SEC clarifies: maintaining a live crypto network is not 'managerial efforts' under Howey

• —Maintaining a functional network does not constitute essential managerial efforts under Howey
• —A buyback of a non-security token on a functional network is not itself a promise of managerial efforts
• —Before functionality, marketing a buyback as a source of yield changes the analysis
• —Staking receipt tokens cannot add new economic rights or transfer the deposited asset to the issuer