Re: File No. 4-927, Order Granting Temporary Conditional Exemptive Relief (Release No. 34-106402) I am a co-founder of Vandergrid, a market maker and market surveillance provider in crypto asset markets. An affiliated venture is developing a venue for tokenized securities in the EU. We support the Order as a bridge to rulemaking and respond to Questions 3, 5 and 10. 1. Trading while the underlying is closed (Question 3) The IMF's October 2026 Global Financial Stability Report found that, for the tokenized stocks it studied, more than half of trading occurred outside regular U.S. market hours, about 80% of trades were for less than one share, and realized volatility was roughly 1.5 times that of the underlying. Overnight is when AMM pricing is weakest: a pool prices from its own reserves with no reference to the NBBO, and a liquidity provider cannot cleanly hedge a single stock while its primary market is closed. Pools then reprice through arbitrage at the open, and liquidity providers absorb the gap. We recommend (a) that TSVs publish, for each stock, the difference between the last pool price before the primary market opens and the opening price, so the effects the Commission asks about in Question 3 can be measured; and (b) that notice items s and cc describe how the TSV prices and protects pools while the underlying is closed, including any oracle, price band or dynamic fee. 2. Transparency data should include depth (Question 5) The Section G fields cover executed trades but not available liquidity. End-of-day pool size does not show what a participant could trade at a given price. We recommend adding a periodic depth measure, such as size available within set percentages of the pool price, and publishing per-TSV daily volume per stock in a common format so that volume and caps can be compared across unaffiliated venues. 3. Wash trading surveillance should be a condition (Question 5) Item bb allows a TSV to state that it does no monitoring for wash trading, spoofing or front-running. TSV volume feeds directly into the Section F caps and is the main quality signal participants see, and permissioning does not prevent self-trading through multiple linked wallets. We recommend that monitoring for self-trading and trading between linked wallets be a condition rather than a disclosure, with results kept under Section L. 4. Covered Firm incentives (Question 10) Covered Firms must keep records of fees, rebates and incentives, including volume-linked compensation. In crypto markets, volume-linked compensation is a well-known driver of manufactured volume. We recommend that the public disclosure under the Covered Firm conditions state whether any compensation from a TSV or issuer is linked to traded volume, and that the liquid-assets record be assessed against a gap at the reopening of the underlying, where a Covered Firm's losses are most likely to concentrate. Disclosure of interest: Vandergrid provides market making and surveillance services in crypto asset markets, and holds an interest in a venture developing a tokenized securities venue. These comments are submitted on behalf of Vandergrid. Sushant Kumar Co-founder, Vandergrid