The Model that Was Halted Today is The Norm: The Contradiction that The System Can No Longer Hide

By: Pablo Rutigliano

Founder of Atómico 3

What was yesterday questioned, today is incorporated. The evidence is no longer technical; it is structural.

In the processes of real economic transformation, systems usually react in the same way: first they ignore, then they resist, and finally they incorporate that which they could not interpret in time. It is not an anomaly. It is a pattern.

The recent initiative promoted by the National Securities Commission (CNV), under the presidency of Roberto E. Silva and its Board, regarding crowdfunding and investor segmentation, clearly confirms this process.

What is presented today as the modernization of the capital market—the enabling of crowdfunding within automatic public offering schemes, investor participation under defined limits, and the creation of a specific regime for super-qualified investors—represents a paradigm shift.

But that change is not born today.

On May 30, 2025, within the framework of a formal requirement from the regulatory body itself, a technical, economic, and legal document was presented that developed a comprehensive financing architecture based on the tokenization of real-world assets (RWA), expressly incorporating crowdfunding mechanisms, economic traceability, and distributed participation within a transparent and auditable scheme.

That model was not conceptual. It was operational.

In it, it was clearly established that the participants of the ecosystem—holders—could interact within crowdfunding schemes through the placement of funds, participation mechanisms, and financing structures linked to real assets, all under principles of transparency, auditability, and technological traceability.

This point is fundamental.

Because the proposed design did not configure traditional financial instruments or negotiable securities in the classic terms of the system, but rather a technological platform for economic articulation, where the primary function was not financial speculation, but the connection between real assets and distributed financing.

At the same time, it was proposed to move toward more agile schemes, reducing unnecessary regulatory friction, through automated processes supported by blockchain technology, without at any time affecting user protection or transparency standards.

Today, those same principles are beginning to be reflected in the regulations.

The enabling of crowdfunding within automated schemes, investor segmentation, and operational flexibility are not new concepts. They are structural elements of a previously presented model.

And it is here where the issue ceases to be technical to become institutional.

Because when a model is presented, analyzed, and subsequently its foundations are incorporated within the regulatory framework itself, it becomes necessary to evaluate the coherence of the regulatory process as a whole.

It is not a matter of questioning evolution. Evolution is necessary.

But it is a matter of pointing out that an evident sequence exists:

First, the model is observed, stressed, and limited in its development.

Then, that same model—in its essential principles—is incorporated as part of the regulatory solution.

And in that process, those who drove the innovation remain exposed to scenarios of uncertainty, suspension, and questioning.

This point cannot be ignored.

Not from a confrontational logic, but from a perspective of legal certainty and institutional consistency.

Because trust in the markets is not built solely with new rules, but with coherence in the application of criteria over time.

When the system incorporates that which it previously did not recognize, without reviewing the previous process, a structural tension is generated: innovation goes from being an engine of change to becoming a risk for those who develop it in early stages.

And that is the real problem.

Innovation is not born within the State. It is born outside of it.

Regulatory bodies fulfill a fundamental role in ordering, validating, and framing those processes. But that framing must occur with predictability, balance, and respect for previous developments.

The case of crowdfunding in Argentina reflects this point with precision.

What is today enabled as a tool to expand access to the capital market had already been conceived as a mechanism to democratize investment in real assets, integrating technology, traceability, and distributed participation.

The difference is not in the concept.

It is in the moment in which that concept is recognized.

And in how that recognition impacts those who promoted it.

This analysis, by its nature, must be addressed within the corresponding institutional and judicial frameworks, avoiding any prejudgment and respecting the processes in progress.

But that does not prevent affirming an objective reality:

The principles incorporated today—structured crowdfunding, automation of processes, investor segmentation, and technological traceability—were already part of a previously developed and presented model.

And that fact, by itself, raises the need to move toward a system that not only incorporates innovation when it becomes inevitable, but is also capable of recognizing it the moment it arises.

Because ultimately, the future of the capital market does not depend solely on the regulations that are issued.

It depends on the trust that the system is capable of generating.

And trust is not born when the system adopts what it previously did not understand.

It is born when it is capable of recognizing it.