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Six blockchain organizations filed a joint Oct. 20 letter asking the SEC to write its digital commodity definition into the proposed Regulation Crypto Assets rule text rather than leave it in interpretive guidance.
Facade of the U.S. Securities and Exchange Commission headquarters in Washington, D.C. Photo via Wikimedia Commons. Source
Six blockchain organizations filed a joint comment letter dated Oct. 20 asking the U.S. Securities and Exchange Commission to write its digital commodity classification into the operative text of the proposed Regulation Crypto Assets rule, rather than leave the definition only in interpretive guidance that can be revised more easily.
The co-signers are Chainlink Labs, the Cardano Foundation, Hedera, Aptos Labs, Ava Labs and the Stellar Development Foundation. The letter landed on the last day of the public comment period for the SEC's proposed crypto framework.
Cointelegraph, Crypto Briefing and Inside Crypto reported the filing on Oct. 21. Bitcoin Sistemi also covered the letter.
The groups argued that the SEC's existing interpretation already recognizes digital commodities as a distinct category from securities, but that the proposed rules do not explicitly reflect that distinction in binding text. Putting the definition in the operative text, rather than in preambles, footnotes, or staff guidance, would give developers and market participants longer-term regulatory certainty, the letter said.
Operative text is the part of a regulation that binds. Crypto Briefing noted that preambles, footnotes, and staff guidance can explain a rule but carry less legal weight, and can be revised, reinterpreted, or withdrawn with less process than amending a formal rule.
The filing also seeks clearer treatment of how securities laws apply to secondary-market transactions in digital assets, and of staking and related activities on decentralized networks. Those points matter for node operators, validators, and infrastructure providers planning compliance under proof-of-stake systems, according to Inside Crypto's summary of the letter.
Bitcoin Sistemi reported that the coalition also wants the SEC to state that a new rule will not silently rewrite existing token classifications or redraw the boundary between the SEC and the Commodity Futures Trading Commission.
Taylor Barr, head of policy at Chainlink, wrote on X that "builders need lasting certainty" and that codifying the framework would help keep the United States a home for digital asset innovation. Chainlink Labs and the other signers represent the teams behind LINK, ADA, HBAR, APT, AVAX and XLM.
ADA, XLM, HBAR, APT, AVAX and LINK were referenced in a footnote of the SEC's March 17, 2026 guidance, connecting them to futures regulated by the Commodity Futures Trading Commission. Crypto Briefing noted that footnotes in guidance documents do not carry the same legal weight as rule text, which helps explain why the issuers behind those tokens want a firmer footing.
The SEC and CFTC issued a joint interpretation in March 2026 that sorted crypto assets into five categories: digital commodities, digital collectibles, digital tools, stablecoins and digital securities, Inside Crypto reported. The proposed Regulation Crypto Assets rule attempts to translate that policy into a formal rulemaking.
The SEC proposed the rule in August. The proposal drew roughly 140 public comments over the 60-day window, Cointelegraph reported. Ripple filed its own separate 20-page comment letter on Oct. 20 supporting adoption of the proposal, according to crypto.news, with Chief Legal Officer Stuart Alderoty writing on X that "case by case, coin by coin" enforcement has pushed innovation offshore and that the industry needs holistic rules for digital assets.
The SEC has indicated it may continue accepting public comments after the formal period closes. Comment letters are requests, not outcomes; the commission is not obligated to adopt the coalition's language, and the final rule could differ from the proposal.
For ADA holders, the filing does not alter how the SEC treats the token right now. It does put the Cardano Foundation on record seeking stronger legal footing for the commodity framework than the March footnote offers.
The six-party letter was not the only industry submission on the final day. The Hyperliquid Policy Center and the Blockchain Association filed separate comments during the same period. The Blockchain Association urged the SEC to raise the startup exemption limit from $5 million to $10 million and the larger offering limit to $150 million, the group said in its Oct. 20 announcement.
Ripple's letter focused on refining existing classifications rather than challenging the broader structure of the proposal. crypto.news reported that the filing asks regulators to judge when investment contracts end by what an issuer expressly promised and whether those promises were fulfilled or withdrawn, not by a separate decentralization test.
The SEC is not required to respond to each comment individually before adopting a final rule. What happens next depends on whether the commission revises the proposed text to carry a binding digital commodity definition, leaves the classification only in guidance, or writes a different formulation that only partly matches what the six organizations asked for.