Ripple Backs the SEC's Crypto Rule, Others Want Its Caps Raised

The comment window on the US Securities and Exchange Commission's proposed crypto rule shut on 20 October, and the two loudest filings of the last day asked for opposite things. Ripple told the Commission to adopt Regulation Crypto Assets as written. The Blockchain Association told it to raise the two offering caps at the centre of the rule, to $10 million for startups and $150 million for larger raises, up from $5 million and $75 million. Both letters landed on File No. S7-2026-27. Neither is on the Commission's docket yet.

Ripple's 20 pages

Ripple's letter runs 20 pages, by crypto.news's count, and the company's chief legal officer Stuart Alderoty confirmed the filing on X on Tuesday. The argument turns on a distinction. An investment contract can be a security, Ripple says, without the token attached to it being one. The company wants the end of such a contract judged by whether the issuer kept or withdrew its express promises, not by a separate test of how decentralised a network has become. It also asks for more certainty around Form TR, the transition report an issuer files to leave the investment-contract analysis behind, so brokers and exchanges can rely on a properly filed one when deciding whether to list a token. Ripple puts the cost of its own past litigation with the Commission above $150 million in legal fees, a figure only the company has given.

"We support the proposal, and the SEC has clear authority to adopt it," Alderoty said in the post.

The caps, and who wants them higher

The Blockchain Association's asks go past the numbers. It wants a federal standard for when a token is decentralised enough to stop being treated as an investment contract, with public source code and the absence of any unilateral power to review transactions among the possible indicators. It wants on-chain transparency accepted in place of audited financial statements under the larger exemption, and airdrops left out of the cap altogether. A third-party filing route would cover tokens already circulating. On that last point the letter is careful, in the PANews rendering: "such filings shall not be construed as an acknowledgment that the token was ever a security." TokenPost and PANews agree on both cap figures. TokenPost alone reports a $20 million first tier inside the $75 million exemption, which the Commission's own August release does not print.

How many letters is not settled

The count depends on the account. PANews put it at about 140 on the morning of the deadline, six of them anonymous, and Crypto Briefing gave the same figure after the close. The Block, publishing at 3:18 p.m. EDT on the deadline itself, said more than 100 had come in. The two do not reconcile, and the Commission's own comment page cannot settle it. Checked on Wednesday, the newest letter it had published was dated 16 October, behind five pages of entries and no printed total. Davis Polk & Wardwell, Ava Labs, Hedera Hashgraph, SkyBridge Capital and the Global Legal Entity Identifier Foundation are already visible there, alongside private individuals. One of those, from a self-described student, closes on a single line: "I urge the Commission to adopt Regulation Crypto Assets substantially as proposed."

Whether the window really shut

Two outlets reported on Tuesday night that in practice it has not. Both trace the claim to one source, a post by the journalist Eleanor Terrett quoting an unnamed Commission spokesperson. The quote each carries breaks off mid-sentence. No replacement deadline was given and no formal extension was filed. The rulemaking page still prints 20 October. The pressure points named across the filings are narrower than the rule: airdrop treatment and the reach of the safe harbor, plus the opt-in mechanics SIFMA wants changed before the innovation exemption's five-year term hardens market practice. The Hyperliquid Policy Center, which asked for five changes before Tuesday, said in a Monday post that the safe harbor "requires a certification that many projects cannot make." Nothing the Commission does next carries a date.