RCAICO · The Offering

Chapter 03 of 10

The Offering · Vol. 02 No. 01

The Statute · 03

September 2026 · London

Pathways that exist, pathways that are proposed, pathways that are folklore · Proposal

How to use a proposed US framework without lying

Attention is a fact. A comment period is not an exemption.

There is a useful fact and a dangerous one, and they travel together. Useful: founders, counsel and boards are planning around a proposed US framework for crypto-asset offerings. That planning is demand. Dangerous: people speak as if the proposal were already the path. A proposal can change, stall, be replaced, or issue in a form that does not match the deck.

Permitted public language, if any, is small: that the team is watching a proposed framework; that any US offer will follow counsel and live rules; that this communication is not an offer. Prohibited: “Reg CA-compliant,” “the new Reg A,” “retail-ready in the US,” “waiting on the exemption” as if the wait were a queue with a number.

Operationally, use the attention to professionalise. Claims, geographies, providers, a desk. Those artefacts remain if the proposal dies. The artefacts we refuse to produce are the ones that only work if a specific final rule arrives: a public sale page, an allocation waitlist, a creator script that tells a general US audience they can participate. Those are a different business.

Next step

Planning a regulated ICO? Same screen as everyone.

Four-step screen. A person replies. Fourteen days to a pack you can take to market. 0% of proceeds.