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SEC Staff Grants Conditional No-Action Relief for Fuse’s Energy Rewards Token

The decision turns on a loyalty-style structure with capped, market-linked redemption that staff said avoids reliance on Fuse’s success.

Overview

  • The Division of Corporation Finance told Fuse it would not recommend enforcement if the ENERGY/FUSE token is offered exactly as described in a Nov. 19 filing.
  • Staff emphasized the relief is limited to the stated facts and could change if the token’s mechanics or use depart from the submission.
  • In applying the Howey test, the staff concluded the token’s value does not depend on Fuse’s managerial efforts or overall corporate performance.
  • Fuse’s Solana-based token functions as a rebate-style reward for households using distributed energy resources—such as rooftop solar, batteries, and EV chargers—with redemption capped and tied to average market prices.
  • Reporters place the action alongside recent staff letters, including relief for DoubleZero’s 2Z token, as a measured step toward clearer guidance for some consumer and DePIN token models.