A Roadmap to Engagement With the U.S. SEC’s New Crypto Task Force

On February 4, 2025, in the first official statement (the Statement) from the Securities and Exchange Commission’s (SEC) newly established Crypto Task Force (Task Force),  SEC Commissioner Hester Peirce provided a glimpse into the priorities and guidelines concerning “the crypto road trip” ahead for all industry participants in the crypto/digital assets space. Most importantly, Commissioner Peirce invites the public to engage with the Task Force, which presents a monumental opportunity for industry participants to shape the future of the digital assets space by engaging via no-action relief requests, written submissions, and virtual or in-person meetings to offer input concerning issues of focus for those participants and development of a new regulatory framework. Sidley has been engaging on behalf of clients with the SEC on these issues for years, including more recent in-person meetings with the Task Force and Commissioner Hester Peirce. It is now more important than ever to engage with the Task Force to voice your views.

The Statement outlines the Task Force’s current priorities and invites public input on them. These issues would affect a wide cross-section of participants, including the following.

Issuers and Protocol Developers: These participants might discuss items concerning the potential security status of certain tokens, structuring future token offerings, and navigating registration exemptions.

Decentralized Finance (DeFi), Lending, and Staking Platforms: These participants might educate the staff on their products and services and discuss how various participants should or should not fall within the ambit of the pending regulatory framework.

Exchanges, Trading Platforms, Transfer Agents, and Clearing Agencies: These intermediaries can discuss issues with the SEC staff concerning exchange-traded products, clearing considerations, transfer agent rules, general market structure, and related token trading.

Wallets, Broker-Dealers, and Custody Solutions: These participants might converse with the SEC staff regarding the pending framework’s applicability to asset custody for retail, institutional customers, and investment advisers as well as proposed modifications to existing guidance for entities that custody both cryptoasset securities and nonsecurities.

Investment Advisers and Funds: For market participants offering investment portfolios that include digital assets, these participants can engage on issues related to compliance with qualified custodian requirements or guidance on investing in or offering digital asset products.

In addition, any financial services institutions beginning to explore the digital assets space would benefit from engaging with the Crypto Task Force as it develops guidance and a new regulatory framework.

The SEC invites market participants to engage with the Crypto Task Force via written submissions and in-person or virtual meetings. The SEC has also launched a webpage² on its official site dedicated to the Task Force that contains “Milestones” (as of today, the recission of Staff Accounting Bulletin 121³ is included) and “Meeting Logs” to provide transparency for public engagement. We suggest interested parties proactively engage, either directly or indirectly, to provide feedback and commentary on existing or new crypto guidance or regulations that should be rescinded, modified, or adopted as SEC officials participate in President Donald Trump’s newly formed Working Group on Digital Asset Markets.⁴ Sidley stands ready to assist clients in navigating engagement with the Task Force and to provide recommendations concerning areas of focus, taking into consideration client business and legal priorities.

Sidley Knowledge Management Lawyer Daniel Engoren contributed to this Sidley Update.