Lieu center’s suv valkenburgh observed the howey test is useful in pursuing schemes which can be pretending not to be investments, but that it must be not a global tool., adding that european countries has a dark letter legislation approach rather than test. Pat sonsini goodrich & rosati’s rosenblum contended that planning to make a distinction involving the two can result in market muddiness, and that it is hard to take a sections between, setting up a climate of second guessing. Instead of creating laws that make an effort to decipher between your two, this individual argued that there should be one particular system which can be applied to both equally securities and commodities. In the testimony, rosenblum made recommendations to our elected representatives for the short and long-term. This individual stated that congress may help ICO list inside the short-term simply by helping to take care of investors out of fraud by simply allowing the sec and also other appropriate federal government regulators to change or revise their existing rules to help ico companies in fulfilling securities regulation requirements. Rosenblum specifically known that current registration requirements do not work efficiently because they are not really targeted at icos, calling on the sec to amend or perhaps modify individuals rules. Inside the long-term, this individual suggested that congress include an one disclosure strategy, registration procedure, and legal approach with regards to how icos and bridal party are addressed in the circumstance. s. Yet cautioned that it can be too early along the way to make such laws, as the industry improvements too quickly.