CTM recommends practical changes to accommodate tokenized funds and securities while preserving investor protections and clear accountability.
WASHINGTON, D.C. — October 29, 2026 — The Coalition for Tokenized Markets (CTM) has submitted a comment letter to the U.S. Securities and Exchange Commission supporting its proposed modernization of transfer agent rules and recommending refinements to ensure the final framework accommodates both conventional and tokenized securities.
In its October 29, 2026 letter, CTM welcomes the SEC’s express recognition that blockchain or other distributed ledger technology can serve as all or part of the official securities ownership record. The Coalition urges the Commission to carry that technology-neutral approach throughout the final rules.
CTM’s response centers on a fundamental principle: tokenization changes the technology used to maintain ownership records, but it does not change the legal nature of a security or the rights of its holder. Regulatory requirements should therefore focus on the outcomes transfer agents must achieve, with clear responsibility for maintaining accurate records and protecting investors.
CTM’s principal recommendations include:
Maintaining technology neutrality: Frame requirements around regulatory outcomes so conventional and tokenized transfer agents that achieve the same results receive equivalent treatment.
Clarifying control over ownership records: Define “exclusive control” by a transfer agent’s authority over the official record, rather than control of the underlying blockchain infrastructure.
Allowing flexible securityholder identification: Require the information reasonably necessary to identify and contact investors, rather than prescribing fixed data fields such as physical mailing addresses.
Connecting tokenized and conventional holdings: Permit arrangements that accommodate both formats within the same securities issue, with clearly defined responsibilities and liability for the transfer agents involved.
The letter also requests technical clarifications addressing distributed ledger recordkeeping, corrections to immutable records, automated transfer rejection notices, safeguarding investor funds, and transferring records to successor transfer agents.
CTM emphasizes that modernization should allow market participants to adopt new technology while preserving accurate ownership records, operational resilience, and accountability. The Coalition welcomes continued engagement with SEC staff to share how its members operate tokenized recordkeeping systems in practice.
About the Coalition for Tokenized Markets (CTM)
The Coalition for Tokenized Markets (CTM) is a U.S. and transatlantic industry coalition of asset managers, financial institutions, and technology and infrastructure providers working to advance the responsible development of tokenized securities and funds. CTM engages with policymakers and regulators across the United States and Europe to promote technology-neutral regulation, interoperability and common international standards, an expanded and trusted permissioned-wallet ecosystem, and the recognition of tokenized funds as eligible collateral. Founding members include WisdomTree, Janus Henderson, Franklin Templeton, and JP Morgan Asset Management.