The U.S. Securities and Exchange Commission updated its crypto asset FAQ on September 28 to say an issuer's announcement of a buyback for a non-security crypto asset generally does not represent a promise of essential managerial efforts when the underlying system is functional and has no central party. The staff guidance, issued three days after the FAQ's initial release, remains fact-specific and does not exempt all token buybacks from securities-law analysis. For a nonfunctional system, a buyback announcement can be relevant to the Howey test when it is presented as generating yield or returns for holders. The clarification followed feedback from a16z crypto General Counsel Miles Jennings, who said earlier wording risked treating issuer buyback announcements as investment contracts. The FAQ also says work to secure, maintain, improve or expand a functional network generally is not essential managerial effort, while issuer marketing, continuing control and explicit commitments remain important. It addresses staking receipt tokens and says trading platforms do not become promoters merely by facilitating secondary-market transactions.