Dear SEC Committee Members, Turnqey builds the data infrastructure that registered investment advisers and wealth platforms use to see, reconcile and report on client crypto and tokenized assets held across exchanges, custodians and self custodied wallets. We support the Innovation Exemption. We are writing because our work sits exactly where this order will create new problems, and we would rather the Commission hear about them now than in year three. The order will fragment trading in tokenized NMS stock by design. Symbol and volume caps per venue, notify and operate entry, and permissionless settlement rails mean the same share will trade on several venues and several chains at once, with no consolidated tape, no central clearing and no single custodian. We think it is the point, and we think it is workable, if the record that ties those venues together is made available to the people who carry fiduciary and tax reporting duties for the investor. Today it’s not. Our recommendations follow. 1. Require a public, machine readable venue record. Each TSV's public notice should include a published registry of the token contracts it trades, mapped to the underlying security's CUSIP and FIGI, with the chain, contract address and the tokenizer's identity. A TSV should also publish trade and liquidity pool data in a documented, machine readable form. Without this, an adviser cannot tell which contract is the issuer backed share and which is something else, and the rights parity verification the order requires is unverifiable from outside. 2. Make corporate actions traceable across venues and chains. The order requires holders of tokenized NMS stock to receive the same rights as the traditional class. Dividends, splits, ticker changes and mergers therefore have to reach every token contract on every chain, on the same terms and on the same dates. We recommend that TSVs and tokenizers publish corporate action events in a standard form, keyed to the same identifiers as the venue record, so that an adviser reconciling a client's position across three venues can prove the client was treated like every other shareholder. 3. Clarify cost basis and transfer reporting for self custodied tokenized stock. A share bought on one TSV, moved to a self custodied wallet and sold on another TSV has no broker in the middle to carry basis. The traditional answer, transfer statements between brokers under Section 6045A, has no onchain analog. We ask the Commission to work with Treasury on a basis carrying standard for tokenized NMS stock, and in the meantime to require TSVs to make each participant's own fills available to that participant and their designated adviser through a documented interface. Advisers will reconcile these positions whether or not the data is offered. The question is whether they do it from primary records or from screenshots. 4. Publish halts and dislocations, not just trades. The order requires a TSV to halt when the primary listing exchange halts. Advisers and investors also need to know when a venue's pool price has moved away from the NBBO for the underlying, and when a venue has paused, resumed or changed its access standards. We recommend a public, timestamped event log for halts, pool parameter changes and access-standard changes, published by the TSV alongside its trade data. 5. Give the investor's adviser standing. Permissioned access is sensible for trading. It should not block read access. A holder should be able to designate an adviser or reporting agent that can read the holder's fills and positions on a TSV without being a trading participant. Registered advisers already carry books and records and fiduciary obligations for these assets; the order should not make those duties harder to discharge than they are at a traditional broker. Fragmentation is not the risk. Unreconcilable fragmentation is. If the venue record, corporate actions, fills and halts are published in a form a machine can read, the market can absorb dozens of venues and investors will be better served than they are today. If they are not, the five year experiment will produce a generation of tokenized positions whose basis nobody can prove. We would welcome the chance to discuss any of this with the Division of Trading and Markets and to share what we see in advisers' reconciliation data as venues come online. Respectfully submitted, Tyrone Ross Chief Executive Officer, Turnqey