CTF Written Submission

Re: Tokenized securities – the record behind the register

Sept. 10, 2026
  • The SEC’s transfer agent proposal allows blockchain-based master securityholder files, but does not address the need for a verifiable, dated, sourced issuance record that documents the facts about the issuer and asset—these facts are often missing or scattered, causing tokenized offerings to stall.
  • A robust issuance record should: (1) link every material fact to its source document, (2) timestamp each fact, (3) distinguish the type of evidence (issuer assertion, third-party review, authority issuance), and (4) preserve all versions without overwriting prior states.
  • The proposal’s requirements for exclusive control do not necessarily exclude public blockchains; transfer agents can maintain authority via smart contracts, and reconciliation between onchain and offchain records should be documented and explained, not prohibited.

Last Reviewed or Updated: Sept. 10, 2026