The chief legal officer of Coinbase Inc. submitted another round of concerns with the U.S. Securities and Exchange Commission on Monday over the agency’s proposal to expand the definition of “exchange.”

Paul Grewal, the chief legal officer of Coinbase, said the SEC’s proposal to amend the definition of “exchange” under Exchange Act Rule 3b-16 failed to include critical analysis, rested on irrational assumptions, failed to show that there is any problem in need of regulation and vastly overstated the proposal’s purported benefits.