Key Takeaways
- • KoreInside submitted a comment letter to the U.S. Securities and Exchange Commission on proposed Regulation Crypto Assets (SEC File No. S7-2026-27), recommending a technology-neutral framework that links investor identity, disclosures, ownership records, payments and settlement across the investment lifecycle.
- • The company urges the SEC to keep a crypto asset distinct from the legal rights of the underlying investment contract, so tokenization, wrapping or network migration does not alter an instrument's legal character.
- • KoreInside proposes a continuation route for existing holders when the proposed Startup Exemption's four-year period ends, avoiding a reporting and resale cliff while the investment relationship continues, without extending the fundraising window.
- • The letter supports non-accredited investor participation paired with compliance requirements scaled to funds raised, discretionary control, custody exposure and operational complexity.
- • KoreInside opposes mandatory use of any specific vendor, ledger, identity system or certification service for issuers relying on the exemption.
Summary
KoreInside, a provider of technology infrastructure for private capital markets, announced on October 8, 2026 that it had submitted a comment letter to the U.S. Securities and Exchange Commission on proposed Regulation Crypto Assets, according to the company's press release distributed by KOREWIRE. The company said the letter seeks a framework that expands capital formation while preserving clear legal rights, accountable transaction processing and dependable investor protections. KoreInside said it supports the Commission's objective of creating workable capital formation pathways for covered investment contracts.
The central recommendation is an infrastructure model combining durable, verifiable records, reusable evidence of identity, capacity and eligibility, and coordinated transaction processing with current authorization checks. Dr. Kiran Garimella, Co-Founder, CTO and CSO of KoreInside, said that capital formation depends on more than issuing a token, and that investors need to know what they own, which disclosures informed their decision, who has authority to act, and whether payment and transfer have settled.
On legal rights, KoreInside urges the Commission to maintain a distinction between a crypto asset and the legal rights attached to an investment contract. Per the letter, tokenization, wrapping or migration to another network should not by itself change an instrument's substantive legal character, and a change in regulatory classification should not be presented as canceling contractual obligations, property interests or claims arising from earlier conduct.
The letter addresses six operational priorities: durable disclosures with dated versions and archives; optional reusable identity credentials that protect personal information; clear rules on which records establish investor entitlements and how failed transactions are resolved; technology-neutral implementation covering public, permissioned and hybrid ledgers; evidence requirements for issuers' regulatory transition determinations; and common data definitions and export formats so participants can change providers or networks without losing records.
KoreInside also recommends avoiding a reporting and resale cliff for existing holders when the Startup Exemption's four-year period ends while the investment relationship continues, proposing a proportionate continuation route for outstanding interests. On access, the company supports participation by non-accredited investors alongside safeguards that small issuers can administer, and says no particular vendor, ledger, identity system or independent certification service should be mandatory merely because an issuer chooses the exemption.
The filing references SEC File No. S7-2026-27 and Release Nos. 33-11434 and 34-106150. KoreInside describes itself as a global capital markets infrastructure company offering blockchain technology, digital securities, identity management, compliance automation, transfer agency services and regulatory technology through products including KoreChain, KoreOracle, KoreID, Compliance Desk and KoreTransfer.
The central recommendation is an infrastructure model combining durable, verifiable records, reusable evidence of identity, capacity and eligibility, and coordinated transaction processing with current authorization checks. Dr. Kiran Garimella, Co-Founder, CTO and CSO of KoreInside, said that capital formation depends on more than issuing a token, and that investors need to know what they own, which disclosures informed their decision, who has authority to act, and whether payment and transfer have settled.
On legal rights, KoreInside urges the Commission to maintain a distinction between a crypto asset and the legal rights attached to an investment contract. Per the letter, tokenization, wrapping or migration to another network should not by itself change an instrument's substantive legal character, and a change in regulatory classification should not be presented as canceling contractual obligations, property interests or claims arising from earlier conduct.
The letter addresses six operational priorities: durable disclosures with dated versions and archives; optional reusable identity credentials that protect personal information; clear rules on which records establish investor entitlements and how failed transactions are resolved; technology-neutral implementation covering public, permissioned and hybrid ledgers; evidence requirements for issuers' regulatory transition determinations; and common data definitions and export formats so participants can change providers or networks without losing records.
KoreInside also recommends avoiding a reporting and resale cliff for existing holders when the Startup Exemption's four-year period ends while the investment relationship continues, proposing a proportionate continuation route for outstanding interests. On access, the company supports participation by non-accredited investors alongside safeguards that small issuers can administer, and says no particular vendor, ledger, identity system or independent certification service should be mandatory merely because an issuer chooses the exemption.
The filing references SEC File No. S7-2026-27 and Release Nos. 33-11434 and 34-106150. KoreInside describes itself as a global capital markets infrastructure company offering blockchain technology, digital securities, identity management, compliance automation, transfer agency services and regulatory technology through products including KoreChain, KoreOracle, KoreID, Compliance Desk and KoreTransfer.
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