CTF Written Submission

RE: Custody of Tokenized Securities by Clearing and Carrying Broker-Dealers

May 5, 2025
  • The document emphasizes the need for the SEC to differentiate between Bearer Digital Asset Securities (BDAS) and Tokenized Securities in its regulations, as the risks associated with BDAS do not apply to Tokenized Securities.
  • It argues that Tokenized Securities should be treated like traditional securities if they incorporate key safety attributes, such as maintaining a redundant secondary record on the blockchain and not being issued in bearer form.
  • The document urges the SEC to provide new interpretive guidance or no-action relief to allow broker-dealers to use issuers or transfer agents as control locations for Tokenized Securities, facilitating scalable solutions for clearing and custody.

Last Reviewed or Updated: May 6, 2025