CTF Written Submission
SIFMA SEC Rule Inventory
Dec. 22, 2025
- Across the SEC’s Investment Advisers Act, Investment Company Act, Securities Act, and Exchange Act rules, the legal and regulatory requirements generally apply equally to traditional and tokenized assets. The rules governing registration, disclosure, custody, recordkeeping, anti-fraud, and investor protection are not fundamentally altered by the use of tokenization or digital asset formats. Where tokenized assets are securities, they are subject to the same substantive regulatory regime as their non-tokenized counterparts.
- For investment advisers and investment companies, custody rules (e.g., IAA Rule 206(4)-2, ICA Rules 17f-1 through 17f-7) require that client assets—including tokenized securities—be held with qualified custodians and subject to the same segregation, audit, and reporting requirements as traditional securities. Self-custody of tokenized assets by advisers is not subject to lesser requirements, and banks acting as custodians for tokenized assets must meet the same standards as for other securities.
- The core disclosure, reporting, and anti-fraud provisions of the federal securities laws (including the Securities Act, Exchange Act, and related SEC rules) apply to offerings, trading, and custody of tokenized securities. This includes requirements for registration statements, prospectus delivery, periodic reporting, proxy rules, and prohibitions on manipulative or deceptive practices. The SEC’s authority and investor protections are not diminished by the use of tokenized or digital asset technology.
Last Reviewed or Updated: Dec. 23, 2025