The SEC’s Division of Corporation Finance has added three questions to its crypto guidance, clarifying when governance arrangements, validator participation and network functionality may indicate centralized control. Voting on proposals or coordinating through a foundation does not by itself make participants a controlling group. The staff instead examines whether participants have agreements to act together outside the governance system and whether an individual or coordinated group controls network operations, economics or voting rights. Powers such as restricting network access, selecting validators, changing upgrade procedures or reversing transactions may weigh toward centralization. The guidance also separates a functional network, where a token performs its programmed utility, from a decentralized network that operates without control by a person or coordinated group. It remains staff guidance rather than a legally binding rule or Commission-approved classification, and does not automatically determine whether tokens such as UNI or networks such as XRP Ledger qualify as commodities.