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>Is it a "promise" if it's a guaranteed algorithmic result?

No, and that's what decentralized staking is. That's fine and the SEC is explicitly not taking issue with it.

Centralized 'promising to engage in decentralized staking on a customer's behalf' is not guaranteed or algorithmic-- which is why it necessarily causes said customers to "take on risks associated with those [centralized] platforms," to quote the SEC, and thus becomes a security.



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