> If I had to guess, the SEC is actually saying "you are offering many products, and _way too many of them_ are securities. We will not list them all because it

> If I had to guess, the SEC is actually saying "you are offering many products, and _way too many of them_ are securities. We will not list them all because it would be way too much work. We will not list one because we don't want you to overfit on the example. We want you to actually do the analysis across all of your products". But to issue a Wells notice shouldn’t they have already performed this research? Seems like both parties benefit by saying something like: Products with X, Y or Z characteristics as defined by Laws 1, 2 & 3 are securities, including but not limited to products A, B and C, etc.