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SEC v. W.J. Howey Co.

investment contractHowey testsecurities definition
Forum
U.S. Supreme Court
Citation
328 U.S. 293 (1946)
Decided
1946-05-27
Judge
Justice Frank Murphy
Posture
On certiorari to the U.S. Court of Appeals for the Fifth Circuit
Agency
court
Status
Controlling. The 'Howey test' is the governing standard for whether an arrangement is an investment-contract security, and every crypto securities case below applies it.

Summary

The foundational securities-law case. The Supreme Court held that a sale of citrus-grove land coupled with a service contract was an "investment contract," and articulated the test now applied to digital assets: an investment of money, in a common enterprise, with a reasonable expectation of profits, derived from the efforts of others.

Holdings

What is an 'investment contract' under the Securities Act of 1933?

The Court defined an investment contract by its economic substance, not its form or label: an arrangement where one invests money in a common enterprise expecting profits from others' efforts. This functional test is what brings many crypto tokens within the securities laws.

Quote as reported (operator-verify): “a contract, transaction or scheme whereby a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party”

Source: Cornell Legal Information Institute · fetched 2026-06-04

Why it matters

Every U.S. crypto securities dispute turns on applying Howey to a token. The SEC's position that most tokens are investment contracts, and the court splits below (Ripple vs. Terraform), are all fights over how Howey's functional test maps onto digital assets.

Mortgage relevance

Indirect. Howey governs whether a crypto asset is a security, which shapes who regulates a borrower's holdings and how an exchange must be licensed: the backdrop to GSE "U.S.-regulated centralized exchange" eligibility language.

Operator-verify. This is a point-in-time summary, not legal advice. Quotes are sourced to the URLs above and have not yet been mechanically confirmed against the official opinion. Confirm any quote and holding against the court’s published opinion before relying on it.