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I’m Your Huckleberry - SEC Staff Statement on WY Division of Banking’s Letter on Custody of Digital Assets

Earlier this month the staff of the U.S. Securities and Exchange Commission (SEC) published a statement in response to a letter issued by the Wyoming Division of Banking on the custody of digital assets.  The SEC staff...more

Revenge of the Rat Pack; SEC Proposes Finders Exemption

The U.S. Securities and Exchange Commission (the “SEC”) recently proposed a new, conditional exemption from registration as a broker for individuals who are “finders” that connect accredited investors with issuers looking to...more

Time to Do the Foxtrot (Three Step) SEC Establishes Improved Process for Settlement of Digital Asset Securities

The U.S. Securities and Exchange Commission (“SEC”) Division of Trading and Markets recently issued a no action letter to FINRA that may help to streamline the settlement of digital asset securities transactions by...more

Court Provides Additional Guidance On When Notes Are Not Securities - The Kirschner Case

The loan market breathed an immense sigh of relief this spring with the ruling in Kirschner v. JPMorgan Chase Bank, N.A. 1 (“Kirschner”) affirming the prevailing market view that notes representing syndicated loans are not...more

Court Provides Additional Guidance On When Notes Are Not Securities

The loan market breathed an immense sigh of relief this spring with the ruling in Kirschner v. JPMorgan Chase Bank, N.A. (“Kirschner”) affirming the prevailing market view that notes representing syndicated loans are not...more

Peircing the Decentralized Autonomous Organization Veil

U.S. Securities and Exchange (SEC) Commissioner Hester Peirce, referred to by some as “crypto mom” for her support for blockchain technology and cryptocurrency, was nominated on June 3, to serve a five-year term. Peirce is...more

It’s the Fall That’s Gonna Kill You

Like Butch Cassidy and the Sundance Kid gloriously diving off a cliff, Telegram is about to take the fall and is trying to take the SEC with it.  However, Telegram and supporters are making a number of important arguments in...more

BitBlog Bi-Weekly Update - February 2020

Many crypto entrepreneurs are seeking to build decentralized networks in which a token serves as a means of exchange on, or provides access to a function of the network.  In the course of building out the network, they need...more

BitBlog Weekly Update

This BitBlog summary focuses on the continuing actions by the U.S. Securities and Exchange Commission (“SEC”) against the issuers of noncompliant initial coin offerings (“ICOs”) and other crypto related transactions including...more

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