Coin Center sent a letter on Mar. 5 to the Securities and Exchange Commission’s Crypto Task Force, addressing Chair Atkins and Commissioner Peirce, with suggestions for regulatory approaches in the cryptocurrency sector.
The letter highlights Coin Center’s interest in promoting clear and consistent rules for crypto markets, which it says is important for both innovation and investor protection. The organization said it supports the SEC’s recent focus on prospective rulemaking, public participation, and regulatory coherence.
Peter Van Valkenburgh, executive director of Coin Center, wrote that while individualized relief such as no-action letters can provide short-term clarity, "it risks fragmentation, implicit merit regulation, and uneven treatment across projects." He said that only general rulemaking can ensure fairness because "a truly decentralized network will not petition the Commission for exemptive relief, and market participants should not be denied access to superior systems simply because no identifiable sponsor seeks regulatory sign-off." Van Valkenburgh also suggested that a formal safe harbor adopted through notice and comment would improve clarity and legitimacy.
Regarding transfer agent modernization, Van Valkenburgh encouraged the SEC to consider whether blockchain-based systems could eliminate the need for separate transfer agents. He wrote that issuers could handle recordkeeping directly when securities are tokenized on a blockchain. He added that privacy-preserving blockchains offer benefits for user safety and confidentiality: "These systems can incorporate credential verification, view keys and related tools that allow issuers to retain visibility and control over relevant records and grant selective access to regulators or third-parties as needed."
Van Valkenburgh further urged the SEC to avoid unnecessary reintermediation by allowing automated logic to replace traditional intermediaries where possible. He said compliance conditions could be embedded in tokenized securities without human intervention: "The goal should be rules for safely connecting calls, not the mandatory inclusion of a nosey and expensive human operator at a switchboard when none is required."
Coin Center promotes values of open standards, federated trust, personal privacy, and individual freedom in digital identity and cryptocurrency policy arenas according to its official website. The organization works to protect individuals' rights to develop and use open cryptocurrency networks through policy research, education, and advocacy according to its official website. Van Valkenburgh leads Coin Center as executive director with support from a team covering policy areas such as consumer protection, financial surveillance, innovation, investor protection, privacy, autonomy, tax policy according to its official website, as well as operations communications research.
Coin Center functions as an independent non-profit research and advocacy group dedicated to cryptocurrency policy according to its official website, offering educational resources on topics like Bitcoin technology regulatory issues according to its official website.
Van Valkenburgh concluded by commending the SEC's commitment "to thoughtful engagement" and stated Coin Center stands ready to assist as these initiatives move forward.
