This is one hell of an article, thank you. 12(g) is a huge problem for SMEs trying to tokenize, and it’s made me wonder if we can really capture the value prop of security tokens.

Indirect holding actually seems like the solution to the problem, though obviously not a perfect one. Short version:

1. Cap investors at 1,999
2. Whitelist broker-dealers/ATSs
3. Allow investors to be beneficial owners
4. ??????
5. Profit

Would love to hear your thoughts on my recent article: https://medium.com/consilient/can-security-tokens-survive-the-exchange-acts-section-12-g-caa86b6f6be3