🚨NEW: The @SECGov just updated its crypto FAQ on token buybacks to add a stipulation that if there is no central party behind those token buybacks, then this arrangement likely does not constitute an investment contract.

It comes following comments from @a16zcrypto General Counsel and Head of Policy @milesjennings last week that the prior wording could “empower an issuer to announce the buyback program without that announcement then creating an investment contract.”