GUARDD Submits Exemptive Framework Proposal to SEC Crypto Task Force

GUARDD submitted a written proposal to the SEC Crypto Task Force urging the Commission to use its exemptive authority under Section 36 of the Exchange Act to formally recognize "Qualified Disclosure Publishers" (QDPs), enabling compliant secondary trading of exempt and tokenized securities without requiring full Exchange Act reporting.

Key recommendations in the proposal include:

• GUARDD urges the SEC to use its exemptive authority under Section 36 of the Exchange Act to formally recognize "Qualified Disclosure Publishers" (QDPs), enabling compliant secondary trading of exempt and tokenized securities without requiring full Exchange Act reporting.

• The proposal includes a request for federal preemption of inconsistent state Manual Exemption provisions, aiming to streamline secondary trading across jurisdictions while preserving states' anti-fraud enforcement powers.

• GUARDD recommends that QDPs be required to publish token-specific data (e.g., contract address, blockchain network, transfer restrictions, audit status) alongside Rule 15c2-11(b) disclosures to support on-chain secondary trading on regulated venues.

This submission represents GUARDD's continued engagement with regulators to shape policy that enables innovation while protecting investors in the evolving digital securities landscape.