The Internet reported that nearly 30 cryptocurrency advocacy groups led by the lobbying group Cryptocurrency Innovation Council (CCI) have asked the U.S. Securities and Exchange Commission to provide clear regulatory guidance on cryptocurrency pledges and pledge services. CCI's Proof of Stake Alliance (POSA) team pointed out in a letter on April 30 to Hester Peirce, head of the agency's Crypto Working Group and member of the U.S. Securities and Exchange Commission, that proof of Stake is fundamentally a technical process, not an investment activity. The coalition called on the Securities and Exchange Commission to support the responsible inclusion of pledge functions in exchange-traded products (ETP) and to "avoid establishing overly strict rules that could freeze market structures and stifle innovation in the pledge space." The organization believes that because the pledger retains ownership of its assets, the pledge does not meet the definition of an "investment contract" under the Howe Test for the definition of a security.