CTF Written Submission

Securities Industry and Financial Markets Association (SIFMA)

Nov. 26, 2025
  • Broad exemptions from federal securities laws for tokenized securities risk undermining investor protection, fragmenting markets, and creating regulatory arbitrage by allowing functionally identical activities to operate outside established oversight frameworks.
  • Entities performing intermediary-like functions in tokenized securities markets—whether centralized or decentralized—should be subject to the same regulatory obligations as traditional brokers, dealers, exchanges, and clearing agencies.
  • Any innovation exemption framework must be narrowly tailored, include investor and transaction limits, and be subject to public notice-and-comment rulemaking to ensure it supplements rather than substitutes for comprehensive regulation.

Last Reviewed or Updated: Nov. 28, 2025