miles jennings
@milesjennings
@a16zcrypto | Prev Partner @Lathamwatkins | Write about crypto policy, decentralization, tokens & more -
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Not the only way, but the easiest and simplest way. Projects should embrace simplicity.
Not sure about “delivering onchain value” via tokens that don’t constitute network tokens. The network token definition stipulates that if a token provides onchain value, it’s a network token. If a token provides offchain value, it’s not a network token and likely remains subject to securities laws.
The bill doesn’t really address anything other than network tokens and NFTs, unless you’re referring to tokenized securities in 505.
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People are overthinking it. It’s as straightforward as possible.
Step 1. Use an ordinary C-corp startup to raise private capital to develop a “distributed ledger system”.
Step 2. Use the same C-Corp to raise capital by selling network tokens to the general public and filing contemporaneous disclosures.
Step 3. Launch the token and commencement of “gratuitous distributions” (including airdrops if desirable).
Step 4. Comply with ancillary asset regulatory regime.
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