#SECGuidance

firms need to adapt to

For example, we’ve seen a few crypto projects where the description appears overly technical. The SEC says the business description must be “presented in clear, concise, and understandable language, without overly relying on technical terminology or jargon.”

Some crypto projects have pseudonymous founders. The problem is someone who is extremely dodgy and has been convicted of crimes will embrace the opportunity to take on a pseudonymous persona. While the guidance doesn’t mention pseudonymous founders, it clarifies that officers have to be identified, including those that may not have formal roles but “perform policy-making functions”.