Token projects raising money under the SEC’s proposed crypto offering rules would have to spell out their token loans, their agreements with exchanges and market makers, and the tokens they pay advisers and influencers, if the agency adopts changes requested by crypto data and media company Blockworks.

Blockworks said it is filing a comment letter on Regulation Crypto Assets, the framework for token offerings the SEC proposed in August. Comments are due Oct. 20. Unchained has not seen the letter itself; the requests below are as Blockworks described them in a briefing it shared with Unchained ahead of release.

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What Blockworks Wants Disclosed

Blockworks said the letter asks the SEC to write line items from its Token Transparency Framework into the rules. Projects would have to disclose token loans and liquidity arrangements, their agreements with exchanges and market makers, any tokens paid to advisers or influencers, key wallet and contract addresses, and how they calculate supply.

The SEC’s draft is less prescriptive. Its Rule 103 names broad topics an issuer must cover, including a token’s supply, lockups, distribution and holdings by related persons, and, according to the proposing release, requires the material aspects of each “without specifying detailed information that must be provided.” The proposing release does not mention market makers or Blockworks. It does ask commenters whether the agency should “adopt more prescriptive disclosure requirements” instead.

Blockworks also said the letter asks the SEC to recognize a new role, the Qualified Onchain Disclosure Agent, which it describes as an independent provider held to standards the SEC would set. A project would connect its wallets and contracts, the agent’s software would pull in what is visible onchain, and the project would fill in the rest, then check and approve the whole filing. The agent would keep every filing in a public, searchable archive with dated versions. The SEC’s release does not describe any such third-party agent.

Tokens Without a Current Filing

The two other requests deal with tokens that lack a current filing. Blockworks said the letter proposes that exchanges or other third parties could write up disclosures for projects that have never filed their own, and that a third party could maintain a labeled record after a project shuts down or exits mandatory reporting. In the SEC’s proposal, the duty to disclose rests with the issuer.

Blockworks developed the Token Transparency Framework and runs it. Blockworks said the letter is being sent in partnership with its Transparency Alliance, a group of firms that back the framework; members listed on its disclosure site include Coinbase, Kraken, Binance.US and ARK Invest. Blockworks has not said which firms, if any, signed the letter. The site also lists filings submitted by issuers alongside ones compiled by Blockworks. The company offers tools to token issuers, including an Issuer Console and RapidFile, a free tool that drafts Token Transparency Framework filings. The briefing does not say whether Blockworks would seek to act as a disclosure agent. Blockworks also publishes crypto news and competes with Unchained.

Where the Rule Stands

The proposal would let token startups raise up to $5 million over four years, or up to $75 million in a 12-month period, as Unchained reported when it was released. SEC and CFTC leaders said last month their agencies would write crypto rules under existing authority after the Clarity Act stalled in the Senate. The SEC must review the comments filed under File No. S7-2026-27 before it can adopt a final rule.

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