Two months after the SEC unveiled its Regulation Crypto Assets proposal, Ripple filed a 20-page comment letter supporting the rule on October 20, while asking for changes to how investment contracts and secondary trading are treated.

Ripple's core argument is that an investment contract can be a security without making the token itself one. It wants the SEC to judge when that contract ends by what the issuer expressly promised investors, not by a separate decentralization test.

The company also asks for certainty around Form TR, the filing that marks an issuer's essential managerial work as done, so exchanges and brokers can rely on it when deciding to list a token. The proposal includes exemptions for raises of up to $5M over four years and up to $75M within 12 months.

Ripple says its earlier legal fight with the SEC over XRP cost more than $150M in legal fees.