Overview

• The SEC’s Division of Corporation Finance said it will not recommend enforcement if DoubleZero conducts programmatic 2Z transfers under the practices described in a Sept. 25 filing.
• Staff indicated 2Z is not an equity security and, per Commissioner Hester Peirce, functions as a reward for services rather than an investment under the Howey Test.
• The assurance is limited to DoubleZero’s representations, with the letter stressing that different facts could yield a different outcome and that it is not a binding legal ruling.
• DoubleZero plans to debut 2Z alongside a mainnet-beta launch on Solana on Friday, with tokens distributed to connectivity and resource providers based on performance.
• Industry voices, including co-founder Austin Federa and legal scholars, welcomed the move as a practical template for DePIN, citing a broader engagement-focused posture at the SEC.