CTF Written Submission

Daniil Ulanovich, Setmos Inc.

Dec. 1, 2025
  • Existing federal securities laws (e.g., Securities Act of 1933, Exchange Act of 1934, Investment Company Act of 1940) do not consistently apply to the digital access layer through which institutions engage with tokenized real-world assets (RWA), resulting in fragmented oversight and uneven disclosure standards.
  • The letter proposes a non-licensing federal framework to standardize expectations for digital access platforms—covering yield presentation, lifecycle reporting, and eligibility criteria—without altering the regulatory treatment of the underlying assets.
  • A new recognition category is suggested for digital platforms that facilitate access to tokenized exposures, aiming to clarify their role without imposing broker-dealer or custodian obligations, thereby improving regulatory clarity and market integrity.

Last Reviewed or Updated: Dec. 1, 2025