DeSci Coin to Company Model Paper
This paper details the Coin to Company (C2C) model for building crypto based organizations to fund and develop advanced scientific research.
THE COIN-TO-COMPANY MODEL:
RECONCILING DECENTRALIZED GOVERNANCE WITH SECURITIES REGULATION THROUGH STRUCTURAL SEPARATION AND COMPLEMENTARY EXEMPTIONS UNDER U.S. LAW
Benjamin Snipes Chief Legal Officer, Molecule AG January 2026
ABSTRACT
This Article proposes a novel legal framework, the Coin-to-Company (“C2C”) model, that reconciles the structural and governance innovations of blockchain-based organizations with the substantive requirements of U.S. securities law through categorical separation and complementary use of established regulatory exemptions. The model addresses a fundamental tension in digital asset regulation, which is how to enable broad-based community participation and decentralized governance through token distribution without triggering securities law compliance obligations, while simultaneously creating compliant pathways for value realization through traditional corporate equity structures.
Rather than attempting to resolve this tension through novel legal theories such as relying on indefinite concepts of “sufficient decentralization” or temporal transformation of securities, the C2C model maintains clear categorical distinction between tokens distributed as utility or community instruments (the “coins”) and equity securities issued through established exemptions by a traditional operating company. Tokens never represent investment contracts; equity never dilutes token utility.
The model achieves this through a set of core design principles and mechanisms described below that implement structural separation, token locking as technical identity infrastructure, documented equity pathways, and governance arrangements that preserve utility while enabling compliant equity participation.
KEYWORDS: Coin-to-Company, C2C, Digital assets, securities regulation, token offerings, DAOs, decentralized governance, Rule 701, Regulation D, Howey test, corporate structure
I. INTRODUCTION
A. The Regulatory Paradox
Since the Securities and Exchange Commission’s 2017 Report on The DAO, [1] digital asset regulation has been characterized by what might be termed a “regulatory paradox”: the law’s ostensible hostility toward decentralization conflicting with its theoretical neutrality toward technological innovation.
The paradox manifests in multiple ways. First, the Howey test—articulated for decidedly non-technological investment arrangements in SEC v. W.J. Howey Co., a 1946 case concerning orange grove investments [2]—has been applied with remarkable consistency to fungible digital assets, despite the profound structural and economic differences between orange grove sale-leasebacks and blockchain protocols. The test’s focus on “efforts of others” has proven difficult to apply in decentralized systems where no identifiable “other” manages the network, and where protocol improvements emerge from distributed developer communities rather than centralized management. [3]
Second, the regulatory response to digital assets has historically depended more on the specific characteristics of distribution arrangements than on the functional nature of the assets themselves. The same token distributed through a private placement to accredited investors might constitute a security, while the identical token distributed decentrally to thousands of network participants might be characterized as a commodity—despite fundamental economic equivalence. [4] This form-over-substance approach creates perverse incentives: projects are encouraged to conduct rushed, risky decentralizations rather than carefully planned network launches, simply to evade securities classification.
Third, the historical regulatory approach has forced projects into false choices: either conduct an unregistered securities offering by raising capital through token sales, or spend years and substantial resources launching tokens through offshore vehicles and geofencing the United States, trying to achieve “sufficient decentralization” before further regulatory scrutiny, which is a threshold whose definition remains frustratingly vague. [5] A middle path enabling compliant community formation through utility token distribution while allowing subsequent, explicitly disclosed equity participation opportunity and traditional capital formation much like any other startup company, has been largely unavailable.
This regulatory environment has had concrete consequences. The initial coin offering (ICO) market, which raised approximately $13.3 billion in 2018, collapsed following sustained SEC enforcement actions establishing that most ICOs constituted unregistered securities offerings. [6] Subsequent token distribution approaches, including Simple Agreements for Future Tokens (“SAFTs”), demonstrated only marginally greater longevity. The SEC v. Telegram enforcement action established that pre-sales do not insulate subsequent token distributions from securities scrutiny if the overall scheme involves unrestricted public distribution. [7]
Crypto projects have increasingly gravitated toward a dual structure comprising an offshore foundation (such as in the Cayman Islands or Switzerland, or as a Swiss association (Verein)) holding crypto assets for the unincorporated DAO of token holders, combined with a U.S.-based “LabsCo” or “DevCo” that performs all traditional corporate activity. This positioning allows the DAO to operate outside the jurisdictional reach of U.S. regulators, thereby minimizing exposure to U.S. securities laws and enforcement actions. Meanwhile, the U.S.-based entity functions as the operational arm, undertaking substantive business operations and programming, which equity is held by venture capitalists and the centralized, founding team. This separation aims to achieve a balance between operational efficacy and regulatory compliance, but has inevitably created friction between token holders who expect value to accrue to the tokens and the DevCo that has fiduciary responsibility to its shareholders. [8]
Meanwhile, the unincorporated decentralized autonomous organizations of token holders and their often adjacent foundations and associations, have developed without clear legal structure, exposing participants to general partnership liability and creating practical difficulties in contracting, owning property, and conducting business operations. [9] Recent litigation has confirmed that courts will apply traditional entity classification frameworks to DAOs regardless of their technological structure, often with outcomes adverse to participants who believed themselves protected by decentralization. [10]
B. Why Prior Approaches Failed
Understanding the C2C model requires first understanding why previous attempts to reconcile tokens and securities regulation have proven inadequate.
The ICO model treated tokens as equity analogues and therefore failed Howey analysis in practice. [11]
The SAFT/pre-sale model attempted temporal bifurcation that Telegram rejected as a unitary offering. [12][13]
The “sufficient decentralization” approach is vague, operationally difficult, and reliant on regulatory discretion. [14][15][16]
C. The C2C Model as Synthesis
The Coin-to-Company model attempts to address these deficiencies through categorical separation rather than temporal transformation.
At a high level: tokens (community/utility instruments) and equity securities (investment instruments) serve different functions and must be operationally and legally separated. Tokens provide community membership, tokenized utility, and technical identity infrastructure; equity provides investment exposure, governance rights under corporate law, and institutional capital. The same person can participate in both ecosystems, but via separate agreements and legal forms.
The design centers on the following core elements (presented as a stepper for clarity):
Dual-Organization Structure
A U.S. LLC with a C Corporation tax election (the “DevCo” or “LabsCo”) handles business operations, IP ownership, and equity issuance.
A decentralized autonomous organization (the “DAO”)—ideally an unincorporated nonprofit association—organizes token holder community functions, receives voluntary IP contributions, and provides liability protection.
The DAO holds no material treasury or binding control over DevCo; legal separation is maintained.
Token Locking as Technical Identity Infrastructure
DevCo offers voluntary token locking (L-TOKENs) that act as cryptographic identity credentials and eligibility signals.
Locking creates no automatic equity rights, no predetermined conversion, and no enforceable claim against DevCo.
Locked tokens enable non-binding voting and forum privileges and facilitate KYC/AML for equity application.
Documented Equity Pathways (the “Equity Bridge”)
DevCo issues equity only through established exemptions and separate documentation:
Regulation D (Rule 506(b)/(c)), Reg S, Reg CF/Reg A for investor sales.
Rule 701 for compensatory grants to contributors and advisors.
Token holders may apply for equity after locking tokens and completing KYC/AML, subject to DevCo discretion and documented processes.
Governance Distinction and Voting Mechanics
Token-based governance remains advisory for non-shareholders.
When a locked token holder is also a shareholder, voting tied to that token may be binding per DevCo’s operating agreement.
Only DevCo knows which locked token votes are binding (i.e., which locked token addresses correspond to shareholders).
Compliance and Disclosure Emphasis
Tokens are marketed and documented as utility/consumptive instruments in whitepapers and disclosures.
Equity issuance is separately documented and compliant with securities regulations.
KYC/AML requirements are applied prior to equity application/issuance, not to routine token purchases (subject to money-transmission rules).
D. DeSci as a Primary Use Case
DeSci (decentralized science) exemplifies why the C2C model is especially useful: tokenized participation can engage researchers, patients, and communities for research governance and data contribution, while equity enables institutional partnerships and capital formation necessary for translational R&D. Two illustrative organizations—DermaDAO and O'Ryan Health‑JDM—are used in Exhibit A to show C2C’s practical application in biotech and rare disease research.
II. THE C2C MODEL ARCHITECTURE
This section details the C2C model architecture, opportunities, limitations, and tradeoffs.
A. Dual-Entity Structure
The C2C model integrates a DAO (community organization) with a DevCo/LabsCo (operating company) and assigns distinct, limited roles to each.
1. The Decentralized Autonomous Organization (“DAO”)
Ideally organized as a U.S. unincorporated nonprofit association (UNA/DUNA) under Delaware or Wyoming law. [20][21]
Critical functions:
Liability protection for token holders (statutory shield for UNA members). [23]
IP assignment vehicle: voluntary contributions from token holders assigned to the DAO and then voluntarily contributed to DevCo to create a clear chain of title. [25]
Interest-group/advocacy organization: non-commercial coordination and community governance input. [26]
DAO should not hold material assets or perform business operations reserved for DevCo to avoid partnership or fiduciary exposure. [22][24]
2. The Development Company (DevCo / LabsCo)
Organized as a Delaware LLC with C Corporation tax election. [27]
Provides:
Corporate tax treatment and potential QSBS benefits. [28][29]
Traditional governance to satisfy institutional investors.
Full operational capability: IP ownership, employment, contract execution, equity issuance. [31]
DevCo creates and distributes tokens as utility goods but ensures tokens convey no equity or financial interest in DevCo.
B. Token Economics and Utility
Project tokens (“$TOKENs”) are designed to provide non-financial utility:
DAO membership credential: automatic, revocable, and non-economic. [32]
Network utility: access to platform features, payments, governance participation, identity/reputation signaling—genuine, disclosed, and non-financial. [33][34]
Locked token functionality: voluntary locking creates L-$TOKENs for identity infrastructure and eligibility signaling; locking creates no legal rights to equity. [35][36][37]
C. The Non-Option Nature of Locked Tokens
Locked tokens are intentionally structured to avoid classification as options or securities:
For options characterization, instruments typically need determined quantity and price and confer enforceable rights. [39]
Locked tokens lack a predetermined equity quantity, lack a strike/exercise price, and create no enforceable right to equity—DevCo retains discretion over any issuance. [40][41][42]
Precedent such as Gwozdzinsky and Lucente supports the design principle that fixed quantity/price and option periods are necessary for option characterization. [43][44]
III. C2C OPERATIONAL MECHANICS
A. Project Launch and Token Distribution
The C2C model prescribes a specific launch sequence to maintain separation between token distribution and equity offering. Presented here as a stepper:
Entity Formation
Founders form DevCo as a Delaware LLC electing C Corporation tax treatment.
Simultaneously establish the DAO as an unincorporated nonprofit association (UNA/DUNA).
DAO articles and membership agreement are public and explicitly state that token ownership conveys DAO membership but no economic interest. [45]
Token Creation and Whitepaper
DevCo creates tokens and publishes a whitepaper disclosing:
The dual-entity C2C structure
Token utility and functionality
Clear statements that tokens are not securities or investment contracts and that no securities are being offered in the token sale
The locked token mechanism
Potential future equity pathways (Rule 701, Regulation D, etc.) that are not current offerings
Intended DevCo operations without financial projections
Comprehensive risk disclosures
The whitepaper channels investment expectations to equity rather than tokens. [46]
Token Distribution
DevCo distributes tokens by:
Direct sales (fiat/crypto),
Airdrops,
Liquidity mining,
Compensation for services,
Or via third parties (e.g., nonprofit organizations undertaking fundraising with tokens).
Distributions are documented as commercial transactions with clear disclaimers that tokens convey no equity or profit rights. Proceeds go to DevCo or designated activities. [47]
B. The Equity Bridge: From Tokens to Shares
The Equity Bridge maps the pathway from locked tokens to potential equity issuance while maintaining legal separation. High-level steps:
Token locking (voluntary) for identity and eligibility. [50]
KYC/AML screening for locked token holders who wish to apply for equity. [52]
DevCo review and discretionary approval of equity applications. [54][55]
Equity issuance through compliant exemptions: Regulation D/Reg S/Reg CF/Reg A for investors or Rule 701 for compensatory grants. [56][62][63][64][66]
Key features of the bridge:
No automatic conversions or formulas; approvals are discretionary and separately documented. [55]
Equity issuances occur under standard securities law frameworks (Reg D, Rule 701), with appropriate filings and disclosures. [56][66][69]
C. Dual Participation: Token Holder and Shareholder
When a locked token holder becomes a shareholder, they occupy two distinct roles:
As DAO member (by token): advisory voting, protocol governance participation, voluntary IP contributions.
As DevCo shareholder (by equity): binding corporate governance rights, dividends, liquidation participation, statutory rights.
Roles are legally separate. Locked tokens serve as cryptographic credentials for on-chain governance and to coordinate corporate actions, but legal rights derive from documented equity ownership on the cap table. [76][77]
D. Exit and Liquidity
Token liquidity: unlocked tokens trade freely as commodities. [78]
Equity liquidity: shareholders face securities holding periods and restrictions (Rule 144, Reg S distribution compliance, QSBS holding periods, contractual transfer restrictions). [79][80][81]
Upon sale of equity, associated locked tokens are typically unlocked to maintain the identity-alignment principle. [82]
DevCo may tokenized corporate assets in the future (security tokens, dividend tokens), subject to compliance. [83][84]
IV. C2C LEGAL COMPLIANCE FRAMEWORK
A. Securities Law Analysis
The C2C model’s central legal proposition: tokens are not securities; equity is. Analysis under Howey and related precedent follows.
Tokens fail Howey prongs in C2C because:
Not a common enterprise in the requisite legal sense; purchasers buy a commodity/utility rather than pooling assets for pro rata returns. [86][87]
No expectation of profits derived from DevCo’s efforts—value driven by network effects, decentralized contributors, and market dynamics; explicit disclaimers and utility marketing reduce investment expectations (Forman precedent). [90][91][92][93]
Ripple decision supports programmatic sales and market-based value distinctions. [94][95]
Locked tokens are engineered to avoid being securities or options:
Lack of fixed equity quantity and price; absence of enforceable right to equity. [97][98][99]
Equity is plainly a security and is issued only through compliant exemptions (Reg D, Rule 701, Reg S, Reg CF/A). [100][101]
B. Anti-Money Laundering and KYC
FinCEN registration may be required if DevCo conducts money transmission activities. [102]
KYC/AML is mandatory for equity issuance to verify investor status, maintain cap table integrity, satisfy tax reporting, and perform OFAC screening. [103][104]
Routine token purchases need not involve KYC (unless other regulations apply, e.g., money transmission or exchange operator licensing), reinforcing token-as-commodity characterization. [105]
C. Tax Considerations
DAO tax status depends on structure; designed to avoid taxable income by not holding material assets or conducting commerce. [106][107]
DevCo elects C Corporation tax treatment, enabling entity-level tax, potential QSBS benefits for qualifying shareholders, and clean corporate tax identity. [108][109][110][111]
Token sales/purchases treated as property transactions (capital gain/loss) under IRS guidance for virtual currency and property. [113][114]
Equity grants trigger IRC § 83 analysis; Rule 701 grants have specific reporting and disclosure thresholds. [115]
V. C2C REGULATORY CONTEXT AND TIMING
Recent legislative, regulatory, and judicial developments make the C2C model timely.
A. The Responsible Financial Innovation Act (RFIA)
RFIA introduces “ancillary assets” and recognizes decentralized governance systems, aligning closely with C2C separation principles. [116][117][118][120][121]
RFIA includes safe harbors for gratuitous programmatic distributions but likely excludes discretionary DevCo-level distributions; C2C therefore relies on disclosure and alternative exemptions where applicable. [126][127][128][129][130]
B. SEC Project Crypto
SEC Chair Paul Atkins’ “Project Crypto” proposes a token taxonomy (Digital Commodities, Digital Tools, Digital Collectibles, Tokenized Securities) and affirms that many tokens fall outside securities regulation provided they are consumptive in nature. [131][132][133][134]
Atkins also indicated investment contracts can terminate (supporting temporal transformations), and previewed tailored “Regulation Crypto” frameworks—C2C’s disclosure-heavy approach aligns with these proposals. [135][136][137][138]
C. Judicial Developments: Ripple and Lido
Ripple: S.D.N.Y. distinguished institutional sales (investment contracts) from programmatic sales (not securities) for XRP, providing useful taxonomy lessons for C2C distribution design. [139][140][141]
Samuels v. Lido DAO: the court held an unstructured DAO could be a general partnership, exposing participants to joint liability—C2C mitigates this by using UNA/DUNA forms and separating DevCo operations. [143][144][145][146][147]
VI. CONCLUSION
The Coin-to-Company model offers a practical synthesis allowing projects to distribute tokens as utility assets while channeling investment capital through compliant equity pathways. It leverages established legal frameworks—unincorporated nonprofit associations, commodity/consumptive characterizations for tokens, and standard securities exemptions (Rule 701, Regulation D)—to permit domestic, regulated, and institutionally credible crypto-based enterprises.
C2C does not rely on speculative legal theories of temporal transformation or undefined “sufficient decentralization.” Instead, it operationalizes categorical separation, clear disclosure, voluntary token locking for identity infrastructure, and documented, compliant equity issuance processes that allow community participation to coexist with investor protection and institutional engagement.
EXHIBIT A
Detailed C2C DeSci Use Cases: DermaDAO and O’Ryan Health‑JDM
INTRODUCTION
This Exhibit illustrates how two decentralized science organizations—DermaDAO and O’Ryan Health‑JDM—could implement the C2C framework to address regulatory and capital formation challenges in DeSci. The mechanisms shown are proposed for discussion and may be adjusted to reflect evolving regulatory guidance.
Document Purpose: demonstrate structural application, token-equity separation, regulatory compliance, revenue alignment, and governance balance in practical DeSci examples.
PART I: DERMADAO — C2C APPLICATION TO CONSUMER SKINCARE RESEARCH
A. Project Overview and Regulatory Challenge
DermaDAO seeks to advance skincare science through community-governed research and product development while enabling institutional capital participation. The regulatory tension: distributing SKIN tokens for participation without creating unregistered securities, while enabling institutional investments via compliant equity.
C2C resolves this by issuing utility SKIN tokens for governance and access and issuing equity to qualified participants via Reg D/Rule 701/etc., maintaining clear separation and documentation.
B. DermaDAO’s Dual-Entity Structure Under C2C
Operating Company: DermaDAO LLC (Delaware LLC with C Corp tax election)
Holds and develops IP, conducts operations, hires staff, issues equity, and retains decision-making authority.
Community Organization: SKIN‑DAO (Delaware Unincorporated Nonprofit Association)
Token-holder membership, community governance (non-binding), IP capture via voluntary contributions, and legal separation from the LLC.
C. SKIN Token Structure and Consumptive Benefits
Core principle: SKIN tokens are utility instruments, not investment contracts.
Non-locked SKIN benefits include product discounts, early product access, research data access, participant recognition (NFT badges), token-gated content and forums, gas subsidies, and educational resources.
Locking SKIN => L‑SKIN (voluntary): enhanced advisory governance privileges, priority access to data, eligibility to apply for equity. Locking is reversible unless equity is issued; locking does not create enforceable equity rights.
D. The Equity Bridge: From Locked Tokens to Securities
Conceptual framework: locking signals commitment and eligibility; equity issuance remains discretionary and separate.
Three primary equity pathways (summarized):
Pathway A: Regulation D private placements (Preferred stock to accredited investors) — capital for product development; documented via subscription and investor rights agreements. [56][61]
Pathway B: Rule 701 compensatory grants (Class B Common for employees/researchers) — equity for bona fide services; subject to Rule 701 limits/disclosure and IRC § 83 tax considerations.
Pathway C: Rule 701 for advisory/IP contributors (Class A Common) — equity for advisors and contributors with IP assignment agreements.
Process for obtaining equity (operational steps) presented below as a stepper:
Equity Application and Review
Applicants submit formal applications describing desired equity class/amount and supporting documentation (services performed, IP assignments, proof of accredited status if applicable).
DevCo board evaluates and exercises sole discretion to approve or deny applications based on contributions, qualifications, equity pool, and cap table considerations. [54][55]
E. Governance Under C2C: Three Levels
Level 1 — Token-holder advisory governance (non-locked SKIN holders): on-chain non-binding voting (Snapshot, time-weighting, quadratic voting, delegation). Token holders cannot compel DevCo actions.
Level 2 — Enhanced advisory governance (L‑SKIN holders): priority consideration and broader advisory input; still non-binding.
Level 3 — Binding shareholder governance (equity holders): binding corporate authority per Delaware law and the operating agreement.
F. Revenue Models and Token Alignment
Revenue streams include D2C sales, subscriptions, data monetization, IP licensing, and retail partnerships. Token utilities (discounts, early access, research participation) align with revenue objectives—tokens build community demand and facilitate data collection, supporting commercialization and institutional partnering.
G. Exit and Liquidity Structure
SKIN token liquidity: free secondary market trading except when tokens are locked due to equity ownership. [78]
Equity liquidity: restricted securities subject to Rule 144, potential QSBS benefits for long-term holders, and standard contractual transfer restrictions. [79][80][81]
Exit scenarios: acquisition, IPO, or continued private operation with revenue distributions; tokens remain distinct from equity in each scenario.
PART II: O’RYAN HEALTH‑JDM — C2C APPLICATION TO RARE DISEASE RESEARCH
A. Project Overview and Regulatory Challenge
O’Ryan Health‑JDM aims to accelerate research for Juvenile Dermatomyositis via the Artemis Platform (home blood collection and high-resolution single-cell RNA sequencing). The regulatory challenge mirrors DermaDAO: enabling community participation via CRJDM tokens while attracting institutional capital for translation into diagnostics/therapeutics.
B. Dual-Entity Structure
Operating Company: O’Ryan Health‑JDM LLC (Delaware LLC, C Corp tax election) — owns IP, operates Artemis, conducts IRB‑approved research, issues equity, and manages partnerships.
Community Organization: JDM‑DAO (Delaware UNA/DUNA) — token-holder membership, community governance (non-binding), voluntary IP capture, legal separation.
C. CRJDM Token Structure and Consumptive Benefits
CRJDM tokens offer research data access, priority study participation, pre-publication review, platform features, commemorative NFTs, educational modules, and community networking.
Locking CRJDM => L‑CRJDM: enhanced advisory input, priority consideration, enhanced data access, and eligibility to apply for equity. Locking does not guarantee equity.
D. The Equity Bridge: Institutional Partnerships and Capital Formation
Three pathways:
Pathway A: Reg D (institutional investors; pharma/diagnostics/VCs) — preferred stock, liquidation preferences, strategic access to datasets.
Pathway B: Rule 701 Class B (research staff and employed contributors) — compensatory equity.
Pathway C: Rule 701 Class A (external academic collaborators, advisors) — equity for contribution and IP assignments.
Revenue flows include data licensing, IP licensing, research partnerships, grant funding, diagnostics, and therapeutic development. Equity investors obtain upside tied to commercialization, while token holders obtain research access and community benefits.
E. Governance Under C2C: Research‑Specific Structure
Three levels adapted for research:
Level 1 — Token-holder advisory governance (non-locked): research priorities and study design input; constrained by IRB protocols and regulatory boundaries.
Level 2 — L‑CRJDM holders: enhanced advisory weight; still non-binding.
Level 3 — Equity holders: binding governance, board oversight, research oversight committee, clinical advisory boards for IRB and regulatory compliance.
F. Path to Therapeutic Development and Revenue
Roadmap phases from infrastructure and data collection through biomarker discovery, clinical validation, and potential diagnostic/therapeutic commercialization—each requiring progressively larger capital inputs and offering corresponding revenue potential and investor returns.
G. Exit and Liquidity Structure
Token liquidity: CRJDM tokens trade freely unless locked by equity holdings.
Equity liquidity: restricted securities with Rule 144 holding periods and potential QSBS benefits.
Typical exits: acquisition by pharma/diagnostic firms, IPO in rare cases, or long-term private operation with revenue distributions.
PART III: COMPARATIVE ANALYSIS — WHY C2C IS UNIQUELY SUITED TO DESCI
C2C reconciles token-based community participation with institutional capital needs by separating utility (tokens) from investment (equity) while providing documented, compliant equity pathways.
Compared to traditional biotech models, C2C enables:
broader researcher and patient participation,
community alignment via tokens,
institutional confidence via familiar equity structures,
IP capture and downstream commercialization aligned to research contributions.
C2C aligns with FDA modernization (decentralized trials and patient-generated data) and emerging crypto regulatory trends (SEC Project Crypto, RFIA/CLARITY Act frameworks) and addresses legal risks highlighted by cases like Lido.
CONCLUSION (Exhibit A)
DermaDAO and O’Ryan Health‑JDM illustrate how C2C makes DeSci feasible: tokens enable participation and data collection; equity enables capital, governance accountability, and commercialization. The framework balances innovation with legal and regulatory prudence.
References and footnotes are preserved throughout the Article inline as bracketed citations (e.g., [1], [2], etc.) and correspond to the detailed references in the original document.