Comparable opportunities. Comparable burdens. Clear reasons for differences.
Presumptive Parity is the Crowdfunding Professional Association’s policy principle for a coherent exempt capital-raising framework. When the Securities and Exchange Commission creates or materially changes one pathway, it should compare the effects on similarly situated existing pathways and explain meaningful differences in treatment.
The CfPA Board of Directors adopted Presumptive Parity on September 18, 2026, as the 20th plank of the association’s policy platform.
The adopted policy
We support the principle of Presumptive Parity: when the SEC creates or materially changes an exempt capital-raising pathway, it should compare that pathway with similarly situated existing pathways, and comparable opportunities and comparable burdens should be the starting assumption unless meaningful differences justify different treatment. The burden of identifying a meaningful difference should fall on whoever defends the disparity. Novelty alone is not such a difference. Where no justification exists, the SEC should move toward parity to the extent its legal authority permits.
Read the current CfPA Policy Platform (PDF)
How Presumptive Parity works
- Compare similar pathways. Evaluate comparable capital-raising activities across the exempt offering framework, including Regulation Crowdfunding, Regulation A and new exemptions.
- Start with comparable opportunities and burdens. Consider both the capital-raising benefits and the investor protections attached to each pathway.
- Explain differences. A meaningful difference can justify different treatment. Novelty alone does not explain a disparity.
- Act within legal authority. Where differences lack justification, the SEC should move toward parity to the extent its authority permits. Where a statute prevents parity, the appropriate change requires legislative action.
The principle runs both ways
A comparison may support modernizing an existing pathway when a new one offers appropriate relief. It may also support adding proportionate safeguards to a new pathway when investors face comparable risks. The aim is to make the comparison explicit and the reasoning visible.
That approach helps entrepreneurs, investors, funding portals, broker-dealers and service providers plan around a more coherent regulatory framework.
Presumptive Parity in practice
CfPA applied this principle in its October 20, 2026 comment letter on the SEC’s proposed Regulation Crypto Assets. The letter compares the proposed crypto offering exemptions with Regulation Crowdfunding and Regulation A, recommends proportionate investor safeguards, and reiterates CfPA’s call to raise the Regulation Crowdfunding offering limit to $20 million.
Read CfPA’s Regulation Crypto Assets comment letter on SEC.gov
Policy and background
- Current CfPA Policy Platform: all 20 planks (PDF)
- CfPA Regulatory & Legislative Policy Platform
- September 23, 2026 announcement of Presumptive Parity
Explore CfPA’s policy priorities or join CfPA to support this work.
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Devin is a journalist, author and educator. He calls himself a champion of social good. As a new-media journalist and founder of the Your Mark on the World Center, Devin has established himself as a champion of social good. As a Forbes contributor, with over 400 bylines and over
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