Thoughts on the SEC’s Initial Coin Offering Bulletin and Investigative Report

  1. Is the seller primarily raising money and the buyer primarily interested in profit?
  2. Will there be common trading for speculation or investment of the instrument?
  3. What are the expectations of the public?
  4. Does other regulation exists to reduce the risk of the instrument?
  1. All ICOs are not created equal. The DAO being a security issuance does not make every ICO a security.
  2. There are tests to consider when determining whether or not something is a security.
  3. We need to be careful which ICOs are labeled securities, because if we overreach, other things might be considered securities that were not before.
  4. Take a thoughtful approach to doing ICOs in the US. Work with experienced professionals.

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Co-founder of @EverbloomHQ, VC at Sigma Prime Ventures, Co-founder of @Localytics, Software Engineer, @andrew311, http://www.andrewrollins.com

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Andrew Rollins

Andrew Rollins

Co-founder of @EverbloomHQ, VC at Sigma Prime Ventures, Co-founder of @Localytics, Software Engineer, @andrew311, http://www.andrewrollins.com

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