Subject: s7-02-22: WebForm Comments from Timothy Gorter
From: Timothy Gorter
Affiliation: CEO, Interdisciplinary Architecture

Jun. 13, 2023

June 13, 2023

 This proposed rulemaking is incredibly flawed and should be abandoned immediately. It is much too vague in key areas. For example, it does not provide the level of token ownership at which an entity must assume regulatory responsibilities, it does not clarify how the rules will be impacted by groups formed also by persons outside of the US, and it does not clarify if or when software developers trigger registration obligations. The rule does not discuss benefits and costs of the proposed change, as it is required to do so.

The SEC needs to recognize the blockchains are decentralized, democratic technologies with many ordinary citizens, like myself, who participate and the rules need to reflect this and not be overly burdensome for persons like myself.

Thank you.