Re: File No. 4-927 - Innovation Exemption for Tokenized NMS Stock Persistence Analytics Group LLC (PAG) appreciates the opportunity to comment on the Commission's temporary conditional exemptive relief for Tokenized Securities Venues. PAG develops written Decision Assurance analyses for consequential decisions that depend on representations, technical systems, external dependencies, and changing operating conditions. PAG's principal recommendation is that the Commission distinguish initial compliance with the Innovation Exemption from continuing evidentiary sufficiency after material change. The Order appropriately requires, among other things, that tokenized NMS stock provide holders with the same rights and privileges as the equivalent traditional NMS stock and that relevant smart contracts be auditable and publicly deployed. PAG recommends adding an explicit revalidation principle: A determination that a tokenized security, venue, or supporting architecture satisfies the conditions of the exemption at one point in time should not automatically be treated as permanently current after a material change. PAG's working architecture is: Representation -> Assumption -> Evidence -> Dependency -> Downside Ownership -> Decision Gate -> Material Change -> Revalidation Applied to tokenized NMS stock, the record should identify where practicable: - the rights and privileges represented as equivalent to the underlying NMS stock; - the evidence supporting that equivalence; - the smart-contract version and relevant logic; - custody and beneficial-ownership structure; - transfer-agent or recordkeeping dependencies; - wallet, key-management, settlement, and blockchain dependencies; - stablecoin or payment dependencies; - corporate-action handling; - issuer-objection status; - trading-halt synchronization; - material third-party dependencies; and - conditions requiring targeted revalidation. Potential material-change triggers could include: - smart-contract modification; - change in token issuer or administrator; - change in custody or recordkeeping structure; - change in underlying shareholder rights; - change in transfer-agent relationship; - change in settlement or wallet architecture; - change in stablecoin or payment mechanism; - change in corporate-action processing; - change in access-control or participant-permission logic; - material cybersecurity or operational incident; - change in blockchain or other critical technical dependency; or - new evidence that materially affects the prior equivalence determination. The key distinction is: Initial equivalence is not necessarily continuing equivalence. A tokenized NMS stock may remain technically tradable while one of the assumptions or dependencies supporting the original determination that it provides equivalent rights has materially changed. PAG therefore recommends that Tokenized Securities Venues maintain a concise Reliance and Revalidation Record identifying: 1. the proposition being relied upon; 2. the evidence supporting it; 3. material dependencies; 4. the decision or exemption condition supported by that evidence; 5. material-change triggers; and 6. the evidence required for targeted revalidation. This would not require continuous full recertification. The objective is to make it administrable to determine when a prior determination remains current and when a material change requires targeted review. PAG does not propose that the Commission adopt PAG's proprietary scoring, weighting, thresholds, durability analytics, or determination logic. The narrower recommendation is to preserve traceable evidence of equivalence, dependencies, material change, and revalidation throughout the period of exemptive relief. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC Decision Assurance | Infrastructure Assumption Verification Evidence before reliance. Revalidation after material change. neil@persistenceanalyticsgroup.com InfraGard Member SAM.gov Registered Vendor UEI: D3VYU39H6DX9 CAGE: 19T34