CTF Written Submission

Re: SEC Tokenized Securities Framework – Issuer-Sponsored Tokens & The Depository Trust Company (“DTC”)

July 27, 2026
  • Regulatory leadership is required to ensure interoperability and neutral treatment between issuer-sponsored tokens (ISTs), Direct Registration System (DRS) holdings, and DTC-issued entitlement tokens, so all forms of book-entry ownership are treated equivalently as far as legally and operationally feasible. 
  • The SEC should promote enhancements to DTC systems and processes to remove friction and establish efficient, timely movement of securities between DTC custodial positions and directly registered book-entry positions, supporting investor protection and market fairness.
  • The Commission is urged to facilitate collaboration between DTC and transfer agents to future-proof system upgrades, ensuring effective integration and interoperability of tokenized securities within traditional and digital market infrastructure, thereby minimizing liquidity fragmentation and operational barriers. 

Last Reviewed or Updated: July 28, 2026