Disclosure reader Early
What issuers would have to tell you under the proposed CLARITY Act, and the disclosure-style documents that already exist. This section is early and incomplete.
At a glance
Three kinds of disclosure- CLARITY Act (proposed)Offering statement + semiannual reports
- GENIUS Act (law)Monthly reserve reports
- EU MiCA (in force)Stablecoin white papers
What the CLARITY Act would require (House-passed text)
Issuers raising money under the new exemption (up to $50M per 12 months, Sec. 202) would file an offering statement with the SEC that includes:
- Maturity status: whether the blockchain is certified as a "mature blockchain system", and if not, the plan and timeline to get there.
- Source code: or a public link to it, plus any third-party security audit and its material results.
- Transaction history: how to independently verify it.
- Token economics: launch and supply, release schedule, consensus, burning, value mechanisms and governance.
- Plan of development: roles, control mechanisms and critical dependencies.
- Ownership: a list of insiders and affiliates who hold or have rights to tokens.
Until the blockchain is certified as mature, issuers would also file semiannual reports (development progress, money raised and spent, financial statements where applicable) and current reports on material changes. Brokers would have to explain how your crypto is treated if they go insolvent (Sec. 311), and registered platforms would have to provide educational materials (Sec. 314).
H.R. 3633 (engrossed in House), Secs. 202, 311, 314 ↗
Already law: stablecoin reserve disclosures (GENIUS Act)
Once in force (by Jan 18, 2027), permitted payment stablecoin issuers must publish the monthly composition of their reserves on their website (total outstanding, and the amount, composition, average tenor and custody location of reserves). An accounting firm examines the report each month and the CEO and CFO certify it. Issuers with more than $50 billion outstanding that aren't SEC reporting companies must also publish audited annual financial statements. GENIUS Act, Sec. 4 ↗
Real documents you can read today
EU MiCA white papers (stablecoins)
- USDC: Circle Internet Financial Europe SAS is listed in ESMA's e-money token register. USDC MiCA white paper ↗
- USDG: Paxos Issuance Europe Oy is listed in ESMA's e-money token register. USDG EU white paper ↗
- USDT: we didn't find Tether in ESMA's e-money token register (checked Oct 19, 2026).
Tokenized funds (offering documents)
- Issuer docs: USYC represents an interest in a Cayman Islands mutual fund; 'tokens represent shares in the fund'. Issued by Circle International Bermuda. Hashnote / Circle ↗
- Issuer docs: USDY tokens have not been registered under the US Securities Act and may not be offered or sold to US persons unless registered or exempt. Issued by Ondo Global Markets (BVI). Ondo Finance ↗
- BlackRock's tokenized fund. Shares are issued under Rule 506(c) of the Securities Act and Section 3(c)(7) of the Investment Company Act, for qualified investors only ($5M minimum). Securitize / BlackRock ↗
- Research memo: Spiko SICAV is an AMF-authorized French UCITS fund company. The token at an allowlisted address is the fund share itself, and US persons can't buy it. Third-party summary of the prospectus. Ketju Research ↗
- Issuer site: ownership in the fund is represented by USTB tokens. The fund is limited to qualifying investors who receive offering materials. Superstate ↗
Summaries are short and factual and don't replace the original documents. Not legal advice.