto Assets 26 September 2026

We submitted formal comments on the SEC's proposed Rule 103 and Form 1-CRYPTO, drawing on our experience preparing over 100 MiCA white papers and developing UK QCDDs. We support Rule 103's principles-based approach substantially as proposed, recommending targeted additions: express disclosure of the rights attached to the crypto asset itself, technical audit status and scope, governing law and dispute forum, and a clearer distinction between the issuer of the investment contract and the issuer of the crypto asset.