What to do with the next 43 days

Who you are, and which pages you actually need

• Pre-product team, < $5 million needed, need to airdrop / incentivize / test: Rule 200. Read definitions, 103, 200, 400, 500. Comment on “substantially similar,” website hashing, and the airdrop/cap interaction.
• Public community round, $5–75 million, U.S. entity, can sit still for 20 days: Rule 300. Read 103, 300–307, forms, 500. Comment on the U.S.-issuer test, investment limits, the ATM ban, and Item 13.
• Offshore foundation with a live token and a 2024 SAFT book: Rule 400 plus Rule 500 seasoning. Read 103(b)(1), 400, 500. Comment on tacit admission and the Reg D → RCA secondary path.
• Exchange, ATS, broker-dealer, market-maker: 101(e) unitization, 300(c) ATM ban, 500 secondary, 12(g) preamble claim. You are a market-structure commenter. Do not write a Howey essay.
• State securities regulator: Rule 500, notice filings, the 1-UC carve-out, Tier 1 preemption. Merit-review philosophy is already in IV.D.5; add mechanics.
• Plaintiffs’ / defense bar: 101(d) deviations, 103(a) whitepaper consistency, 400 private-litigant non-bind, 104 lookback. These are litigation rules wearing offering-exemption clothes.
• Auditor / CFA: Tier 2 U.S. GAAP + S-X 2-01, Item 13 vs. MD&A, 1-KC/1-SC financial-condition. CAQ, Deloitte, EY, PwC already have a Task Force file — update it against the form appendices.

Pick an exemption before you comment on all of them

Rule 200 is cheap, public, unrestricted, retail, no financials, four-year fuse, one-time, website disclosure, $5 million including the airdrop residual. Rule 300 is a 20-day qualified public offering, both-tier reports, both-tier investment limits, U.S. issuer, no ATM, up to $75 million. Rule 400 is not an exemption; it is the off-ramp. Rule 500 is not an exemption; it is the blue-sky machine. Issuers who need more than $75 million, or who are selling a digital security rather than a CIC, are not in this paper. Project Crypto’s registered-offering workstream is the other line.

Highest-leverage RFCs, ranked

• RFC 35 — related-person lockup as a condition. The comment that can still change the exemption’s economics.
• RFC 82 — U.S.-issuer tests. The comment that determines whether the Cayman stack can use Rule 300 at all.
• RFC 134 — tacit admission on Form TR. The comment that determines whether Rule 400 clears the legacy docket.
• RFC 9 / 200 “substantially similar” — the comment that determines whether Rule 200 is one-time in reality.
• RFC 16 — list of significant deviations. The opinion-practice comment.
• RFC 90 — investment limits on both tiers. The community-round comment.
• RFC 101 — ATM / variable pricing. The market-structure comment.
• RFC 141 / 144 — 1-UC and TR edges of preemption. The secondary-liquidity comment.
• Holders of record under 305(c) — not numbered loudly, more important than most that are.
• 12(g) in the text, not only the preamble.

The file, the inbox, the paper

• Internet form: sec.gov/comments/s7-2026-27/regulation-crypto-assets. Use it.
• Email: rule-comments@sec.gov, subject line File Number S7-2026-27. One method only.
• Paper: Vanessa A. Countryman, Secretary, SEC, 100 F Street NE, Washington, DC 20549-1090.
• OMB PRA: MBX.OMB.OIRA.SEC_desk_officer@omb.eop.gov, copy the Secretary, inside 30 days of August 21 if you are attacking hours.
• Do not include personal identifiable information you do not want posted. The Commission will post the letter.

• Do not re-argue Howey. Do not re-file your February 2025 letter. Do not praise the Commission for six pages.
• Do name the exemption you would use, the size, and the date you would file. A signed intent is evidence of take-up; it moves IV.B and the PRA in the same stroke.
• Do send the OMB copy if you touch hours. Do not wait until October 19.
• Nothing on this desk is a legal opinion. Retain counsel. The 60-day clock is not a reason to skip that.