CTF Written Submission

GUARDD, Inc.

May 14, 2025
  • The SEC should recognize modern disclosure platforms under state manual exemption regimes to replace outdated paper-based publishers, facilitating lawful secondary trading of tokenized and exempt securities.
  • The SEC should permit broker-dealers and ATSs to rely on structured digital disclosures under Rule 15c2-11, enhancing compliance and transparency in secondary markets.
  • The SEC should extend federal preemption to secondary trading of securities from issuers current in Reg A reporting, particularly when such reporting is conducted via structured platforms like GUARDD.

Last Reviewed or Updated: May 14, 2025