The SAFT may be unneeded and very expensive but great for law firm billables.

The SAFT wants to eliminate the utility token argument. Many tokens are NOT securitites and are more like metrocards and software licenses, however the SAFT doesn't care and essentially creates a securities where there is not. As Cooley admits in the whitepaper, the token is often not the security while the SAFT always is. So then why add such a regulatory burden and why limit the amount you can raise and who you can offer to (only Accredited Investors (i.e. high net worth)? (rhetorical question)

Furthermore, what protections do the SAFT provide once the tokens are delivered? Are the tokens now treated as restricted securities, meaning that you must hold your tokens for a year or more before selling them? That seems like a major drawback for anyone buying tokens for short to medium term investing.

SAFT may also create more problems than it solves. Such as...

Can SAFTs be swaps? A swap is an agreement in which (among other variations) one party pays cash and the other party delivers cash, securities, or other consideration in an amount based on the economic performance of a specific security or other asset. Although the CFTC has not yet issued official guidance, we currently believe that most SAFTs should properly be treated as forward purchase agreements rather than as swaps. If SAFTs are swaps, they generally could be purchased only by investors with $10 million in assets, which is considerably higher than the $1 million net-worth test for "accredited investors" under the federal securities laws.

SAFT must go away in many cases, maybe it is opportunistic for big law. It is not always a good fit for utility ICOs, crypto and blockchain technology startups.