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ARTICLE · 22 JULY 2025

New Frontiers, Old Rules: SEC Staff Outlines Disclosure Expectations For Crypto Asset ETPs

Gesmer Updegrove LLP
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On July 1, 2025, the SEC's Division of Corporation Finance issued a comprehensive staff statement clarifying its views on disclosure obligations under the federal securities laws...

United StatesTechnology
Braeden Anderson
Braeden Anderson

On July 1, 2025, the SEC's Division of Corporation Finance issued a comprehensive staff statement clarifying its views on disclosure obligations under the federal securities laws for issuers of crypto asset exchange-traded products (ETPs). While the products themselves represent novel financial structures—trust-based vehicles holding spot crypto or derivatives—the statement emphasizes continuity in legal obligations: crypto ETP issuers must adhere to well-established disclosure requirements under the Securities Act of 1933 and the Securities Exchange Act of 1934.

This release signals the Commission's evolving comfort with crypto asset vehicles while reinforcing investor protection as a non-negotiable pillar of U.S. securities regulation. Below, we break down the key takeaways.

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