Blockworks, Inc. urged the U.S. Securities and Exchange Commission (SEC) to let issuers using its proposed startup exemption publish disclosures through a shared archive, saying investors could track changes more easily.
In an Oct. 20 comment letter, Blockworks argued that disclosures spread across issuer websites make revisions difficult for investors, market intermediaries and SEC staff to follow. Its proposed Qualified Onchain Disclosure Agent, or QODA, would help issuers prepare Rule 103 offering disclosures and maintain a dated, searchable public record. Use of the agent would be optional; issuers would approve their disclosures and remain responsible for the content.
Blockworks said an agent could draw on blockchain data when preparing disclosures. The agent’s public record would be separate from the notice of reliance an issuer would file with the SEC on EDGAR.
The SEC’s plan covers eligible issuers of investment contracts involving crypto assets. Over four years, the proposed startup route would allow offerings totaling up to $5 million. A separate, tiered exemption has 12-month limits of $20 million and $75 million. Neither exemption has taken effect.
For the startup route, the SEC has asked whether issuers should publish disclosures on websites identified in their SEC notices or submit them through EDGAR. It has also sought views on preserving earlier website versions and identifying revisions. EconoTimes previously covered the proposed offering exemptions and comment deadline.
Blockworks also wants issuers to provide more detail on trading and liquidity arrangements, including market-maker loans and exchange listings. Its letter calls for disclosure of token compensation for advisers and influencers, relevant wallet and contract addresses, and the methods used to calculate token supply.
Blockworks said its Token Transparency Framework held 213 disclosures on Oct. 15. Projects submitted 117; the company assembled the other 96 from public information. It said people could read a QODA repository it might operate for free, while it might charge for bulk, programmatic or integration access. Blockworks said it was seeking neither an exclusive role nor an SEC-set fee.
The company argued that shared infrastructure could lower costs for issuers and cited proxy processing and market information services as precedents. The comment period ended Oct. 20, and the SEC has not adopted a final rule.
