The SEC released a formal proposed rulemaking titled Regulation Crypto Assets, aimed at creating a bespoke regulatory framework for crypto assets structured as investment contracts. The proposal does not treat all crypto assets as securities per se but establishes a fit-for-purpose registration and disclosure regime for those that qualify, with a comment period expected to follow. This is the most substantive SEC crypto rulemaking since the 2024 SAB 121 reversal cycle.
For Armada's crypto repo desk, the proposal directly threatens the unencumbered collateral status of assets like SOL and HYPE, which sit closer to the investment-contract boundary than BTC or ETH. If any collateral is reclassified under the new framework, Armada's eligibility policy and client agreements would need revision. Legal counsel should review the proposal against current collateral schedules immediately.