Blockchain technology has captured the imagination of the financial services industry. Unfortunately, the adoption of the technology is impaired by a lack of clarity from regulators including the U.S. Securities and Exchange Commission (“SEC”) as to how the technology will be regulated. Many firms in the financial services industry believe blockchain technology can be adapted for use in traditional financial services transactions in a way that can reshape the industry. Unfortunately, the success of blockchain technology will be impacted in large part by how the SEC elects to regulate platforms that use the technology. The devil will be in the details.