Ripple filed its own comment letter with the Securities and Exchange Commission on Oct. 20, 2026. Chief Legal Officer Stuart Alderoty signed it, with General Counsel Sameer Dhond and Deputy General Counsel Deborah McCrimmon1. The letter runs 20 pages. Six rival networks, including Chainlink Labs and the Cardano Foundation, signed one joint letter instead, asking for one fix6. That fight cost the company more than $150 million in legal fees, the letter told the SEC. Ripple's chief executive is Brad Garlinghouse. His top lawyer chose to write alone.
The $150 Million Lesson Behind Ripple's Letter
Ripple's letter opens with its own history. The SEC sued Ripple in December 2020, arguing that XRP itself was a security1. XRP's price fell roughly 70% in the days after that complaint, and Ripple says the drop wiped out about $15 billion in market value. Nearly every exchange reachable from the United States delisted XRP or blocked it.
A federal judge ruled in July 2023 that XRP itself fell outside the definition of a security1. XRP's market cap rose by roughly $21 billion the same month. Coinbase and Kraken restored XRP trading for U.S. customers within a day4. Ripple's letter puts a price tag on that fight: “Few market participants can bear that cost, and none should have to in order to learn what the law requires,” it reads.
XRP's Market Cap Fell $15 Billion in 2020, Then Rose $21 Billion in 2023
The change in XRP's market value around the SEC's case, in billions of dollars
Source: Ripple Labs Inc., via ripple.com [1].
Read the chart as a table
| Item | Value |
|---|---|
| Lost after the 2020 complaint | $15B |
| Gained after the 2023 ruling | $21B |
Stuart Alderoty made the same point in public terms. “We support the proposal, and the SEC has clear authority to adopt it,” he wrote on X the day Ripple filed29. He called years of "case by case, coin by coin" enforcement a drag on the industry, and said the SEC needs "holistic rules for digital assets" in their place.
Both sides, in their own words
Does writing alone beat writing together?
“We support the proposal, and the SEC has clear authority to adopt it”
“No other framework in the history of the SEC allows those raising money from the public to check a box when they seek to stop complying with the obligation to honor their commitments to investors”
What Ripple's 20 Pages Actually Ask For
Ripple's central request is narrow. The SEC's proposed rule is Regulation Crypto Assets. It lets an "investment contract" tied to a crypto asset end once the issuer stops the promised work1. Ripple backs that idea in full. Its fight is over how an issuer proves that work has stopped.
The proposal offers a safe harbor called Rule 400. An issuer that files a public "Form TR" can show its promises are finished1. Ripple worries a filing could be mistaken for an admission that a token was a security all along. “Filing could become a litmus test in the eyes of a future Commission; not filing could stop looking neutral,” the letter says. So Ripple wants a new line added to the rule: skipping Form TR should leave a token's legal status exactly where it already stood.
Ripple also wants exchanges and brokers to rely on a filed Form TR and skip watching the issuer's every move afterward1. It wants that certainty to reach beyond the Securities Act, too. The same line should cover the laws that govern funds and investment advisers. Then a token's status stays fixed, whichever law a reader applies.
A decentralization test is the one thing Ripple opposes outright. The SEC's proposal ties an investment contract's end to what the issuer itself promised, leaving the spread of its network aside entirely1. Ripple backs that choice. SEC Chairman Paul Atkins has described the same standard in his own words: a crypto asset separates from an investment contract when the issuer “fulfills the representations or promises, fails to satisfy them, or they otherwise terminate”.
Six Rivals, One Letter, One Request
One joint letter drew six signers by the SEC's Oct. 20 deadline6. The group spans Chainlink Labs, Hedera, Aptos Labs, Ava Labs, the Cardano Foundation and the Stellar Development Foundation7. Their ask differs from Ripple's. In March 2026, the SEC's own guidance split tokens into five categories, including "digital commodities" that sit outside securities law. That split lives only in the preamble of the proposed rule, a step short of its binding text, the six organizations wrote.
Taylor Barr, Chainlink's head of policy, explained the stakes in plain terms. “Builders need lasting certainty. Codifying this progress would be a meaningful step toward keeping America the home of digital asset innovation,” he said8. The six letters sought one change: write the word "commodity" into the rule itself, so dropping it later would take a full rulemaking.
Hedera's name appears twice in the record that week. It joined the six-network letter, but it had already filed its own separate letter on Oct. 7, two weeks earlier3. That letter asked the SEC to protect issuers already relying in good faith on its 2026 guidance. It wanted that protection even ahead of any final rule. Ripple's ask and Hedera's solo ask point the same direction. Both companies added a letter of their own, apart from the group.
The Case Against the Self-Certification Model
Ripple's Form TR plan rests on one belief. An issuer can tell the SEC its own promises have ended. The market is supposed to trust that filing. Benjamin Schiffrin, director of securities policy at Better Markets, rejects that belief outright. His group filed its own comment the same week Ripple did10.
“No other framework in the history of the SEC allows those raising money from the public to check a box when they seek to stop complying with the obligation to honor their commitments to investors,” Schiffrin wrote10. His group asked the SEC to scrap the whole proposal. "We recommend that the Commission withdraw the proposal in its entirety," Schiffrin wrote.
Ripple's letter answers a version of that worry on its own terms. Issuers stay subject to the law's "antifraud and antimanipulation provisions," the letter notes, regardless of what a Form TR says. A false filing still leaves the SEC free to treat a token as a security1. Schiffrin's complaint and Ripple's answer point at the same clause from two directions: one calls it a loophole, the other calls it a backstop.
By the numbers
- Ripple's SEC litigation cost the company more than $150 million in legal fees, Ripple's own letter says1.
- The SEC's December 2020 complaint erased roughly $15 billion of XRP's market value within days1.
- XRP's market cap rose roughly $21 billion after the July 2023 ruling that put the token outside securities law1.
- Ripple's comment letter runs 20 pages, filed on the SEC's Oct. 20, 2026 deadline1.
- The rival joint letter drew six signers, one more than the brief first reported67.
- Hedera filed its own solo letter on Oct. 7, 2026, 13 days before it also joined the six-network letter3.
- The U.S. share of the world's crypto developers fell from 38% in 2015 to 19% in 2024, Ripple's letter says1.
Ripple Files Alone as Six Rivals Sign One Joint SEC Letter, Oct. 7 to Oct. 20, 2026
Three SEC comment letters on Regulation Crypto Assets, by filing date
Read the chart as a table
| Date | Event |
|---|---|
| Oct. 7, 2026 | Hedera files its own SEC letter |
| Oct. 20, 2026 | Six networks file one joint letter |
| Oct. 20, 2026 | Ripple files its own letter |
What to watch
The SEC's comment window on Regulation Crypto Assets closed Oct. 20, 2026, and the agency now reviews every letter before any final vote. See whether the adopting release keeps the clause Ripple proposed for Rule 400, or sides with Schiffrin's call to pull the rule back. The rule's binding text is the second test to watch. Check whether the SEC writes "digital commodity" into it. That is the one line all six rival networks asked for by name.
Sources
- Stuart Alderoty, Sameer Dhond and Deborah McCrimmon, "Comment Letter Re: Regulation Crypto Assets, Release Nos. 33-11434; 34-106150; File No. S7-2026-27," Ripple Labs Inc., via ripple.com, Oct. 20, 2026, https://ripple.com/reports/ripple-comment-letter-on-sec-reg-proposed-crypto-rule.pdf
- Stuart Alderoty, Post on X, X (Stuart Alderoty, @s_alderoty), Oct. 20, 2026, https://x.com/s_alderoty/status/2112673463416795466
- Nilmini Rubin and Gregory Schneider, "Comment Letter Re: Regulation Crypto Assets, Release Nos. 33-11434; 34-106150; File No. S7-2026-27," Hedera Hashgraph, LLC, Oct. 7, 2026, https://www.sec.gov/comments/S7-2026-27/s7202627-1086579-3792606.pdf
- Olivia Stephanie, "Ripple backs SEC crypto rule after $150M legal fight, seeks key changes," crypto.news, Oct. 21, 2026, https://crypto.news/ripple-sec-regulation-crypto-assets-comment-letter/
- Muriuki Lazaro, "Ripple spent $150M fighting the SEC lawsuit - Now it wants clear crypto rules," AMBCrypto, Oct. 21, 2026, https://ambcrypto.com/ripple-spent-150m-fighting-the-sec-lawsuit-now-it-wants-clear-crypto-rules/
- "Six blockchain organizations urge the SEC to define 'digital commodity'," KuCoin News, Oct. 21, 2026, https://www.kucoin.com/news/flash/six-blockchain-organizations-urge-sec-to-define-digital-commodity
- Generation Infinity, "SEC Digital Commodity Definition: Six Blockchain Networks Urge the SEC to Write It Into Binding Rule Text," Genfinity, Oct. 20, 2026, https://genfinity.io/2026/10/20/six-blockchains-urge-sec-codify-digital-commodity-definition/
- Varinder Singh, "Ripple, Cardano, Chainlink, Hedera, Stellar, Aptos & Avalanche Support SEC 'Regulation Crypto Assets'," CoinGape, Oct. 21, 2026, https://coingape.com/ripple-cardano-chainlink-hedera-stellar-aptos-avalanche-support-sec-regulation-crypto-assets/
- Rizwan Ansari, "Ripple Pushes SEC to Finalize Crypto Rules as Stuart Alderoty Calls for Clearer Laws," Coinpedia, Oct. 21, 2026, https://coinpedia.org/news/ripple-pushes-sec-to-finalize-crypto-rules-as-stuart-alderoty-calls-for-clearer-laws/
- Benjamin Schiffrin, "SEC Prioritizes Crypto Patronage Over Investors' Wallets," Better Markets, Oct. 20, 2026, https://bettermarkets.org/newsroom/sec-prioritizes-crypto-patronage-over-investors-wallets/