In March, the SEC concluded that digital commodities, digital collectibles, and digital tools are not securities. In August, it proposed Regulation Crypto Assets, an offering rule that treats the investment contract question as the organizing problem for the entire asset class. I filed a comment letter addressing that gap yesterday. The argument is that the frame does not fit the subject. A crypto asset performs at least 9 distinct functions, and those functions implicate at least 14 regulatory regimes. Only 4 of the 9 touch the securities laws at all, and one of those only derivatively. The rest are tax, banking, money transmission, commodities, national security, privacy, consumer protection, and commercial law. The letter sets out that taxonomy function by function, and proposes three changes that follow from it: scoping the rule to the functions it actually reaches, classifying at the point of use rather than at issuance, and a treatment for tokens issued before a protocol operates. It also covers two regimes the proposal leaves unaddressed: (1) state securities regulation outside the exemptions and (2) state money transmission licensing, either of which can defeat the capital formation rationale the rule is built on. Documents can't be attached, so screenshot of first page only. Comments on File No. S7-2026-27 close on October 20.