Submission to the U.S. Securities and Exchange Commission

Comment on Regulation Crypto Assets

Regulator
U.S. Securities and Exchange Commission (SEC)
Date filed
Filed by
Auditchain Labs AG
File number
S7-2026-27
Release number
33-11434
Release number
34-106150
RIN
3235-AN38
Responding to
Regulation Crypto Assets

Summary

Our comment on the SEC's proposed Regulation Crypto Assets makes one main request: every disclosure should be readable by computers, not just by people. Under the SEC's proposal, issuers would file most disclosures as ordinary documents. Instead, we recommend that every form use XBRL, the data format the SEC already uses on EDGAR. We also recommend that each filing carry a digital fingerprint recorded on a public blockchain. As a result, anyone can check that what they read is exactly what the issuer filed. To show how this works, we built a data dictionary for Regulation Crypto Assets and nine sample filings for one example company. In addition, we answer each of the SEC's 68 questions about disclosure. Finally, we note that the proposal does not say how markets should trade and hold existing crypto investment contracts. See also our other comments to the SEC.

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