The SEC Division of Corporation Finance stated in a new FAQ that maintenance, upgrades, and feature enhancements for functional crypto networks generally do not constitute "essential managerial efforts" under the Howey test. The guidance clarifies that funding or sponsoring development for operational systems typically does not satisfy the corresponding elements of the securities law framework. The FAQ further indicates that staking receipt tokens evidencing ownership without altering rights may be classified as digital instruments or commodities when issued by protocol-based liquid staking providers. Buyback programs for non-security assets on functional networks are also generally excluded from essential managerial efforts, unless the network is pre-functional and returns are promoted to holders. The SEC emphasized this guidance represents staff views only and carries no legal force.