GSR has submitted a comment letter to the SEC in response to its recent interpretive release on the application of the federal securities laws to certain crypto assets and secondary-market transactions. Our request is straightforward: the SEC should adopt a formal safe harbor for principal OTC trading and market-making firms. As the guidance stands today, it asks third-party liquidity providers to make determinations they often cannot reasonably make such as whether a project's past statements remain "attached" to a token in secondary markets. Regulatory clarity should be practical as well as principled. We hope the Commission addresses these issues so firms can continue providing liquidity to U.S. markets while supporting investor protection.(Frank Chaparro)