6/26/2018 1:35:54 PM,
Legal & Compliance, LLC replied:

As it stands today, the vast majority, if not all, token or coin issuances implicate the federal securities laws and involve the sale of securities.  Accordingly all offerings should be treated as such.  The guidance helps us understand how companies can plan in advanced to either have their token or coin remain subject to the securities laws, or go in a specific direction that will result in an eventual decentralized network, where purchases and sales do not involve the securities laws.