February 4, 2022
GM, and thank you for the opportunity to comment. I wish it was a longer so that I could further research and address the implications of the hundreds of pages of potential knock-on effects. I'm sure your Commission is well aware how much something like this can impact outside of the direct intent of Amendment.
This impact is the reason for sending you my comment today. I am the CEO of a company building and investing in the blockchain and cryptocurrency space. I have invested a considerable amount of my wealth and time in this, as its potential for solving problems and employing those that otherwise would not have income. I currently employ 35 people that count on me and our company for their livelihood.
This expansion of definitions as written in the Amendment is frightening to many investing and building in the sector. The overly broad definition of exchange extends to \"systems,\" communications, and other protocols that are in no way an \"exchange\" under anyone's common understanding of what an exchange is or does.
As one example, autonomous bulletin board-style sites, protocols, communication mediums and contracts that do not actually provide any exchange services would be considered an exchange when that is not their design or intent. There are plenty of these supporting functions, protocols, companies and teams that are building in the space that to any outside observer look nothing like an \"exchange.\" This Amendment would stifle or stop many of these efforts from building and innovating in the United States, and drive them oversees.
I, and my company, have struggled building in this space due to the impending threat of changing regulations and lack of clarity for years. The SEC has a history of regulation through litigation, instead of providing acceptance and willingness to work with those of us attempting to build within legal bounds. This Amendment, while attempting to codify your purview, is an overstep. The Commission may not understand the implications of the expansion of \"exchange\" definition, the same way the United States just expanded the definition of \"broker.\" These two changes of definition will frankly drive the innovation overseas.
An organization such as the SEC cannot unilaterally expand such an important definition under such a short time constraint, with the intent of stifling innovation and driving development oversees. The SEC has stated they are helping protect people and investors. I am writing this to tell you this would NOT protect me, my company, my employees, or investors. This Amendment along with the many other US changes are small steps toward driving my company overseas.
My company is not large enough to hire large Counsel to navigate the uncertain mine field that is constantly shifting. We are busy building Please don't drive our sector overseas.
I love this country. I have served for decades in the US Military, and would love to have this innovation live in the United States. That being said, I have dozens of people that depend on me and my company to pay their bills. There are many ways the SEC can help the United States safely become the world leader in blockchain and crypto, many of which Hester Peirce have eloquently expressed in many papers. Please help America build and grow the industry - deliberately, freely, and for the benefit of the many.
Thank you for your time.
V/r,
Matthew Voke, CEO
Yip Gaming