July 11, 2018
SEC,
I do believe centralized ICO’s or centralized “Blockchains” running on a minimal number of nodes owned by one authority rather than being decentralized and dispersed should be regulated as securities.
I do not believe “validator nodes” relaying information back to the centrally controlled “Blockchain” (in this case, more of a centrally operates and maintained group of company owned data ledgers) should count toward the title of “decentralized”, as in the case of Ripple Labs’ “XRP”.
I do believe, similar to the previous rulings around Bitcoin and Ethereum not being labeled securities, that “Proof of Work” (concept whereby data on the decentralized and immutable data ledger is “mineable” through the usage of directed energy) Blockchains should not be labeled securities, especially if there was no Initial Coin Offering surrounding the release of the Blockchain, as in the cases of Litecoin or DigiByte, for examples.
I believe that ICO’s (initial coin offerings), if centralized, should be labeled securities. This goes for at least 95% of registered ICO’s. ERC-20 “tokens” built on the Ethereum (ETH) Blockchain are primarily released with an ICO, for example.
I believe any company or centrally owned authority stating that their Blockchain is “decentralized” in the same way that government fiat is “decentralized” (in that it is created or pre-mined or virtually printed by a central authority) should be held to the strict regulatory ruling of being labeled a security.
Best regards,
Devon Cutak