Ripple Labs submitted a 4-page memorandum to the SEC's Crypto Task Force in response to Commissioner Hester Peirce's speech on crypto assets and investment contracts.
Ripple proposes a two-pronged test to determine when a token has severed from an investment contract, highlighting the importance of outstanding promises to the original purchaser.
The company cites a July 2023 ruling that found XRP itself is not a security, emphasizing the distinction between XRP and investment contracts.
Ripple endorses the idea of a well-designed safe harbor as suggested by Commissioner Peirce to provide regulatory certainty for crypto assets circulating openly in functional networks.