Subject: File No. S7-02-22
From: Anonymous
Affiliation:

Oct. 14, 2023

The scope of coverage of the new SEC rule is indeed quite broad, and it may have unintended consequences. Under the new rule, every person who uses a smart contract could potentially be seen as an exchange. This raises concerns about the potential impact on individuals and organizations operating in the blockchain space.

One of the main concerns is that the broad scope of the SEC rule may stifle innovation and impose unnecessary burdens on developers and users of smart contracts. The rule could potentially extend regulatory requirements to individuals and organizations that do not have the resources or expertise to comply with such regulations. This could hinder the growth of the blockchain industry and limit opportunities for individuals and businesses to leverage the benefits of smart contracts.

Furthermore, the classification of individuals using smart contracts as exchanges raises questions about the applicability of existing regulations. Exchanges are typically subject to stricter regulations, such as Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements. Applying these regulations to individuals using smart contracts could be seen as excessive and may not align with the decentralized nature of blockchain technology.

It is important for the SEC to carefully consider the potential unintended consequences of the rule and ensure that the scope of regulation is proportionate to the risks at hand. There needs to be a balance between protecting investors and fostering innovation in the blockchain space.

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In conclusion, while the SEC's intention to protect investors and ensure market integrity is commendable, the broad scope of coverage and the classification of individuals using smart contracts as exchanges are areas of concern. It is crucial for regulators to strike a balance between regulation and innovation to foster a sustainable and vibrant blockchain ecosystem.