CTF Written Submission

Re: Support for Coinbase Global Inc. – Letter on Third-Party Tokenization of Publicly Traded Securities

April 13, 2026
  • SEC should not require issuer consent for third‑party tokenization because existing securities law frameworks already allow secondary‑market infrastructure to develop without issuer approval, and imposing such a requirement would create an unjustified barrier to lawful market activity.
  • Conditioning tokenization on issuer consent would distort competition by granting incumbents an effective veto over settlement infrastructure, contrary to principles of technology‑neutral regulation and the SEC’s historical approach to secondary‑market operations.
  • A time‑ and volume‑limited innovation exemption would allow the SEC to evaluate tokenized securities in real‑world conditions while avoiding overbroad regulatory changes and ensuring consistent, principles‑based treatment across tokenization models.

Last Reviewed or Updated: April 13, 2026