WASHINGTON, D.C. – October 26, 2026 – (KOREWIRE) – The Crowdfunding Professional Association (CfPA) announced that its October 20, 2026 comment letter on the U.S. Securities and Exchange Commission’s proposed Regulation Crypto Assets (Regulation CA), File No. S7-2026-27, is publicly available on the SEC website.

The letter supports a tailored framework for crypto assets while recommending changes to strengthen investor protections and promote consistency across exempt securities offering pathways.

Central to CfPA’s recommendations is Presumptive Parity, a regulatory principle the association adopted in September 2026. Comparable capital-raising activities should carry comparable regulatory requirements and benefits, regardless of asset type, unless meaningful differences justify different treatment.

“We want crypto projects to have a workable path to raise capital here in the U.S.,” said Brian Belley, President of the CfPA. “As the SEC develops Regulation CA, it should look at how all the exemptions fit together. This is an opportunity to support innovation and build on what’s working across these markets, so we move toward a coherent framework instead of adding to a patchwork of exemptions.”

Strengthening investor protections for startup crypto offerings

The proposed Startup Exemption would allow eligible issuers to raise up to $5 million over no more than four years through covered investment contracts involving crypto assets, without many of the safeguards required under Regulation Crowdfunding (Reg CF).

CfPA recommends investment limits for non-accredited investors, proportionate independent third-party oversight for cash contributions, scaled financial disclosures, and a minimum 12-month holding period for related persons with additional sales limits. Non-cash distributions, such as airdrops and protocol rewards, would remain intermediary-free under CfPA’s recommendation.

The association also recommends filing disclosure amendments on EDGAR and requiring a U.S. entity attached to the capital raise to support regulatory accountability and investor claims.

Applying Presumptive Parity across exempt offerings

The proposed Regulation CA Fundraising Exemption would permit qualifying issuers to raise up to $20 million in a 12-month period under Tier 1. Reg CF remains capped at $5 million in a 12-month period, despite its mandatory registered intermediary, investment limits, financial disclosures and resale restrictions.

CfPA reiterates its recommendation to increase the Reg CF offering limit to $20 million and asks the Commission to explain differences in financial reporting, communications and other requirements where comparable offerings receive different treatment.

For Tier 1 crypto fundraising offerings, CfPA recommends financial statements reviewed by an independent public accountant at a minimum. It supports the proposed audited financial statements for Tier 2 offerings.

Clarifying safe harbors, state preemption and legal authority

CfPA recommends limiting proposed Rule 400’s safe harbor to projects that fulfill their promised managerial efforts. Abandoned projects should be addressed separately, with notice on EDGAR and disclosure of proceeds raised, use of funds, remaining treasury, related-person holdings and secondary sales.

CfPA supports preemption of state securities registration and qualification requirements when adequate investor protections accompany it. For Startup Exemption offerings, the letter recommends conditioning preemption on added protections; without them, preemption should be limited to the Fundraising Exemption.

The letter also asks the SEC to identify the statutory authority for Rules 200, 400 and 500 and explain how each stays within that authority. If express delegated authority for Rule 400 is absent, CfPA recommends presenting it as the Commission’s enforcement position. Where authority is lacking, the letter recommends considering deferral of affected components, including at least Rule 400 and secondary-market preemption, until Congress acts.

Read CfPA’s full October 20, 2026 comment letter on the SEC website.

About the Crowdfunding Professional Association

The Crowdfunding Professional Association (CfPA) is a 501(c)(6) nonprofit trade association dedicated to fostering the growth of the regulated investment crowdfunding economy. CfPA supports issuers, investors, regulated intermediaries, and crowdfunding professionals through education, advocacy, industry engagement, and policy work. CfPA advocates for responsible growth of regulated investment crowdfunding, including Regulation Crowdfunding, Regulation A, intrastate crowdfunding, and related frameworks that expand access to private-market investment opportunities under established regulatory structures.

Learn more at CfPA.org and CrowdfundingEcosystem.com, or join CfPA.

Media Contact

Jason Fishman

Vice President | Chair, Growth Committee

Crowdfunding Professional Association, Inc.

Email: press@cfpa.org

Website: CfPA.org

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