DRC's SEC comment letters, explained: Who decides when a network is decentralized?

The SEC's proposed Regulation Crypto Assets, published Aug. 21, 2026, sets out how crypto projects can raise money and when an issuer's investment contract ends. DRC filed two comment letters on the

The SEC's proposed Regulation Crypto Assets, published Aug. 21, 2026, sets out how crypto projects can raise money and when an issuer's investment contract ends. DRC filed two comment letters on the proposal this month, calling the proposed exemptions and safe harbor meaningful progress and asking the SEC to add a bright-line safe harbor for when essential managerial efforts have ceased, built on an objective, control-based test. Who decides when a network is decentralized, and by what measure,