[JumpCrisscross]

> Would a no action letter have been feasible

Probably not, given the integrated broker-exchange-custodian model. But that’s the point. We specifically outlawed that in 1934. Coinbase was counting on rules being changed in the midst of regulatory inertia.

[Dylan16807]

If it's clear enough for certain popular tokens then the SEC should have just declared them as securities years ago.