SEC staff revised a September 25 FAQ answer on token buyback programs to make the absence of centralized control an explicit condition for the guidance to apply, not merely an implied functional characteristic. The original answer addressed only a system's technical functionality; the revised language requires that no central party be capable of directing buyback activity. The change was made quietly, without a formal notice-and-comment process.
For Armada's crypto repo desk, this matters because HYPE and SOL are accepted collateral assets whose governance and protocol upgrade mechanisms involve identifiable central actors to varying degrees. If the SEC's revised framework is applied broadly, it could support a securities classification argument for tokens that fail the no-central-party test. Legal counsel should review the governance documentation for each non-BTC collateral asset against the revised SEC standard and flag any that present elevated classification risk.