Sep. 7, 2026
Subject: Comments Subject: Comments on Proposed Rule: Transfer Agent Modernization (File No. S7-2026-30) To: Ms. Vanessa A. Countryman, Secretary U.S. Securities and Exchange Commission 100 F Street NE, Washington, DC 20549-1090 Submitted via Electronic Mail: rule-comments@sec.gov Dear Ms. Countryman, I am writing to express my strong support for the Commission's proposed rule package to modernize transfer agent regulations (File No. S7-2026-30). This regulatory overhaul is a necessary step to update a system that has not been substantially altered since the early 1980s. I strongly agree with the inclusion of Distributed Ledger Technology (DLT) within the operational framework of Registered Transfer Agents. As an individual investor, I believe the following elements of the proposal are critical to ensuring fair, transparent, and resilient capital markets: 1-to-1 Blockchain Integration: I support formalizing DLT as a recognized method for maintaining the "Master Securityholder File." By ensuring that a public company's registry can live on a cryptographically secure, transparent ledger verified exclusively by a registered transfer agent, the Commission can eliminate the opacity that allows synthetic, unbacked share positions to exist in the shadows of the market. Elimination of Offshore Synthetic Arbitrage: Recent market events-such as the creation and overnight supply manipulation of unregulated offshore tokenized equities pegged to U.S. listings-demonstrate the severe systemic risk of parallel, unbacked markets. The SEC must mandate that any third-party tokenized instrument tracking a U.S. security be mapped 1-to-1 with the official transfer agent ledger. Unbacked synthetic derivatives operating without transfer-agent verification should be classified as fraudulent. Infrastructure for Digital Distributions: I strongly support the inclusion of digital wallet addresses as valid securityholder registration points on the official ledger. This framework provides public companies with a reliable, legally protected path to distribute non-replicable digital assets and blockchain-based distributions directly to their registered shareholders, bypassing the conflicts of interest often found at the broker-dealer level. The retail investment community demands transparency and mathematical accountability. This proposal provides the exact framework needed to align market infrastructure with modern technology. I urge the Commission to finalize these rules swiftly without weakening the provisions regarding ledger integrity and transfer-agent control. Thank you for your time and consideration of the views of individual retail investors. Sincerely, Courtney T Nisbett East Bay Regional Parks Oakland CA