Tokenized Securities Roadmap Calls for Flexible Models and Clear SEC Guidance

• A roadmap for tokenized securities has been formally submitted to the SEC.
• Multiple ownership and blockchain models can operate together on-chain.
• Clear, flexible regulation can strengthen U.S. leadership in digital asset markets.

A detailed roadmap for tokenized securities has been delivered to the SEC, marking a new step in the national conversation about how financial assets will move on-chain. Tokenization is advancing quickly around the world.

Many jurisdictions now test or deploy systems that place traditional assets on distributed ledgers. In the United States, however, progress has been held back by an argument that asks regulators to choose one winning model. That debate has created uncertainty and discouraged innovation.

The submission challenges that approach. It says direct registration, beneficial ownership, and linked security structure options all exist in the traditional world. They all have different purposes in mind. They all have their own sets of benefits for custody, transfer, and settlement. The letter states that these options exist together in the traditional world of capital markets but can co-exist in the blockchain world.

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Roadmap Calls for Multi-Model Tokenization Framework

The roadmap calls for the development of a framework to facilitate a broad range of tokenization activities. There needs to be a regulatory approach that accepts direct and intermediated forms of ownership.

There is also the need to collaborate on permissioned, permissionless, and hybrid blockchain networks. These different systems already in place in the market can be of great benefit in the processing of regulated financial products.

A second area of interest is the need for specific focus on the role of tokenization in transfer agents. Essentially, the transfer agent already has a clearly identified position in the recordkeeping business.

An enhancement of their position in the tokenized space may present a straightforward transition from the traditional framework to the blockchain framework. This letter also calls on the SEC to facilitate the general tokenization of the securities currently held at the Depository Trust Company.

Tokenization Roadmap Highlights U.S. Leadership Potential

The overall message is clear: the assets are going on-chain, and the United States can be a leader in the process if the country adopts flexible regulation. A public, permissionless blockchain would allow for this when properly applied. There would be a balance of market choices if there were a combination of different types of technology. This would reflect the long-standing values of the United States in terms of the principles of competition.

The letter ends by pledging to continue to support the SEC in its consideration of this transition. The way ahead will also involve a high degree of coordination. But the promise of improved markets appears to be there.

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