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On April 3, 2019, the SEC’s Strategic Hub for Innovation and Financial Technology (“FinHub”) issued a long-awaited framework for analyzing whether a given digital asset constitutes a “security” under federal law and is thus subject to the vast complex of federal securities laws and regulations.  Simultaneously, the SEC’s Division of Corporate Finance issued its first “no-action” letter for a digital token offering, stating that it will not recommend enforcement action to the Commission based on…