Methodology

We cover the top 100 tokens by market cap (CoinGecko, Oct 19, 2026). For each one we collect: regulator statements (SEC, CFTC), court rulings and enforcement outcomes, US spot ETF and CFTC-regulated futures listings, stablecoin issuer status under the GENIUS Act, US exchange availability, and decentralisation signals. Then we apply these rules in order:

1. R1 · Payment stablecoin: a USD stablecoin from a centralized issuer whose structure fits the GENIUS Act 'payment stablecoin' model → 'Payment stablecoin'. Confidence is capped at Medium-High until the Act takes effect (expected Jan 18, 2027), because no issuer is yet a 'permitted' issuer. Foreign issuers are capped at Medium.
2. R2 · Likely digital commodity: the token is named as a 'digital commodity' in the SEC's March 2026 interpretation → 'Likely digital commodity'.
3. R3 · Confidence for R2: High needs at least 2 corroborating signals (CFTC calling it a commodity in an enforcement filing; CFTC-regulated futures; a US-listed spot ETF trading) and no adverse court finding or prior SEC securities allegation. Otherwise Medium-High.
4. R4 · Likely security-type: used only with strong official basis. Either a court or regulator has held that the token itself is a security, or the issuer's own legal documents say the token is a fund share or note offered under securities laws (tokenized funds). No network token in the top 100 meets the court/regulator bar. XRP's 2023 ruling applied to certain Ripple sales, not to the token, and the SEC now names XRP a digital commodity.
5. R5 · Unclear: everything else, including tokens with only market signals (ETFs, listings) but no official classification; stablecoins outside the payment-stablecoin model; exchange tokens; and tokenized real-world assets.

Confidence reflects the quality of the evidence: High needs an official statement naming the token plus market-structure evidence such as CFTC-regulated futures or ETFs. Each missing element lowers it. Payment stablecoins are capped below High until the GENIUS Act takes effect. "Unclear" is our default whenever there is no official basis. We never guess "security".

Confidence across the top 100 today:

• Low48
• Low-Medium25
• Medium2
• Medium-High21
• High4

1. US money-transmission licensing (25): FinCEN MSB registration (5) plus state money transmitter licence coverage: broad (20), partial or unverified (12), none (0).
2. Higher-tier US oversight (20): NYDFS BitLicense or NY trust charter (10), a CFTC-registered affiliate (DCM/FCM/DCO) (5), an SEC-registered broker-dealer affiliate or an SEC-reporting parent (5).
3. Reserves & financial transparency (20): audited financial statements filed with the SEC (10) plus proof of reserves: within 12 months (10), self-reported only (5), older than 12 months (3). Capped at 20.
4. Enforcement record, last 5 years (25): starts at 25. Criminal guilty plea by the company −20, or by a related group company −10. Each regulatory penalty of $1M or more −5 (max −15). Dismissed or closed cases don't deduct, but we still show them.
5. Security incidents, last 3 years (10): starts at 10. Theft of $100M or more −7. Disclosed customer-data breach −4.

Bands: 80+ Strong signals · 60–79 Moderate · 40–59 Weaker · under 40 Significant concerns. The score measures public regulatory and transparency signals, mostly from a US point of view. It is not a solvency rating, an audit, a guarantee your funds are safe, or a recommendation. Exchanges that don't serve the US score low on US licensing by design. Each input is linked to a dated source on the exchange's page; "not found" means we looked and couldn't verify it, not that it doesn't exist.

On My tokens we weight each token's status (commodity 10, stablecoin 20, unclear 60, security-type 90) by your holdings' value, or equally if you don't enter amounts. It measures legal uncertainty only, not price risk.

A cron job checks Congress.gov, SEC and CFTC feeds every day at 06:00 UTC. New items appear as unreviewed. Anything that might affect a status is only flagged pending review and is never auto-published. Evidence is re-checked manually. Each token and exchange page shows its last-checked date.

"Not found" means we looked and couldn't verify something, not that it doesn't exist. Third-party sources are labelled. Statuses are estimates under a bill that isn't law, so read them as "likely, not legal advice".