"It is the investment contract, not the crypto asset itself, that is the security," Ripple wrote in an October 20 comment letter on the Securities and Exchange Commission's proposed Regulation Crypto Assets framework, signed by Chief Legal Officer Stuart Alderoty and other company attorneys, per Bitcoin.com News. The proposal would exempt certain crypto fundraising from registration, up to $5 million over four years or $75 million a year, while keeping issuer disclosure and antifraud rules in place. Ripple supports it and argues that binding rules beat enforcement cases and guidance, and that existing law already gives the SEC authority to act even with the CLARITY Act stalled. Its asks are specific. It wants a safe harbor once promised managerial work is finished, abandoned or ended, provided issuers make no new promises, and good-faith protection for Form TR filers, with later SEC determinations applied only going forward. It warns that leaving dealers out of relief from state registration could limit access, widen spreads and push trading offshore, and wants ordinary broker-dealer activity covered. Ripple also asks the SEC to confirm that holding, lending, pledging, collateralizing or staking a token does not on its own trigger registration, and it opposes income or wealth tests for buyers in resale markets.