> For the complete documentation index, see [llms.txt](https://dataipo.gitbook.io/dataipo-docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://dataipo.gitbook.io/dataipo-docs/whitepaper-center/simplechain-whitepaper/appendix-d-regulation-crypto-assets.md).

# Appendix D — Regulation Crypto Assets

This appendix restates the exemptions, forms, and deadlines in the U.S. SEC's Regulation Crypto Assets proposed rule (Release Nos. 33-11434, 34-106150; File No. S7-2026-27) that bear on protocol objects. The rule is at the Proposed rule stage and not yet effective; formal filing calendars, legal opinions, and effective obligations rest with the responsible parties under whatever rules apply at the time.

## D.0 Rule 103 disclosure discipline

Proposed Rule 103 takes a principles-based narrative disclosure approach for covered investment contracts. SimpleChain and AICOS maintain source and version consistency between disclosed facts, websites, social media, and promotional materials: disclosed facts reference EvidenceEnvelopes, separating formal facts, model inference, management statements, and third-party materials; disclosure versions bind their applicable time, approver, formal channel, and supersession; cross-channel consistency checks output differences and owners; material events trigger review, amendment, notice, or reporting tasks through LifecycleEvents; all external disclosure and promotion reuse one approved fact base.

## D.1 Startup Exemption: proposed Rule 200

The proposed Startup Exemption allows raising up to $5,000,000 within a four-year period, with public disclosure, a Form NOR filing, Rule 103 compliance, and a Form TR filing after specified events or deadlines. Eligibility, computation, timing, documents, and limits follow the final rule status and professional legal advice.

SimpleChain can store the financing path choice, Rule 103 disclosure versions, and the preparation, approval, submission status, and formal receipts of Form NOR and Form TR; AICOS can organize materials, difference checks, and task reminders. The formal filer submits through EDGAR, counsel and responsible institutions make the legal judgments, and the SEC's formal receipt decides acceptance. The system updates compliance status only after receiving verifiable external receipts.

## D.2 Fundraising Exemption: proposed Rules 300–307

The proposed Fundraising Exemption has two tiers: Tier 1 up to $20,000,000 per twelve months, Tier 2 up to $75,000,000 per twelve months. The proposal requires Form 1-CRYPTO and continuous reporting; Tier 2 involves audited financial statements. Material events and annual, semi-annual, and current reporting obligations follow the formal rules and forms.

The protocol can express fundraising windows, participant eligibility, disclosure, audit materials, reporting calendars, material events, and submission receipts as PolicyProfiles and LifecycleEvents. Amount computation, offering integration, exemption eligibility, and state-law preemption rest with counsel and responsible institutions. Automated reminders must survive rule changes and human review.

## D.2.1 Proposed filing objects and reporting deadlines

The table restates form purposes and proposed deadlines from the SEC proposal, to define the evidence, event, and status objects the protocol should support. Formal filing calendars, legal opinions, and effective obligations rest with the responsible parties under the rules effective at the time, who also review the covered filers, starting points, suspension and termination conditions, duplicate-reporting exceptions, and final deadlines.

| Proposed form | Covers                                                                                               | Proposed deadline / status                                                                                                                            | SimpleChain / AICOS support                                                                                      |
| ------------- | ---------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------- |
| Form 1-CRYPTO | The offering statement of the Fundraising Exemption: notice, offering circular, financials, exhibits | Submission, amendment, and qualification per proposed Rules 301 and 306; exact milestones follow the final rule                                       | Binds material sources, versions, approvals, signatures, eligibility status, formal receipts                     |
| Form 1-KC     | Annual report, including special financial reports in specified cases                                | Annual report proposed within 120 calendar days after the covered fiscal year; other starting points apply separately                                 | Maintains reporting periods, financial and non-financial evidence references, approval chains, submission status |
| Form 1-SC     | Semi-annual report, usually the first six months of each fiscal year                                 | Proposed within 90 calendar days after the covered semi-annual period                                                                                 | Locks reporting periods, source versions, difference checks, owners, formal receipts                             |
| Form 1-UC     | Current reports of listed material events                                                            | Unless otherwise specified, proposed within 4 business days of the event; substantially identical prior reporting may remove the duplicate obligation | LifecycleEvent triggers tasks, linking fact materials, human approvals, submission and acceptance receipts       |
| Form TR       | Transition reports under the Startup Exemption or the Investment Contract Safe Harbor                | Triggered by the events, deadlines, and conditions the relevant proposed rules list                                                                   | Stores eligibility basis, certifications, analysis, approvals, submission status, immutable receipt references   |

AICOS can generate tasks, assemble materials, and flag gaps. Form applicability rests with counsel and the filer, EDGAR submission with the formal filer, and acceptance with the SEC's formal receipt. SimpleChain updates filing\_status only on verifiable external receipts and keeps the evidence differences among prepared, approved, submitted, accepted, amended, and withdrawn.

## D.3 Investment Contract Safe Harbor: proposed Rule 400

The proposed safe harbor is a conditional legal path. The passage of time alone does not move a token out of an investment contract. The proposal turns on whether essential managerial efforts are complete or permanently ceased, whether new undertakings exist, and conditions such as Form TR. Applicability depends on the facts, management activity, undertakings, governance, and continuing relations.

SimpleChain can store managerial-effort milestones, responsible-party attestations, public communications, changes of undertakings, governance events, and Form TR status to support evaluation by counsel and responsible institutions. Safe-harbor conclusions rest with professional responsible parties under the final effective rules, and the protocol keeps the version differences between the proposed text and the final rules.


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