CTF Written Submission

Modernizing Transfer Agent Rules for U.S. Leadership in Tokenized Securities

April 25, 2025
  • The memo urges the SEC to issue interpretive guidance clarifying that ancillary actors in decentralized blockchain systems are not considered transfer agents.
  • It recommends using the SEC's exemptive authority to create blockchain-based exemptions to existing transfer agent registration mandates.
  • The memo suggests exploring smart contract equivalency to fulfill specific transfer agent functions and establishing standards for blockchain record-keeping systems.

Last Reviewed or Updated: April 25, 2025