The SEC had recently clarified its stance on what would constitute securities in an initial coin offering and this article gives a good write up on what to expect.
Basically, the SEC stance is substance over form. It does not matter if you don't label your token a security. What matter is the economic reality of the underlying value of the token issued. As MAS usually takes guidance from MAS, it would hardly be surprising if Singapore too follow this interpretation in the future. Your comment will be posted after it is approved.
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