TL;DR
- Ripple supports the SEC’s Regulation Crypto Assets and wants it finalized as a replacement for case-by-case enforcement, which Stuart Alderoty says created uncertainty.
- The company argues that investment contracts, not tokens themselves, should determine securities status, while Rule 400 should cover managerial work that is completed or abandoned.
- Ripple says its $150 million battle illustrates the cost of ambiguity and wants clearer rules for issuers, exchanges, brokers and market participants.
Ripple has formally backed the U.S. Securities and Exchange Commission’s proposed Regulation Crypto Assets, urging the agency to finalize a framework that would replace years of case-by-case enforcement with clearer standards. In an X statement, Chief Legal Officer Stuart Alderoty said the SEC has authority to adopt the proposal. Ripple argues that predictable rules should replace “case by case, coin by coin” enforcement, adding a regulatory dimension to Ripple’s broader institutional positioning. Alderoty said clearer rules could support capital formation, investor protection and innovation under existing securities law.
1/ Today Ripple filed its comment letter on the SEC’s proposed Regulation Crypto Assets. We support the proposal, and the SEC has clear authority to adopt it.
2/ Years of “case by case, coin by coin” enforcement has pushed innovation offshore. We need holistic rules for digital…— Stuart Alderoty (@s_alderoty) October 20, 2026
Ripple Pushes for Clearer Limits on Securities Status
A central element of Ripple’s position is that an investment contract can be a security without making the underlying token itself a security. Alderoty said this approach remains faithful to the Howey test, which focuses on the arrangement between issuer and buyer. Ripple wants regulators to examine what an issuer actually promised and when those obligations end, rather than relying on a subjective decentralization standard, an issue that has also shaped recent SEC and Ripple regulatory debates.
Ripple also supports proposed Rule 400, a safe harbor that would allow issuers to file Form TR after promised managerial work has been completed or abandoned. The company opposes limiting that protection only to issuers that fulfilled every promise, arguing that abandoned work can also eliminate expectations of profit from continuing managerial efforts. It additionally wants failure to file Form TR to create no presumption that a token remains tied to an investment contract.
The filing also challenges classifications separating “company-backed” tokens from “network” tokens and seeks changes to Rule 500(b), which addresses secondary-market transactions. Ripple wants the framework to reduce uncertainty for exchanges, brokers and other market participants without weakening existing investor protections. The issue is especially relevant as regulated blockchain markets expand, including discussions around SEC-regulated tokenized securities and XRP Ledger infrastructure.
Ripple grounded its argument in its own litigation history with the SEC. Alderoty said the company spent more than $150 million obtaining legal clarity, while the 2020 lawsuit was followed by a roughly 70% XRP decline and widespread U.S. exchange restrictions. Ripple now presents the proposed framework as a way to establish rules before companies face years of litigation. The broader question remains whether the SEC will adopt Ripple’s requested changes, as regulatory clarity continues influencing how XRP-related disclosures are interpreted.
