Apr. 21, 2023
To whom it may concern, I am writing to express my general support for the proposed rule changes regarding exchange activity involving crypto asset securities and distributed ledger technology (DLT). I believe that these rule changes are a good beginning to ensure fair and transparent markets for all participants. The proposed rule changes should help to address lack of regulation in crypto spaces by providing a clear regulatory framework for platforms that offer trading in crypto asset securities; By requiring these platforms to register as national securities exchanges or comply with the conditions of Regulation ATS, the SEC can ensure that these platforms are subject to the same level of oversight and regulation as traditional exchanges. In addition, I believe that the use of DLT in the trading of crypto assets is a significant development that should be encouraged. DLT has the potential to increase transparency and reduce transaction costs, which can benefit both investors and market participants. By explicitly recognizing the use of DLT in the trading of securities, the SEC can help to promote the adoption of this technology and encourage further innovation in the industry. Overall, I believe that the proposed rule changes will help to promote fair and transparent markets for all participants, while also encouraging innovation and growth in the digital asset industry. One sidenote: I do hope there is additional clarification between DLT as a technology, and digital assets that contain an inherent value. Just because something is decentralized does NOT make it a security. NFT's being sold on a marketplace are not necessarily a security, despite containing value and having a decentralized ledger. There needs to be a very clear distinction, specifically where tokenized securities exist. FTX's downfall and ultimate failure leads me to believe there is more going on behind the scenes with relation to the stock market and moving money/information around between it and crypto exchanges. In plain english, what I would like to see: Tokenized securities that act as a 'digital stock market' fall under the same rules as stock exchanges. Monetary penalties are no longer just 'a cost of doing business' - companies that do not comply should LOSE THEIR LICENSE TO OPERATE. Once they do comply, they can resume operations. Digital Ledger Technology that is leveraged on non-securities such as digital playing cards, loot boxes, loot drops, in-game assets, etc. do not fall under the jurisdiction of the SEC; Just because it's using similar tech does not mean it's a security. Thank you for your time, Dave Champagne