Form & Structure
In another episode of our recurring Policy & Regulatory Roundtable, Karen Ubell, Partner at Goodwin, joins Patrick Murck to discuss the SEC and CFTC's joint guidance on crypto assets and break down the framework. Karen warns its 'express promises' approach 'encourages no disclosures,' an unusual position for an agency 'founded on the basis of full and fair disclosure.' They also cover how the framework cites the 2017 SAFT (which she and Patrick both contributed to) as a valid mechanism a decade after the SEC was rumored to hate it, whether CLARITY actually crosses the finish line. Note: This episode was recorded before the Senate Banking voted to advance the CLARITY Act.
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