CTF Written Submission

Re: OTCM Protocol - Roadmap for Tokenized Securities on the Solana Ecosystem

Jan. 3, 2026
  • SEC should confirm that SEC-registered transfer agents may serve as qualified custodians for tokenized securities, ensuring regulatory oversight and compliance.
  • Establish guidance allowing tokenization of securities in markets abandoned by traditional infrastructure under existing exemptions when using SEC-registered transfer agent custody with verifiable 1:1 backing.
  • Clarify that public, permissionless blockchains (e.g., Solana) may be used for tokenized securities when paired with appropriate custody arrangements, without requiring permissioned alternatives.

Last Reviewed or Updated: Jan. 5, 2026