SEC Buyback Guidance Offers Limited Relief for Crypto Projects

The SEC recently issued guidance suggesting that token buybacks by decentralized networks may not inherently constitute a promise of managerial efforts under the Howey test. However, the agency later clarified that this relief only applies to networks with no central party, defined as having no operational, economic, or voting control. Analysis of major buyback programs, including those for $PUMP, $HYPE, $JUP, $LINK, $AAVE, $SKY, and $LDO, indicates that few, if any, currently meet this strict decentralization criteria.