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Yuma, the DCG company focused on Bittensor, has submitted a comment letter supporting the SEC's proposed Regulation Crypto Assets while seeking rules for how token issuers sell and repurchase their tokens after an initial offering.
The company is asking for a new Subpart F to address activity in existing token markets. Its proposal centers on disclosures and objective standards that would give issuers a route to ongoing market sales and clarify how buyback programs affect a token's treatment under securities law.
The SEC's Regulation Crypto Assets proposal would create two registration exemptions: one allowing offerings of up to $5 million over four years and another allowing up to $75 million in each 12-month period. It also includes principles-based disclosures and a conditional safe harbor from the definition of an investment contract. Issuers would remain subject to antifraud and antimanipulation rules.
Yuma supports Subparts A through E substantially as proposed but argues that the framework leaves a gap once tokens begin trading and issuers continue developing and governing their networks.
Yuma wants an additional route for market sales rather than asking the SEC to remove Subpart C's prohibition on at-the-market offerings (sales into an existing trading market at prevailing prices). The route would serve issuers unable to use a Form S-3 shelf registration. Yuma argues that the proposed $5 million startup exemption, available only once per crypto asset, is poorly suited to recurring sales. Regulation D and Section 4(a)(2) produce restricted securities that do not fit an anonymous public order book, while Regulation S requires offshore transactions.
Yuma's buyback concern is whether an issuer's commitment to repurchase tokens could count as essential managerial efforts on which holders rely for profit. Under that interpretation, Yuma argues, a token could remain tied to an investment contract even when it changes hands between unrelated holders. The company wants disclosures that distinguish programmatic repurchases from discretionary management so issuers have clarity before committing revenue.
Its proposed Subpart F would be accompanied by amendments to Rules 500 and 175. Yuma says the approach draws on the SEC proposal's existing tools, including disclosure, tiering, issuer eligibility, limits on related-person sales, and notice of reliance.
Yuma's asset-management business reported fund holdings equal to 2.0% of Bittensor's subnet market capitalization at September's close. The letter does not take a position on how any particular crypto asset should be classified.
