[SEC Staff: Maintenance and Upgrades of Functional Crypto Networks Generally Do Not Constitute 'Essential Managerial Efforts' Under the Howey Test] According to the FAQ on crypto assets released by the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance on September 25, once a crypto system reaches a 'functional' state, providing services such as secure maintenance, improvements, feature enhancements, or promoting network effects—including funding or sponsoring development projects—generally does not constitute the 'essential managerial efforts' referred to in the Howey Test. Such service commitments themselves typically do not meet the corresponding criteria of the Howey Test. The FAQ also states that if staking receipt tokens merely represent the holder's ownership of the underlying digital commodity and do not alter related rights, obligations, or benefits, they may be considered 'digital tools'; when issued by protocol-based liquid staking providers, they may also be regarded as 'digital commodities.'