The recent release of NASAA’s Principles for SEC Crypto Asset Regulation underscores the growing urgency to bring digital asset markets into compliance—but misses a key point: state-by-state blue sky compliance for secondary trading simply doesn’t work in today’s market environment.

At GUARDD, we’ve been on the front lines, building the infrastructure to enable lawful secondary trading of exempt, freely transferable securities—including tokenized assets. We’ve helped dozens of issuers publish structured disclosures. But when we tried to get our system accepted on a state-by-state basis under the outdated “manual exemption” model, we hit a wall. The system is fragmented, slow, and opaque—despite our platform offering better transparency and automation than the printed directories regulators still rely on.

It’s time for a new approach.

We urge NASAA and its members to consider a unified state standard for structured disclosures—one that qualified platforms like GUARDD could support. Without it, issuers are left in limbo, investors face liquidity barriers, and innovation continues to be throttled by regulatory friction. Alternatively, Congress or the SEC must step in to establish or authorize a central registry for exempt securities disclosure, akin to EDGAR, but tailored for secondary trading compliance.

We’re ready to help build this future. But we can’t do it alone.