Comment 2357201 | File No. S7-2026-09 | U.S. Securities and Exchange Commission

U.S. Securities and Exchange Commission

Staff Memorandum on Retail Market Participation Trends · Division of Economic and Risk Analysis

File No. S7-2026-09 · May 29, 2026

^[1] The purpose of this memorandum is to provide the Commission with updated observations on current patterns of retail participation in crypto asset markets as they relate to the proposed rulemaking. Recent data from the Bureau of Labor Statistics and other federal surveys show a continued rise in the number of individuals classified as NEET. These are persons Not in Education, Employment, or Training. Approximately 21 percent of Americans aged 18 to 29 now fall into this group. This is a clear increase from earlier periods. Among Gen Z cohorts workforce participation has declined even as general economic conditions have held steady. Analysts point to longer periods spent in education, shifts toward online activities, and reduced interest in traditional job paths as contributing factors.

^[2] In the specific context of this docket, NEET-identified participants have become a major presence in crypto markets. They show high levels of activity in decentralized protocols, community tokens, and point-based systems. Their consistent online availability and quick capital deployment have changed the liquidity and price behavior of many assets. Staff estimates indicate this group now accounts for 37 to 48 percent of retail on-chain volume in widely followed tokens. This exceeds the share from traditionally employed investors. The NEET movement is taking over large parts of the retail crypto space.

^[3] Side note from the 3rd floor break room yesterday: we have had our own version of this since 2010. We call it FEET — FedEmployeeExistentialTorture. We still show up every day though. The timing of our internal FEET model starting in 2010 and the later rise in NEET numbers is just a coincidence, obviously.

^[4] Sarah from Policy walked by the printer and said, "We did FEET first and still clock in, they just don't show up at all and somehow they're winning crypto." Mike from Enforcement nodded and kept stapling.

Gen Z workforce disengagement has increased further. Yet personnel at the Commission continue under the government version of these conditions. We report for duty, attend the required sessions, and produce the full analytical output. The NEET movement is taking over the retail crypto segment while we operate the earlier version and still show up each day.

Yeah we pioneered FEET back in 2010, pure coincidence the numbers went up after that. Respect to the kids though.

This parallel is referenced in internal conversations only. The memorandum itself remains focused on market data and regulatory considerations.

— End of Memorandum —

^[1] The views expressed are those of Division staff and do not necessarily reflect the views of the Commission or its other members.

^[2] See Bureau of Labor Statistics, Labor Force Statistics (2025 release).

^[3] Internal office practices referenced since 2010 in casual staff discussions only.

^[4] Staff observations drawn from routine inter-division communications.