Crypto Startups Have 54 Days to Influence SEC’s $75M Fundraising Cap Proposal

A proposal by the US Securities and Exchange Commission to establish two crypto fundraising exemptions had received 31 posted public comments as of August 27, along with one separately labeled meeting memorandum.

With the comment period closing on October 20, prospective commenters had 54 days remaining to advocate for changes to the framework.

The proposed exemptions would enable eligible crypto ventures to raise up to $5 million within any four-year period under one pathway and up to $75 million in each 12-month period under the other.

The posted comment file did not identify a major crypto exchange, large asset manager, significant token issuer, or established investor advocacy group in its visible row labels.

Crypto Commenters Target the Exemptions’ Mechanics

The early letters explore where the SEC establishes boundaries regarding disclosure, investor protections, non-cash compensation, and the $75 million ceiling.

Ohanae Securities, an SEC- and FINRA-registered broker-dealer, requested the agency clarify the $75 million exemption’s availability and proposed Rule 500 preemption. Its comment letter also proposed an EDGAR status hub, stronger Form TR disclosures, and good-faith protection for unaffiliated regulated intermediaries that rely on issuer representations.

ARKONIX examined whether independent offerings should share the $75 million ceiling simply because they utilize the same infrastructure. The firm argued that separate partner vaults should not be aggregated, citing an example in which 10 partners each raise $20 million rather than treating their provider as a $200 million issuer.

Other letters challenged the $5 million path. Beeezo asked the SEC to distinguish genuine commercial activity paid with predetermined, stable-value compensation from services furnished to an issuer for its own token when calculating non-cash consideration.

Tilden Moschetti opposed the startup exemption as proposed and advocated for entity eligibility, individual investment limits, scaled financial assurance, permanent EDGAR disclosure, four-business-day material updates, and tighter resale and insider safeguards.

The Digital Chamber’s docket presence argued that the SEC item represents a memorandum recording an August 19 meeting rather than a public comment, and that it states no substantive positions. Separately, the Chamber indicates that its Token Alliance submitted 13 responses covering all 48 questions in an earlier SEC request, with input from more than 75 members.

Those materials reside in a pre-proposal written-input archive, outside the S7-2026-27 comment tally.

Larger institutions may have engaged elsewhere, but the letters already posted reveal the concrete choices still open for debate. The October 20 deadline leaves a narrowing window to add additional positions to the formal rulemaking record.

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