🚨NEW: The
@SECGov just updated its crypto FAQ on token buybacks to add a stipulation that if there is no central party behind those token buybacks, then this arrangement likely does not constitute an investment contract.
It comes following comments from
@a16zcrypto General Counsel and Head of Policy
@milesjennings last week that the prior wording could “empower an issuer to announce the buyback program without that announcement then creating an investment contract.”