The President’s Working Group report, “Strengthening American Leadership in Digital Financial Technology,” is a roadmap for the next three years to fill in the gaps in areas Congress has yet to begin legislating. This will guide regulators and agencies to begin rulemaking and reviewing existing guidance, so that the United States is positioned to lead globally in crypto. We appreciate the Task Force’s efforts, led by Bo Hines, that adopted critical TDC recommendations such as:

1. Directing the SEC to consider using its rulemaking and exemptive authority under the Securities Act to establish a fit-for-purpose exemption from registration for token issuances. 
2. Establishing that the CFTC should have clear authority to regulate spot markets in non-security digital assets. 
3. Ensuring issuers of digital asset securities, and of securities involving digital assets, should be subject to disclosure requirements that are appropriately tailored to address the novel characteristics of digital assets and blockchain technology. 
4. Supporting clear guidance from relevant agencies allowing Americans to custody their own digital assets without relying on intermediaries.  
5. Clarifying that developers and non-custodial blockchain infrastructure providers are not financial institutions. 
6. Directing agencies to identify, secure and gain access to digital asset keys in seized electronic evidence — bolstering the U.S. government’s digital asset stockpile and providing a strategic advantage as other jurisdictions build their own reserves. 
7. Encouraging federal digital identity guidelines to adopt privacy-enhancing cryptographic technologies like zero-knowledge proofs (ZKPs). 
8. Calling for clear legal protections for decentralized finance (DeFi) protocols that operate autonomously without holding user funds—ensuring DeFi can flourish onshore. 
9. Directing regulators and agencies to collaborate with industry experts to encourage globally consistent regulatory standards that leaves room for innovation, ensuring American interests and companies aren’t burdened by overregulation in the U.S. or abroad. 
10. Advocating that NIST integrate blockchain’s unique benefits into emerging government technology standards to strengthen federal digital infrastructure. 

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