Hyperliquid Policy Center, or HPC, said it has submitted a comment letter to the U.S. Securities and Exchange Commission supporting the agency’s proposed Regulation Crypto Assets and urging the SEC to adopt it.
According to HPC, the proposal, introduced by the SEC in August 2026, would allow startup projects to raise as much as $5 million through token offerings over four years. It would also allow projects to raise up to $75 million through an exempt financing route within 12 months. The proposal would also establish a new safe harbor to determine when a token is no longer tied to an investment contract.
Five revisions proposed by HPC
In its comment letter, HPC asked for five changes covering airdrops, secondary-market trading, on-chain protocol intermediaries, token buybacks, and federal preemption.
- Write the SEC’s March interpretation on airdrops into the final rule, making clear that steps such as connecting a wallet or passing sanctions screening to claim an airdrop do not amount to paying consideration.
- Directly clarify the legal status of secondary-market trading and intermediaries such as on-chain protocols, so tokens issued under an exemption can trade freely from the outset.
- Allow projects to certify directly that their tokens were never tied to an investment contract, so the safe harbor can be used without requiring a project to assume such a contract previously existed, and extend that protection to projects still under development.
- Incorporate SEC staff guidance on token buybacks into the final rule, unify the definition of a 「central party」, and distinguish between programmatic buybacks and discretionary buybacks.
- Keep federal preemption in place after a project meets the safe harbor conditions, so tokens do not face registration requirements across more than 50 jurisdictions.


