The U.S. Securities and Exchange Commission has received more than 100 comment letters on a new crypto rule proposal. The SEC plans to keep accepting comments even after the submission deadline passed on Oct. 20 local time.

According to blockchain media outlet Coinpost, key questions have centered on what registration exemptions to allow for crypto fundraising and when tokens fall outside securities classification.

Regulation Crypto Assets, proposed by the SEC in August, lays out a framework that exempts certain offerings from registration requirements under securities law for crypto-based fundraising such as ICOs. The proposal includes a "startup exemption" that applies up to $5 million over four years and a "fundraising exemption" for up to $75 million over 12 months. It also includes a safe harbor to identify when a token is no longer linked to an investment contract.

The Hyperliquid Policy Center on Oct. 19 supported adopting the proposal itself but called for changes in five areas. "Until now, projects could not be sure whether securities law applies to tokens," the group said, adding that this has led many to choose offshore issuance or exclude U.S. persons from distributions.

Airdrop provisions in particular have emerged as a central issue. The Hyperliquid Policy Center called for the rule text to clearly state, as in the SEC's March interpretation, that distributing tokens to recipients who did not pay consideration does not constitute an "investment of money." It also asked for confirmation that receipt procedures such as wallet connections or sanctions screening are not considered consideration.

The safe-harbor design has also drawn calls for changes. The Hyperliquid Policy Center said many projects would find it difficult to submit the required supporting materials. The proposal requires proof that key work by the business side — work on which token holders rely while expecting profit — has been completed, and the group said that structure could be interpreted as projects acknowledging that tokens were once investment contracts.

Comments also continued on disclosure standards. Blockworks proposed incorporating items from its "Token Transparency Framework," which it has operated since June 2025, into the rule. It also called for allowing third parties such as exchanges to assign disclosure drafting to independent disclosure providers that meet the standards, and for a system that lets third parties update information even after a project stops reporting.

The Alternative Investment Management Association said information explaining investors' legal rights and risks should be clearer. It said issuers should present tokens' utility aspects and economic exposure separately from ownership, redemption, cash flows and contractual rights. It also said standards should be clarified for event reporting tailored to individual cases and for handling information that cannot be obtained.

Concerns were also raised about the separate "Innovation Exemption" for on-chain trading of tokenized stocks. The Securities Industry and Financial Markets Association on Oct. 19 requested immediate action on investor protection and changes to participation, saying the five-year temporary exemption that took effect in September could lock in market practices first. It said the initial design could effectively become the standard before a permanent system is put in place.

Against this backdrop, the SEC has decided to keep accepting comment letters after the deadline. According to Eleanor Terrett, an SEC spokesperson said comments on the proposal will continue to be accepted after the cutoff. How much the final rule text reflects issues such as how to assess free airdrop distributions, the burden of proof under the safe harbor and a third-party disclosure system is expected to be a key focus going forward.