The comment period just closed. Coinbase didn’t say “we fully support this”—it went straight to changing the numbers.
On October 20, Coinbase submitted a comment letter to the SEC on Reg Crypto Assets (S7-2026-27): the proposal’s startup exemption of $5M over 4 years → Coinbase wants to raise it to $20M; Tier 1’s $20M per year → $120M, with no audited financial statements required; Tier 2’s current $75M cap → remove the ceiling entirely for offerings with audited financials. The appendix also runs the numbers: among roughly 962 token fundraises from 2012–2026, raising the startup exemption to $20M could reduce the share shut out from roughly 28% to about 6%.
A tougher line: $0 consideration, or tokens exchanged solely for network contributions (airdrops, testing, governance, ecosystem grants), shouldn’t count against fundraising limits or require a separate filing. On secondary transactions, they argue that if buyers don’t receive the rights in the investment contract, the transaction shouldn’t be treated as a securities transaction again—the framework’s success still hinges on “the Token itself is not a security.”
Note: This is a comment letter, not a finalized rule; the proposal is still proposed, and the comment period closed on October 20. In that same window, six public blockchains urged that “digital commodities” be written into the main text, while Ripple cast a supporting vote—those are separate developments.
This does not constitute investment advice.