Coin Center Urges SEC to Prioritize Rulemaking Over Intermediaries

• Coin Center urges the SEC to favor rulemaking over fragmented case-by-case relief.
• Blockchain systems may replace transfer agents with issuer-led recordkeeping.
• SEC advised to avoid mandatory intermediaries as automation enables compliance.

Coin Center has called on the U.S. Securities and Exchange Commission (SEC) to prioritize formal rulemaking over case-by-case relief and to reassess the role of intermediaries in blockchain-based financial systems.

In a March 5, 2026, letter addressed to Chairman Paul Atkins and Commissioner Hester Peirce, the organization outlined proposals intended to improve regulatory clarity and align oversight with the structure of open blockchain networks.

The letter argues that individualized no-action letters and exemptive relief may offer limited clarity but could lead to inconsistent outcomes across projects. Coin Center stated that such approaches risk fragmentation and uneven treatment, particularly when access to regulatory relief depends on resources and incentives available to specific entities.

Instead, the group recommended a broader rulemaking approach, describing it as more general and forward-looking. According to the letter, decentralized blockchain networks may not have identifiable sponsors to seek regulatory approval, which could restrict access to certain systems if rulemaking is not prioritized. Coin Center also noted that a formal safe harbor established through public processes could improve clarity, legitimacy, and durability in crypto regulation.

Blockchain Systems and Transfer Agent Functions

In addition, Coin Center raised questions about the continued necessity of transfer agents in blockchain-based markets. The letter suggested that, when tokenized securities are recorded on a blockchain, issuers could assume recordkeeping responsibilities. This structure, it is noted, mirrors how stablecoin issuers currently manage records.

The organization also addressed the role of privacy in blockchain systems. It stated that transparency should not be assumed to be a requirement for compliance, pointing to privacy-preserving technologies that enable selective access to data. These systems can incorporate features such as credential verification and view keys, enabling issuers to maintain oversight while granting regulators access when necessary.

More broadly, Coin Center urged the SEC to avoid what it described as unnecessary reintermediation. The letter argued that many functions traditionally performed by brokers, exchanges, and transfer agents can now be executed through automated code and user-controlled identity tools. It added that compliance conditions, including investor eligibility and trade execution standards, can be embedded directly into tokenized instruments.

The group further stated that regulatory frameworks should assign responsibility to the “least cost avoider,” which it identified in many cases as the issuer. While issuers could still delegate functions to third-party providers, Coin Center recommended that such arrangements remain optional rather than mandated.

Related: SEC Clarifies Crypto Rules, Says Most Assets Aren’t Securities