Hedera Urges SEC to Codify Asset Types in Rule 400

• —Hedera wants Rule 400 to draw explicit boundaries between digital commodities and other asset classes
• —Rule 200 offers a $5M startup exemption, Rule 300 covers $20M–$75M raises, Rule 400 is a Form TR safe harbor
• —Developers criticize the $5M four-year cap, which counts grants, airdrops and liquidity incentives
• —Opponents argue the SEC lacks statutory authority under Section 2(a)(1) to terminate investment-contract status