Peer statutes. One US offering paper.

Open a comment letter that says “align with international standards” and the staff already know you have not named a statute. The international standard is not one thing. MiCA is a Union market-in-crypto-assets regulation with a passport. The UK SI 2026/102 is an FSMA activity perimeter that generally prohibits public offers of qualifying cryptoassets and goes live on 25 October 2027. Germany’s eWpG put the security on a register. Bermuda licensed issuance as a business in 2018. The Bahamas rewrote DARE after FTX and is now writing a DAO Bill that puts a responsible person on the file. Cayman carved tokenised funds out of VASP in March 2026. El Salvador runs a CNAD public-offering statute next to a voluntary bitcoin legal-tender law. India taxes VDAs at 30% and has not written a market Act. Indonesia’s OJK licenses traders against a whitelist. China prohibits the business. South Africa licensed 310 CASPs under FAIS and still has no issuer circular. Hong Kong licensed platforms and specified stablecoins. Singapore split DPT payments from SFA capital-markets products. Japan split cryptoasset exchanges from electronic payment instruments. Korea wrote user-protection against VASPs and has not yet written an issuance act. Australia will fold digital-asset platforms into the Corporations Act on 9 April 2027 without regulating the token. Canada registered the platform as a dealer. VARA licensed issuance as an activity in one emirate. Switzerland put the security on a ledger. Liechtenstein wrote the token as a civil-law object. Gibraltar licensed DLT custody in 2018 and left ICOs outside. FATF wrote the Travel Rule. None of them wrote Rule 400.

The translation key

• Rule 100 CIC — almost unique. Peers classify the token (MiCA ART/EMT/other; DFSA Investment vs Crypto Token; FINMA payment/utility/asset; eWpG crypto security; Cayman fund token) or the activity (UK SI, VARA, DABA, DARE, PSA). The Howey wrapping is a US object.
• Rule 103 disclosure — MiCA Title II white paper is the closest prescribed disclosure. VARA, DAIA, DAIL and DARE issuance files sit next. Canada, Korea, India, South Africa and China do not have a live issuer-paper analogue. ASIC INFO 225 is characterisation, not a circular.
• Rule 200 $5M / 4 years — no peer. MAS SCS S$5M, Australia’s A$10M DAP line, and Bermuda Class T are different jobs. Do not cite them as startup exemptions.
• Rule 300 fundraising — Regulation A is the parent; MiCA Title II public offer is the cousin; El Salvador DAIL and Bermuda DAIA are licensed public issuance; the UK SI is the opposite (ordinary case: no public offer); China is a prohibition.
• Rule 400 safe harbor — empty set. DeFi perimeter debates (MiCA Art. 2, FCA 2026 DeFi consultation) and the Bahamas DAO Bill (a named responsible person) are not a Form TR deemed-cessation.
• Rule 500 preemption — MiCA passport is the commercial equivalent in a Union. The US needs NSMIA because it has states. Gulf centres, Caribbean licences and Gibraltar do not passport even across the road.
• CASP / platform / custody — the chapter RCA does not write. Every other serious jurisdiction on this map did, except India (tax/AML only) and China (ban).

What is live while this comment window is open

• In force now: MiCA (full, from 30 Dec 2024), eWpG, HK VATP + Cap. 656 (from 1 Aug 2025, first SO licences 10 Apr 2026), Japan PSA/EPI, Singapore PSA, Switzerland DLT Act, Liechtenstein TVTG, Korea VAUPA, Brazil 14.478, Canada CTP registration, VARA/FSRA/DFSA, DABA/DAIA, DARE 2024, Cayman VASP Phase 2, Gibraltar DLT, El Salvador DAIL, India VDA tax + FIU-IND, Indonesia OJK + Law 4/2026, South Africa FAIS CASPs, China Notice 42, FATF Rec. 15, US BSA/CFTC/NYDFS, UK promotions and MLR.
• Made but not fully commenced: UK SI 2026/102 (full commencement 25 Oct 2027; applications 30 Sep 2026–28 Feb 2027). Australia Digital Assets Framework (Royal Assent 8 Apr 2026; commence 9 Apr 2027).
• Forthcoming or in bill: Korea Digital Asset Basic Act (white paper / issuer entry); Bahamas DAO Bill 2026; Gibraltar PCC tokenised-fund-share bill; Cayman VASP Phase 3 public issuance. Not cites for a live disclosure duty.
• US proposed: this paper, comments 20 Oct 2026. Complementary US stablecoin legislation is a different statute and should stay a different statute.

The Rule 400 hole, in every language

No peer has a self-executing “the investment contract is deemed not to exist if essential managerial efforts are completed or permanently ceased and a form is filed.” MiCA argues about fully decentralised arrangements at the perimeter. The FCA will consult on DeFi guidance. The Bahamas would put a responsible person on a registered DAO. FINMA and BaFin characterise the token and then the token stays that thing. RCA is trying to do something no other commission has put in a rule text. That is either the paper’s contribution or its litigation engine. Comments should pick, with a peer cite, not a vibe.

• One peer, one ask. “Align with MiCA Art. 6 white-paper liability” is a comment. “Be like Europe” is not. “Be like El Salvador” without naming DAIL versus the Bitcoin Law is worse.
• If you would file in the Union, the UK, Hong Kong, Singapore, Bermuda or San Salvador instead of using RCA, say which door and at what size. That is the substitution exhibit for IV.B and the PRA.
• If you need a CASP chapter, say so and point at Title V / VATP / CESP / CTP / DAP / DABA / FAIS / OJK. Then concede it is not this file.
• If you need a stablecoin chapter, point at Cap. 656, MAS SCS, Japan EPI, MiCA III–IV, BMA SCPS. Then concede it is not this file.
• If you need a registered tokenised-security form, point at eWpG, the Swiss DLT Act, Cayman Act 4 of 2026. Then concede it is not this file.
• Open the jurisdiction pages from the matrix or the numbered tiles. Each one has the statute links, a Rule 100–500 map, and a desk note on what to file.