WASHINGTON – Blaine Luetkemeyer, CEO of the American Consumer and Investor Institute (ACII), today filed a comment letter with the U.S. Securities and Exchange Commission (SEC) applauding President Trump’s swift action to restore U.S. leadership on digital asset innovation and providing recommendations to further advance an America First crypto agenda.
“The technology underlying crypto markets has the potential to revolutionize our financial system by making markets faster, more efficient, lower cost, and available 24/7 worldwide,” wrote Luetkemeyer. “With proper regulatory clarity, the United States can lead the global digital asset revolution while ensuring appropriate consumer and investor protections.”
The letter outlines specific recommendations in four critical areas to advance U.S. digital asset innovation:
- Tokenization: ACII recommends expanding support for blockchain-based clearance and settlement systems, eliminating duplicate registration requirements for tokens representing already-registered securities, allowing trading platforms to list both tokenized securities and non-securities side-by-side, and supporting diverse digital asset custody models.
- Token Status and Listing: ACII recommends implementing a temporary safe harbor, if necessary, allowing responsible market participants to issue and list tokens they believe in good faith are not securities while the SEC engages in rulemaking and works with Congress to provide long-term clarity on which digital assets are securities.
- Staking : ACII recommends developing a dual-track approach for securities-based staking and compliant alternatives, issuing clear guidance distinguishing between different types of staking arrangements, establishing specialized registration pathways, and providing standardized disclosure requirements.
- Custody: ACII recommends abandoning the limited Special Purpose Broker-Dealer framework in favor of broader, inclusive guidance, building on the recent rescission of SAB 121, and allowing flexibility in custody arrangements while maintaining strong asset protection standards.