SEC corporation-finance staff states that described meme coins generally are not securities

What changed

Corporation Finance staff stated that the offer and sale of meme coins with the characteristics described in the statement generally do not involve securities. The statement is nonbinding, fact-specific, and does not protect products labeled as meme coins that are structured or marketed differently.

Who it affects

• Advisers evaluating meme-coin exposure or client requests
• Issuers, promoters, platforms, and custodians

What is still open

• How the SEC will analyze hybrid or promoter-supported meme-coin arrangements
• Application of state law, commodities law, fraud law, and adviser fiduciary obligations

What it means for an advisor

• Do not use the staff statement as a blanket asset-approval list
• Document product-specific facts, liquidity, manipulation, custody, valuation, and communication risks

Previous interpretation

There was no comparable current staff statement identifying a described category of meme coins as outside federal securities registration.