With congressional efforts to enact comprehensive crypto legislation—including the CLARITY Act—stalled for the time being, the SEC has made its own rule proposal based on Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions Involving Crypto Assets, Release No. 33-11412 (Mar. 23, 2026), input from its Crypto Task Force, the President’s Working Group on Digital Asset Markets (Executive Order 14178) and Chairman Atkins’ “Project Crypto” Initiative. If adopted, the new rules known as “Regulation Crypto Assets” would establish an offering regime for certain investment contracts involving crypto assets (defined as “covered investment contracts”),…