Coin Center has formally urged the U.S. Securities and Exchange Commission to move away from case-by-case no-action relief and toward full notice-and-comment rulemaking for crypto oversight. The group’s central argument is that bespoke no-action letters create an uneven regulatory environment instead of a stable framework that applies equally across the market.
In a letter dated March 5, 2026 and addressed to the SEC’s Crypto Task Force and Chairman Paul S. Atkins, the Washington-based advocacy group said the current approach effectively rewards projects with the resources to secure individualized guidance. Coin Center argued that selective relief distorts competition by favoring well-funded actors over decentralized networks that lack a corporate sponsor capable of petitioning regulators.
In a letter to the SEC, Coin Center suggests the agency:
1) Prioritize rulemaking over case by case no-action letters
2) Consider whether open blockchains obviate the need for transfer agents altogether (and to resist rent seeking state-mandated intermediation) pic.twitter.com/a4OWl2kaLO
— Neeraj K. Agrawal (@NeerajKA) March 17, 2026
Coin Center Wants Formal Rules Instead of Selective Relief
The group described no-action letters as a form of “implicit merit regulation,” warning that they can produce de facto advantages for projects able to bear legal and lobbying costs. In Coin Center’s view, that dynamic increases concentration risk and pushes the market toward structures built for regulatory access rather than genuine decentralization.
To address that problem, Coin Center called for a formal safe-harbor framework developed through public notice and comment. The organization said a transparent rulemaking process would create more predictable and durable standards for compliance, fundraising, and product design across the digital-asset sector.
The letter also pushed for a more modern approach to recordkeeping in tokenized markets. Coin Center argued that issuers should be allowed to use blockchain-based ownership records directly instead of being forced to recreate traditional intermediary structures such as transfer agents.
The Debate Is Expanding Beyond No-Action Letters
That recommendation reflects a broader theory about how tokenized instruments should function. Coin Center’s position is that compliance conditions can be embedded directly into tokens and enforced programmatically, allowing issuers to assume recordkeeping responsibilities without defaulting to legacy middlemen.
The timing of the letter has added to its relevance. Coin Center’s proposal landed just as the SEC issued a March 17, 2026 interpretation explaining how federal securities laws apply to crypto assets, and days after the SEC and CFTC signed a March 12, 2026 memorandum aimed at improving inter-agency coordination.
A move toward formal, universal rulemaking could reduce legal uncertainty, lower compliance costs for projects that cannot secure bespoke relief, and narrow the regulatory advantages currently enjoyed by better-funded petitioners.
More broadly, Coin Center is framing the issue as one of governance as much as regulation. Its argument is that a notice-and-comment process would reduce the risk of regulatory gatekeeping that leaves decentralized protocols excluded from market access simply because they lack a formal entity to ask for permission.
