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Model Opening Brief – Regulation Crypto Assets (Sept. 18, 2026)
This is a model opening brief, published as an example of what could be filed once Regulation Crypto Assets is adopted. It was drafted against the Commission’s August 2026 Proposal on the assumption that the Final Rule adopts the Proposal without material change, and was updated on September 18, 2026, to reflect the Senate’s September 15, 2026 rejection of cloture on H.R. 3633, the CLARITY Act (49–50, sixty required), and Chairman Atkins’s September 16, 2026 statement that the Commission will act “with or without legislation.” Bracketed fields identify information that does not yet exist or that a filing petitioner must supply. Citations are current as of September 18, 2026.
About John Reed Stark
John Reed Stark President of John Reed Consulting LLC. Served for 15 years as an SEC enforcement attorney leading cyber-related projects, investigations and enforcement actions; For 11 years as Founder/Chief of SEC Office of Internet Enforcement; For 15 years as Adjunct Professor at Georgetown University Law School teaching cyber law; For 10 years as a Guest Instructor at the FBI Academy; For 5+ years as Managing Director (three as head of the Washington, D.C. office) of Stroz, Friedberg, a global digital risk management firm, leading cybersecurity, incident response and digital compliance engagements for corporations. Appointed since 2017 as Senior Lecturing Fellow at Duke University Law School teaching law of cybersecurity and data breach response. Author of The Cybersecurity Due Diligence Handbook. 
