CryptoSlate
The US Securities and Exchange Commission's proposal to create two crypto fundraising exemptions had drawn 31 public comments plus one separately labeled meeting memorandum as of August 27, with a 54-day window remaining before the October 20, 2026 comment deadline. The framework would let eligible crypto ventures raise up to $5 million in any four-year period under one path, and up to $75 million in each 12-month period under another.
Why it matters
This is the formal rulemaking record shaping how US crypto startups access domestic capital. Commenters are stress-testing the boundaries the SEC has drawn around disclosure, investor protections, non-cash compensation, and the $75 million ceiling. The letters already posted reveal how granular the negotiations have become: Ohanae Securities, an SEC- and FINRA-registered broker-dealer, pushed for an EDGAR status hub, stronger Form TR disclosures, and good-faith protection for unaffiliated regulated intermediaries that rely on issuer representations. ARKONIX argued that independent partner vaults should not be aggregated under the $75M ceiling merely because they share infrastructure, using an example in which 10 partners each raise $20 million rather than treating their provider as a $200 million issuer.
Market impact
The conspicuous absence is institutional. No major exchange, large asset manager, established token issuer, or large investor advocacy group appears in the visible posted-comment row labels, though the Digital Chamber's Token Alliance says it submitted 13 separate responses covering all 48 questions in an earlier SEC request, with input from more than 75 members. That material sits in a pre-proposal written-input archive, outside the S7-2026-27 comment tally. With the comment window closing in under two months, the trade-offs locked in here will determine whether early-stage US crypto fundraising flows through SEC-supervised channels or migrates offshore.
Frequently asked questions
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What is the SEC's proposed $75 million crypto fundraising exemption?
It is one of two exemptions in a draft SEC framework that would let eligible crypto ventures raise up to $75 million in any 12-month period, with a separate smaller path capped at $5 million over any four-year period.
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When does the public comment window close?
The comment window closes on October 20, 2026, with 54 days remaining from the August 27 cutoff reflected in the posted comment file.
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Why are major crypto institutions absent from the visible comment file?
The posted rows do not name a major exchange, large asset manager, large token issuer, or established investor advocacy group, though bodies like the Digital Chamber's Token Alliance say they filed responses in a separate pre-proposal written-input archive.
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What specific changes are early commenters pushing for?
Ohanae Securities proposed an EDGAR status hub, stronger Form TR disclosures, and good-faith protection for regulated intermediaries. ARKONIX wants separate partner vaults excluded from the $75M aggregation rule. Beeezo and Tilden Moschetti are pushing for sharper rules on non-cash compensation and tighter investor…
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How would the final rule affect where US crypto startups raise money?
If the exemptions stay workable, more early-stage US crypto raises could move through SEC-supervised channels. If the $75M ceiling or disclosure burden is set too tight, founders may continue to raise offshore or under existing Reg D and Reg S paths.
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