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File S7-2026-27/Issue 0042/Window closed

3. Pre-2025/pp. 10–12

The DAO Report decade

From the 2013 Bitcoin ETP S-1 through the 2017 DAO Report and a string of ICO settled actions, the Commission applied Howey case-by-case. Commissioners Peirce and Uyeda called it regulation by enforcement. The petitions sat.

I.A.1 Approach Before 2025

First crypto ETP S-1

1 Jul 2013

DAO Report

25 Jul 2017

Release

34-81207

Analysis

What the text does

Staff engaged with crypto as early as 2013 — the first registration statement for a crypto-asset exchange-traded product was filed on July 1, 2013. The first Commission-level analytical framework arrived in 2017, as ICO volume spiked. The vehicle was not a rule. It was a section 21(a) report of investigation into The DAO.

The DAO Report (Release 34-81207, July 25, 2017) found that DAO Tokens were offered and sold as investment contracts under Howey. That finding became the template. Subsequent settled actions — Munchee (Dec. 2017), Paragon Coin (Nov. 2018), Gladius (Feb. 2019) — and a handful of no-action letters (TurnKey Jet, Pocketful of Quarters, IMVU) were the entire “framework.” There was no form, no exemption, and no off-ramp.

Why not set forth a coherent legal framework in a rule? After all, if we continued with our regulation-by-enforcement approach at our current pace, we would approach 400 years before we got through the tokens that are allegedly securities.
— Commissioner Hester M. Peirce, Outdated, Jan. 20, 2023

The Commission now quotes that critique in the proposing release. That is not a small thing. A proposing release that reprints a sitting commissioner’s attack on the prior decade is the Commission telling commenters which political argument has already been accepted. Re-arguing “regulation by enforcement” in 2026 is fighting a war the paper says it has already conceded.

RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.