Plume launches key move against the SEC: Cryptocurrency rules may change!

Plume Network, SEC submits new regulatory model

Plume Network has submitted a new proposal with the U.S. Securities and Exchange Commission (SEC) that could affect the way the United States regulates tokenized real-world assets (RWAs) and blockchain-based financial products. The application, filed on September 21, 2026, covers a number of key topics, from the regulatory status of on-chain vaults to the trading mechanism of tokenized funds in the secondary market. Plume's proposal argues that regulatory responsibility should focus on the entities making economic decisions rather than the neutral protocol developers providing infrastructure.

Clarify the attribution of regulatory responsibilities

The document drafted by Salman Banaei, general counsel of Plume Network, was published in the records of the SEC's Crypto Task Force under the title "Plume and vaults." The core of the proposal is to determine which regulations apply to Vault structures operating on blockchain. Plume believes that when determining regulatory obligations, the roles of various participants in the system must be distinguished. The proposal advocates that those who directly make economic decisions, such as Vault managers and Vault token issuers, should be at the core of regulatory responsibilities. Conversely, neutral protocol developers who only provide technical infrastructure and do not interfere in users 'economic decisions should not bear the same regulatory obligations.

Legal status and evaluation criteria for Vault shares

Plume's proposal also focuses on how to determine the legal status of Vault shares. The company recommends referring to the Howey Test and Reves Test to determine whether these assets should be considered securities. However, Plume opposes a single regulatory approach for all Vault structures, arguing that individual assessments should be conducted based on product characteristics. Factors such as the nature of assets held in the Vault, the decision-making power held by managers, the fees charged, and the sales of products inside and outside the United States may affect the determination of regulatory status. Depending on these factors, compliance requirements under the SEC or the Commodity Futures Trading Commission (CFTC) may also vary.

Promoting the construction of a secondary market for tokenized funds

The model Plume submitted to the SEC is not limited to resolving the legal status of on-chain vaults. The company also argued that in order to enable tokenized funds to operate on a broader blockchain infrastructure and establish a secondary market for them, corresponding support policies need to be developed. The proposal also proposes points such as making on-chain custody rules more transparent, lowering the threshold for different structured funds to use blockchain technology, and modernizing the transfer agent system. Plume pointed out that anti-money laundering (AML) controls could also be integrated directly into the structure of tokenized fund assets.

If this approach is implemented, tokenized fund units can obtain a more functional structure not only in the issuance stage, but also in the secondary market. Plume's proposal is consistent with his previous submissions to the SEC's Cryptocurrency Working Group on tokenization and capital market modernization.

Summary and Outlook

The proposal submitted by Plume Network to the SEC aims to delineate clearer regulatory responsibilities for the fast-growing tokenization industry. Among them, distinguishing neutral protocol developers from Vault managers who make economic decisions is one of the most eye-catching highlights of the proposal. Developing secondary markets for tokenized funds, clarifying on-chain custody standards, and adapting existing financial infrastructure to blockchain technology are important steps in strengthening the connection between traditional capital markets and blockchain-based finance.