Crypto startups have 54 days left to shape the SEC’s proposed $75 million fundraising cap

A US Securities and Exchange Commission proposal to create two crypto fundraising exemptions had drawn 31 posted public comments as of Aug. 27, plus one separately labeled meeting memorandum.

With comments due Oct. 20, remaining commenters had 54 days to seek changes to the framework.

The proposed exemptions would let eligible crypto ventures raise up to $5 million in any four-year period under one path and up to $75 million in each 12-month period under another.

The posted comment file did not identify a major crypto exchange, large asset manager, large token issuer, or established investor advocacy group in its visible row labels.

Crypto commenters target the exemptions’ mechanics

The early letters test where the SEC sets boundaries around disclosure, investor protections, non-cash compensation, and the $75 million ceiling.

Ohanae Securities, an SEC- and FINRA-registered broker-dealer, asked the agency to clarify the $75 million exemption’s availability and proposed Rule 500 preemption. Its comment letter also proposed an EDGAR status hub, stronger Form TR disclosures, and good-faith protection for unaffiliated regulated intermediaries that rely on issuer representations.

ARKONIX focused on whether independent offerings should share the $75 million ceiling merely because they use the same infrastructure. It argued that separate partner vaults should not be aggregated, using an example in which 10 partners each raise $20 million rather than treating their provider as a $200 million issuer.

Other letters challenged the $5 million path. Beeezo asked the SEC to distinguish genuine commercial activity paid with predetermined, stable-value compensation from services furnished to an issuer for its own token when calculating non-cash consideration.

Tilden Moschetti opposed the startup exemption as proposed and sought entity eligibility, individual investment limits, scaled financial assurance, permanent EDGAR disclosure, four-business-day material updates, and tighter resale and insider safeguards.

The Digital Chamber’s docket presence argued that the SEC item is a memorandum recording an Aug. 19 meeting, rather than a public comment, and that it states no substantive positions. Separately, the Chamber says its Token Alliance submitted 13 responses covering all 48 questions in an earlier SEC request, with input from more than 75 members.

Those materials sit in a pre-proposal written-input archive, outside the S7-2026-27 comment tally.

Larger institutions may have engaged elsewhere, but the letters already posted show the concrete choices still open for debate. The Oct. 20 deadline leaves a shrinking window to add more positions to the formal rulemaking record.