CTF Written Submission

Re: And Then Some: Request for Information Regarding National Securities Exchanges and Alternative Trading Systems Trading Crypto Assets

June 18, 2026
  • The response advocates for a technology-neutral regulatory framework, emphasizing that rules should focus on regulatory outcomes (such as investor protection and market integrity) rather than prescribing specific technological means, and that principles-based standards are preferable to prescriptive requirements.
  • tZERO recommends rescinding the SEC’s “Three-Step Process” for ATS settlement of digital asset security trades, arguing that recent regulatory guidance now permits broker-dealers to custody crypto asset securities directly, making the previous workaround obsolete and unnecessarily restrictive.
  • The document proposes targeted amendments to existing forms (Form ATS and Form ATS-N) to clarify disclosure requirements for crypto asset security ATSs, rather than creating new forms, and suggests that public blockchain records should satisfy regulatory reporting and recordkeeping obligations, reducing duplicative compliance burdens.
     

Last Reviewed or Updated: June 22, 2026