Ripple asks the SEC to clarify the status of tokens and trading

A response to an official consultation

On 20 October 2026, Ripple sent the Securities and Exchange Commission a letter concerning its proposed Regulation Crypto Assets. The document is available in the regulator's public record. The company supports adopting a binding framework and requests changes concerning investment-contract classification, issuer filings and secondary-market transactions.

The submission is the contribution of a business to a consultation organised to gather positions before the regulator reaches its own decision. It reveals an interested participant's arguments but does not constitute an SEC decision. A letter's content remains attributable to its author even when published on the authority's official website. It is therefore necessary to distinguish the framework originally proposed by the regulator from the additional clarifications that Ripple asks the authority to include.

A fundraising framework that remains proposed

The SEC's official presentation describes two contemplated exemptions from registration obligations. The first would permit certain offerings up to $5 million over four years; the second up to $75 million over twelve months. Issuers would remain subject to disclosure obligations and provisions against fraud and manipulation.

These ceilings do not constitute general permission to raise money without conditions. The proposal defines a framework and criteria that must be satisfied. Eligibility to use an exemption, documentation requirements and applicable restrictions must be examined together. The announced amounts are not sufficient, on their own, to establish that a particular transaction would be covered.

Separating the token from the investment contract

Ripple's central argument is that an investment contract involving a cryptoasset does not necessarily turn the asset into a security. The company asks for the analysis to follow, in particular, the issuer's undertakings and their termination. It therefore advocates an interpretation that would not indefinitely tie every token to a previous contractual relationship.

This position must remain presented as Ripple's contribution to the debate. It does not establish that every access or governance token automatically falls outside securities law. Classification depends on an arrangement's characteristics and applicable rules rather than merely the name given to a token or its advertised function.

Form TR and intermediaries remain central to the requests

The proposal includes a public certification mechanism called Form TR. Ripple notably wants failure to file to create no presumption that an investment contract necessarily continues. It also asks for intermediaries acting in good faith to be able to rely on a published filing under clearly defined protective conditions.

Its letter also addresses secondary trading and ordinary holder activities such as lending or staking. It requests clarification of these operations' legal consequences rather than announcing a universal exemption. Following the next steps will require the regulator's response and any eventual final rule. The 20 October submission explains the changes requested without itself modifying platforms' or investors' rights.

The existence of a public filing provides evidence of the company's position; it should not be read as evidence that the authority has accepted each of those requests. The proposed exemptions, the company's desired clarifications and the rules ultimately adopted remain separate elements of the regulatory process.