# Tokenized securities for advisors: what the holder actually owns

> A tokenized share can be the share, a pointer to the share, a custodian’s entitlement, or a note or swap that pays like the share. SEC staff named the four in January 2026. The file has to say which one the client holds.

- URL: https://riadefi.com/asset-classes/tokenized-securities/
- Section: Asset classes
- Author: Jon Ragsdale
- Reviewed: 2026-09-23

Reader objective: Tell which model a tokenized share is, who keeps its official record, and how the position fails.

## What the SEC did, in order

Between December 2025 and September 2026 the SEC and its staff took ten actions that decide what a tokenized share is, who keeps its record, and where it may trade. Two cautions first. Staff statements and no-action letters are staff views: the January statement says it “has no legal force or effect.” And a proposed rule binds no one until the Commission adopts it.

| Date | Action | What it means for a client’s file |
| --- | --- | --- |
| 2025-12-11 | Trading and Markets staff no-action letter to DTC Ledger entry | DTC may let its participants tokenize their holdings of Russell 1000 stocks, Treasury bills, notes, and bonds, and ETFs that track major indices. The letter lapses three years after launch. |
| 2026-01-28 | Statement on Tokenized Securities , three SEC divisions Ledger entry | Names the models: issuer-sponsored (on-chain or off-chain record), third-party custodial, and third-party synthetic. |
| 2026-02-23 | WisdomTree exemptive order, Release IC-35968 Ledger entry | A registered government money-market fund’s tokenized shares may be bought and sold by an affiliated dealer at $1.00 a share. The order covers the dealer’s price, not how the fund uses a blockchain. |
| 2026-03-18 | SEC staff approve Nasdaq rule under delegated authority, Release 34-105047 Ledger entry | A tokenized share trades on the same order book as the ordinary share only if it has the same CUSIP, symbol, and rights. Settlement stays T+1 through DTC. |
| 2026-04-09 | NYSE files an immediately effective rule, Release 34-105260 | The same trading in tokenized form, tied to the DTC pilot. |
| 2026-07-15 | DTCC processes production trades in DTC-tokenized assets | More than 30 firms took part. DTCC plans to launch the service in October 2026. |
| 2026-08-12 | Investment Management staff no-action letter to Franklin Templeton Ledger entry | Franklin’s own funds may hold shares of its tokenized money fund with Franklin’s affiliated transfer agent as custodian, under twelve conditions. Franklin argued that custody turns on control of the official record, not of a wallet key; the staff granted relief without adopting that view. |
| 2026-09-01 | Transfer Agent Rules proposed, Release 34-106246 Ledger entry | A blockchain may form part of the official list of owners if the transfer agent keeps “exclusive control.” Published in the Federal Register 2026-09-04; comments due 2026-11-03. |
| 2026-09-17 | Innovation Exemption order, Release 34-106402 Ledger entry | Permissioned on-chain venues may trade tokenized listed stock until 2031-09-17. Synthetic tokens are excluded by definition. |
| 2026-09-21 | ARK Venture Fund order, Release IC-36333 Ledger entry | A registered closed-end fund may offer a class of tokenized shares traded on alternative trading systems. |

## Four models, in advisor terms

The January statement sorts tokenized securities by who does the tokenizing. If the issuer or its agent does it, the security is issuer-sponsored. If an unrelated firm does it, the security is third-party-sponsored. Each side splits in two.

**The token is the share.** The issuer’s agent builds the blockchain into its list of owners, so that “a transfer of the crypto asset on the crypto network results in a transfer of the security on the master securityholder file.” The staff says the only difference from a share in traditional form is that the list lives on a blockchain instead of in an ordinary database.

**The token points at the share.** The issuer keeps its list off chain and gives holders a token that “does not convey any rights, obligations, or benefits of the security.” Moving the token tells the agent to update its list. The share moves when the list changes, not before.

**The token is a custodian’s entitlement.** A firm holds the real share and issues a token for the holder’s claim on it, “such as a tokenized security entitlement.” This is the claim a brokerage statement shows, in a new format.

**The token pays like the share.** The firm issues its own security: a linked security, such as a structured note, or a security-based swap. The staff says a linked security “is not an obligation of the issuer of the referenced security and confers no rights or benefits from the issuer of the referenced security.” A swap “typically does not convey to the holder any equity, voting, information, or other rights with respect to the referenced security.” The name on the token does not decide the model; the staff looks to “the economic reality of the instrument rather than the name given to the instrument.”

| Model | Who holds the official record | What the holder can enforce | Example from the Register |
| --- | --- | --- | --- |
| Issuer-sponsored, on-chain record | The issuer or its transfer agent; the chain is part of the list of owners | The rights of a registered holder, against the issuer | Invesco USTB (Superstate) : “The on-chain record is the securityholder file” |
| Issuer-sponsored, off-chain record | The issuer or its transfer agent, off chain; the token is an instruction to it | The share’s rights as the off-chain list records them; the token alone conveys none | WisdomTree WTGXX : the transfer agent’s file governs and the chain is a mirror |
| Third-party custodial | The company’s list shows the custodian or its nominee; the custodian’s books show the holder | A security entitlement against the custodian, including a pro rata share if it falls short | Coinbase Tokenized Stock, bStocks, Backpack Securities, Anchored aStocks, Sygnum FIUSD, ARK Venture Fund. The DTC path below is the largest planned case. |
| Third-party synthetic | The company’s list never shows the holder; the backing shares sit with a broker or custodian for the note issuer, and the note’s own record shows the holder | A claim on the note issuer and, after its default, on pledged collateral; nothing against the company | xStocks and Ondo Global Markets , both rejected |

The model is the first fact in the file because every later answer depends on it: who can fix a wrong entry, who the client stands behind in a bankruptcy, and whether the token may trade on the new venues at all.

## The fifth path: a share tokenized at DTC

The Depository Trust Company holds securities for the brokers and banks that are its participants; DTCC says DTC holds assets worth over $114 trillion. The company’s list names DTC’s nominee, Cede & Co., and each broker’s client sees the share on the broker’s books. The December 2025 no-action letter lets a participant turn part of that holding into tokens.

The mechanics are set out in the letter. A participant with a Registered Wallet instructs DTC to tokenize its holding. DTC moves the shares from the participant’s account to a Digital Omnibus Account and mints a token to the participant’s wallet. Tokens move only between Registered Wallets, and “Only DTC Participants would be permitted to register wallets.” DTC tracks every move with an off-chain system called LedgerScan, and “LedgerScan’s record would constitute DTC’s official books and records.” Through all of it, the shares “would remain registered in the name of Cede & Co., DTC’s nominee.” The eligible list is the Russell 1000, Treasury bills, notes, and bonds, and ETFs that track major indices such as the S&P 500 and Nasdaq-100.

In the staff’s scheme this is the custodial model. The January statement cites the DTC letter in that section. It earns its own place in a file for three reasons. The intermediary is the central depository, not a new firm. The token keeps the share’s CUSIP. And the exchanges will trade it on the same book as the ordinary share: Nasdaq’s approved rule requires the tokenized share to be fungible with the ordinary share and to carry its CUSIP number and symbol, and trades settle T+1.

A client does not hold this token in a wallet. The broker does, and the client’s statement shows the share. DTCC ran production trades on 2026-07-15 with more than 30 firms and plans to launch the service in October 2026. Until then no client can hold one. [The DTC explainer](/regulation/explained/dtc-tokenized-shares/) covers the root wallet, the launch, and what a broker must answer.

## What changes hands when the token moves

A token transfer is one event on a blockchain. What it moves in law differs by model.

- On-chain issuer record: the share itself. The token move is the entry on the list of owners.
- Off-chain issuer record: an instruction. The staff says the token transfer “operates to notify the issuer (or its agent) to record the transfer of ownership of the security on the master securityholder file.” Between the token move and the agent’s entry, the chain and the list can disagree. The list wins.
- Custodial: the entitlement. The custodian’s books move the claim; the share stays in the custodian’s name.
- Synthetic: the note. Nothing changes at the company. Ondo tells its holders, “you will not see your name on the share register for the underlying assets.”
- DTC-tokenized: the entitlement between two participants’ wallets. DTC’s record changes; Cede & Co. stays the registered owner.

Programs that reference the same share do not quote the same price, and the gap is not a mispricing to trade on. Ondo says: “One token does not necessarily represent the value of one share, and the price of one token will not always match the price of the underlying asset.” Its tokens reinvest dividends, so one token can come to track more than one share. xStocks apply a multiplier for dividends and splits; on Solana “the raw onchain balance remains constant” and the change shows only in display. Two quotes are comparable only after each is converted to shares per token on the same date. Ketju prints no cross-program price gap until it can compute one per share, at the same minute, from primary data. The Commission warns that prices on the new venues “could dislocate from the prices of the NMS stock in traditional format,” because a pool prices from the ratio of assets it holds.

## Who holds the official record

For a U.S. security, the list of owners that counts is the master securityholder file, usually kept by a transfer agent registered with the SEC. The September proposal calls it “the authoritative record of who owns an issuer’s securities.” It would let that file be spread across linked systems of the agent’s choosing, “provided the transfer agent maintains at all times exclusive control over the master securityholder file.” The Commission also asks how to treat records that “exist solely on a blockchain or distributed ledger that is not exclusively controlled by the transfer agent.” That is the question to ask of any token: can the agent, alone, change the record?

The Franklin Templeton letter shows what exclusive control looks like in practice. Franklin’s transfer agent keeps the fund’s list of owners in a system that joins an internal database to one or more blockchains, and it holds a separate set of administrative keys. The letter records that “The Administrative Controls permit FTIS to maintain, correct, freeze, migrate, or restore the official record of share ownership in the Integrated System.” Franklin represented that a compromised or misused wallet key “would not, by itself, establish a different official ownership record.” The staff’s no-action position rested on those representations. For a client, the wallet key is not the last word. The agent is.

The proposal would also put this on paper each year. A new Question 5(b) on Form TA-2 asks each agent to name its “Tokenization Agent(s)” and “Distributed Ledger Technology Platform(s).” A new Question 6(b) asks it to count the issues it services by model, issuer-sponsored or third-party-sponsored. And proposed Rule 17ad-31 would bar agents from helping unregistered sales unless they have “a reasonable basis to believe” the sale does not break Section 5 of the Securities Act. If adopted, the agent becomes a gatekeeper on resale, and its filings name the platforms it uses.

A synthetic token has no transfer agent of the company behind it. xStocks put it in one line: “The token is the certificate. Holding the token constitutes holding the instrument.” The instrument is the note. The share’s record sits elsewhere, in a custodian’s name.

## What “same rights” means, and what it does not

The phrase has a defined meaning now. Under the Innovation Exemption a tokenized share gives “the same rights and privileges” as the ordinary share if it “conveys the same interest in the company,” the same dividends, the same votes, and “the same share of the residual assets of the company upon liquidation.” A third party that tokenizes someone else’s stock must pass along proxy materials “at no cost to the issuer or the shareholders.” Nasdaq’s rule uses the same test. Three things sit outside it.

**It does not bring SIPC.** SIPC says it “only protects the custody function of the broker dealer.” A DTC-tokenized share held by a SIPC-member broker for its customer is still in that broker’s custody, and the ordinary SIPC analysis starts there. A token in a client’s own wallet has no broker custody for SIPC to restore. Same rights against the company say nothing about who holds the asset.

**It does not mean the token can be delivered to a brokerage account.** Ondo tells holders, “you can redeem your Tokens for cash or stablecoins for the then-value of the underlying assets.” That is cash, not shares. xStocks run an in-kind route, xPort, through the broker Alpaca, where “xStock tokens can be redeemed back into shares at any time for use within Alpaca.” It requires onboarding with both the issuer and Alpaca, and xStocks are not offered to U.S. persons at all.

**It gives no claim on the company from a note.** Both synthetic programs in the Register say so in their own words. Ondo: “An Ondo tokenized stock is a structured note: a debt instrument issued by Ondo Global Markets (BVI) Limited,” and holders “do not have shareholder voting rights, shareholder information rights or other shareholder rights from the issuer of the underlying securities.” xStocks: “Each xStock is a bearer debt instrument classified as a tracker certificate,” and “It does not confer shareholder voting rights.” Neither is offered to Americans. Ondo sells “only to persons who are (i) located outside the United States”; xStocks “are not marketed, offered, or solicited in the United States, to U.S. Persons, or in any other prohibited jurisdiction.” Ketju rejected both; the [xStocks memo](https://ketjuresearch.com/register/xstocks/) and the [Ondo Global Markets memo](https://ketjuresearch.com/register/ondo-global-markets/) give the reasons.

## The Innovation Exemption: conditions an advisor can check

On 2026-09-17 the Commission exempted Tokenized Securities Venues from the definition of “exchange,” and certain liquidity providers in their pools from the definition of “dealer.” The order runs “until September 17, 2031.” The venue carries the conditions. An advisor can check most of them from public documents:

- The token is tokenized listed stock, issuer-sponsored or third-party custodial. The order excludes “securities where a third party issues a crypto asset representing its own security that provides synthetic exposure to an underlying security.” By that definition a tracker note such as an xStock or an Ondo token cannot trade on a venue under the order.
- The venue verified that the token gives the same rights and privileges as the ordinary share.
- For a share tokenized by a third party, the venue sent the company written notice and waited at least 30 calendar days. If the company objected in time, the venue cannot list the token, and must say so in its public notice within five business days.
- The venue is a U.S. person, and it published a plain-English public notice at least 30 calendar days before it began operating. The notice describes who may trade.
- Every pair has a tokenized listed stock on one side. The other side is another tokenized stock, a non-security crypto asset such as a payment stablecoin, or a tokenized money-market fund.
- Trading stops whenever trading in the share stops on its primary listing exchange.
- Tier 1 stocks, the Limit Up-Limit Down Plan’s Tier 1, are capped at 75 symbols and 0.25 percent of the prior month’s average daily share volume. Tier 2 is capped at 250 symbols and 2.5 percent. After a first breach of a volume cap, each further breach pauses that symbol for three months.
- The venue publishes free, machine-readable trade data in dollars for the past 30 days, updated within ten minutes of each trade: symbol, price, size, time, and direction, plus each pool’s contract address, daily volume, and end-of-day size.
- Its smart contracts are public, auditable, and on a public, permissionless blockchain.
- No new shares are issued on the venue.

A venue’s 30-day notice period means none can operate before mid-October 2026. A listing on a venue is not a judgment about the token. And the order grants no relief under the Investment Company Act, which matters for the tokenized money-market funds that sit on the other side of a pair. [The exemption explainer](/regulation/explained/sec-tokenized-stock-exemption-2026/) covers who may trade and what it changes for a client.

## Where the exposure fails

Each model has its own failure. The file should name the one that applies.

**The note issuer defaults.** A synthetic holder is a creditor of a special-purpose company. The staff warns that holders “may be exposed to risks with respect to the third party, such as bankruptcy, to which a holder of the underlying security would not necessarily be exposed.” Both programs give a security agent power over the backing shares. At Ondo, Ankura Trust Company holds “a first-priority, perfected security interest” and on default can “take possession of this collateral, exchange it for cash, and distribute the proceeds to tokenholders.” At xStocks, “the Security Agent may take control of the collateral accounts, liquidate the underlying assets, and distribute proceeds to token holders in accordance with the prospectus terms.” The recovery is cash, after a sale, on the prospectus’s timetable. It is not a share.

**The intermediary fails.** A custodial holder depends on Article 8 of the Uniform Commercial Code. Securities an intermediary holds for its customers “are not property of the securities intermediary, and are not subject to claims of creditors of the securities intermediary.” But if the intermediary is short, each holder’s interest “is a pro rata property interest” in what is there. DTC’s request, attached to the staff letter, says securities held at DTC are “bankruptcy remote” from DTC. A smaller custodian may be sound, and the file should name it and state which law governs its books.

**The agent corrects the record.** Every model that keeps an official record keeps the power to change it. DTC’s technology standards are meant to ensure it can “address any erroneous entries, lost tokens, or malfeasance,” and the letter states that “DTC would have the technological capability to transfer any of the tokens to address Conditions Requiring Reversal.” Franklin’s agent can “correct, freeze, migrate, or restore” the record. The same power that rescues a client who loses a key can move tokens out of a client’s wallet. That is not a defect in a regulated security; it is a fact the file must name, with the document that grants the power. Ketju’s [WTGXX file](https://ketjuresearch.com/register/files/wisdomtree-wtgxx/) lists each power read from the contract: allowlist, freeze, pause, clawback, mint, and upgrade.

## When the token is collateral

On 25 September 2026 Aave Labs opened a market on Base that takes seven Coinbase Tokenized Stocks, AAPLc, AMZNc, GOOGLc, METAc, MSFTc, NVDAc, and TSLAc, as collateral for USDC loans. It is the first lending market where the collateral is a security, and it shows why the file cannot stop at the token. A client on either side of that loan depends on five links.

**The certificate.** Coinbase Onchain SPV Ltd, an Abu Dhabi company, issues the token and holds the shares as bare trustee at Alpaca Securities LLC. The prospectus says a token transfer on Base passes title only when Onchain Marketplace Ltd’s Legal Register records it, and the contract lets a single key freeze a holder, pause transfers, and claw tokens back. Aave’s market cannot see any of that; it sees a balance.

**The price.** Chainlink’s 24/5 tokenized-equity feeds run from Sunday 20:00 ET to Friday 20:00 ET. Over a weekend or a holiday, in Aave’s words, “feeds hold the last published price, so collateral values do not change until the underlying market reopens.” A loan taken on Friday accrues interest through Sunday against a price that cannot move, and a Monday gap lands on the lender all at once.

**Corporate actions.** A split or a dividend changes how many shares a token stands for. Aave says “the affected reserve is paused until the new token multiplier is applied.” While it is paused, no one supplies, borrows, or repays in that reserve.

**Liquidation.** When a borrower’s collateral falls below the line, the market sells the certificate on Base to whoever bids there. The buyer gets a token that only a vested, non-US holder can redeem for shares. The depth of that bid is the lender’s real protection, and it is not the depth of the NASDAQ.

**Who may be there.** The certificates are offered under Regulation S to non-US persons only, and Aave says the market is “available in eligible geographies outside the United States.” A US client cannot hold the collateral. An adviser whose client supplies USDC to the market is lending against something the client could not own, and the client’s exit depends on borrowers the client cannot see.

Aave has not published the loan-to-value figures or the supply and borrow caps; it says they will be set “through the risk steward process.” The Ketju memo for Aave v4 records the market and reopens together with the Coinbase file if a weekend price gap, a long pause, or a deep liquidation shows up on chain.

## The programs on file

Ketju keeps one eligibility file per program that issues a tokenized stock, ETF, or note. 31 programs on file in this class, each read from the issuer’s documents and the chain, updated daily.

**stocks and shares.** [Coinbase Tokenized Stock (certificates by Coinbase Onchain SPV Ltd, ADGM, "c" tickers on Base)](https://ketjuresearch.com/register/files/coinbase-tokenized-stock/) · [CURRENC Group ordinary shares in token form (Securitize, on Solana, Avalanche and Ethereum)](https://ketjuresearch.com/register/files/currenc-curr/) · [Draggable Aktionariat AG Shares (DAKS: the issuer’s own registered shares as Swiss ledger-based securities on Ethereum)](https://ketjuresearch.com/register/files/aktionariat-daks/) · [Exodus Movement Class A common stock tokens (Securitize on Algorand; Superstate on Solana)](https://ketjuresearch.com/register/files/securitize-exodus-exod/) · [Figure Technology Solutions Series A Blockchain Common Stock (FGRS)](https://ketjuresearch.com/register/files/figure-fgrs/) · [RealUnit Shares (REALU: RealUnit Schweiz AG’s registered shares as Swiss ledger-based securities on Ethereum)](https://ketjuresearch.com/register/files/aktionariat-realunit/) · [Superstate Opening Bell (tokenized common stock of listed companies)](https://ketjuresearch.com/register/files/superstate-opening-bell/) · [Switzerlend AG C1 Shares SHA (LENDS: preferred shares of the lend.ch lending platform as Swiss ledger-based securities, locked in a drag-along contract)](https://ketjuresearch.com/register/files/aktionariat-switzerlend/) · [Tokenized SECZ (Securitize Corp. common stock, issuer-tokenized on Avalanche and Solana)](https://ketjuresearch.com/register/files/securitize-secz/) · [wemakeit AG shares (WMKT: a Swiss crowdfunding platform’s registered shares as ledger-based securities on Ethereum)](https://ketjuresearch.com/register/files/aktionariat-wemakeit/)

**notes and bonds.** [DeedFlow Royalty Revenue Bonds, Series 2026](https://ketjuresearch.com/register/files/deedflow-royalty-bonds/) · [deJAAA (Open Market Factory notes linked to JAAA)](https://ketjuresearch.com/register/files/open-market-factory-dejaaa/) · [Etherfuse Stablebonds (credit claims on sovereign bonds bought through Mexican brokers: CETES, USTRY, TESOURO, KTB, GILTS, EUROB)](https://ketjuresearch.com/register/files/etherfuse-stablebonds/) · [Figure YLDS (Figure Transferable Certificates)](https://ketjuresearch.com/register/files/figure-ylds/) · [Midas mTBILL](https://ketjuresearch.com/register/files/midas-mtbill/) · [Nomyx Revenue Participation Bonds, Series 2026 (Bond Tokens)](https://ketjuresearch.com/register/files/nomyx-revenue-bonds/) · [Obligate Trade Finance Yield (oTFY)](https://ketjuresearch.com/register/files/obligate-otfy/) · [Ondo Global Markets (tokenized stocks and ETFs, "on" tickers)](https://ketjuresearch.com/register/files/ondo-global-markets/) · [Ondo Intelligent Portfolios (seven portfolio tokens, "on" tickers)](https://ketjuresearch.com/register/files/ondo-model-portfolios/) · [Ondo U.S. Dollar Yield (USDY, rUSDY, mUSD)](https://ketjuresearch.com/register/files/ondo-usdy/) · [OpenTrade Loan Vaults (XMMF, XTBT, XEVT, XFTB, XHYC)](https://ketjuresearch.com/register/files/opentrade-loan-vaults/) · [Republic pre-IPO notes on Bitget IPO Prime (preOPAI, preSPCX)](https://ketjuresearch.com/register/files/republic-pre-ipo/) · [Robinhood Stock Tokens (tracker certificates by Robinhood Assets (Jersey) Limited on Robinhood Chain)](https://ketjuresearch.com/register/files/robinhood-stock-tokens/) · [rTokens (Reality, Bitget’s issuance platform; listed on CoinGecko as "rStock")](https://ketjuresearch.com/register/files/reality-rtokens/) · [Spiko Digital Assets Cash and Carry Fund (SPKCC, eurSPKCC)](https://ketjuresearch.com/register/files/spiko-cash-carry/) · [Tenbin Gold (tGLD)](https://ketjuresearch.com/register/files/tenbin-tgld/) · [Tessera T-Tokens (loans to Panama issuers repaid from SpaceX, Kalshi, and OpenAI exposure)](https://ketjuresearch.com/register/files/tessera-pre-ipo/) · [Tradable private-credit deal tokens](https://ketjuresearch.com/register/files/tradable-deal-tokens/) · [USDM1 (Republic of the Marshall Islands tokenized secured bonds, redeemable at one US dollar)](https://ketjuresearch.com/register/files/usdm1/) · [xStocks (tracker certificates by Backed Assets (JE) Limited, "x" tickers)](https://ketjuresearch.com/register/files/xstocks/)

**ETFs.** [WisdomTree 500 Digital ETF](https://ketjuresearch.com/register/files/wisdomtree-500-digital-etf/)

**One ticker, several programs.** [AAPL](https://ketjuresearch.com/register/stocks/aapl/) · [CRCL](https://ketjuresearch.com/register/stocks/crcl/) · [GOOGL](https://ketjuresearch.com/register/stocks/googl/) · [META](https://ketjuresearch.com/register/stocks/meta/) · [MSTR](https://ketjuresearch.com/register/stocks/mstr/) · [MU](https://ketjuresearch.com/register/stocks/mu/) · [NVDA](https://ketjuresearch.com/register/stocks/nvda/) · [QQQ](https://ketjuresearch.com/register/stocks/qqq/) · [SNDK](https://ketjuresearch.com/register/stocks/sndk/) · [SPCX](https://ketjuresearch.com/register/stocks/spcx/) · [SPY](https://ketjuresearch.com/register/stocks/spy/) · [STRC](https://ketjuresearch.com/register/stocks/strc/) · [TSLA](https://ketjuresearch.com/register/stocks/tsla/). Each page puts every version of the stock side by side: which gives the holder the share, which a custodian’s claim, which a note that pays like it.

## What belongs in the diligence file

- The file names the SEC staff model the token fits, and cites the page of the offering document that shows it.
- It names who keeps the official record, whether that party is a registered transfer agent, and whether it alone can change the record.
- It says what the client can enforce and against whom: the company, a custodian, or a note issuer.
- It quotes who may buy, hold, and redeem under the issuer’s terms, and whether U.S. persons are excluded.
- It states how the position exits: redemption into shares, redemption into cash, or a sale, and on which days.
- It lists every power over the token contract, who holds it, and the document that grants it.
- For a DTC-tokenized share, it names the broker that holds the token and the account where the share appears.
- For a trade on a venue, it keeps the venue’s notice, the date it was read, and the feed that reports the trade.
- It records the dated event that would reopen the review.

Ketju keeps one [eligibility file](https://ketjuresearch.com/register/files/) per program with these facts in the issuer’s own words. Continue with [tokenized assets for RIAs](/tokenized-assets/) for the wrapper mechanics, or [tokenized Treasuries](/asset-classes/tokenized-treasuries/) for the fund case.

## Sources

[^1]: [Coinbase Tokenized Stocks on Aave V4 (2026-09-25)](https://aave.com/blog/coinbase-tokenized-stocks), Aave Labs
[^2]: [Statement on Tokenized Securities (2026-01-28)](https://www.sec.gov/newsroom/speeches-statements/corp-fin-statement-tokenized-securities-012826-statement-tokenized-securities), SEC Divisions of Corporation Finance, Investment Management, and Trading and Markets
[^3]: [No-action letter: DTCC Tokenization Services (2025-12-11)](https://www.sec.gov/files/tm/no-action/dtc-nal-121125.pdf), SEC Division of Trading and Markets
[^4]: [WisdomTree exemptive order, Release IC-35968 (2026-02-23)](https://www.sec.gov/files/rules/ic/2026/ic-35968.pdf), U.S. Securities and Exchange Commission
[^5]: [Order approving Nasdaq rule to trade securities in tokenized form, Release 34-105047 (2026-03-18)](https://www.sec.gov/files/rules/sro/nasdaq/2026/34-105047.pdf), U.S. Securities and Exchange Commission
[^6]: [NYSE notice of immediately effective rule for tokenized trading, Release 34-105260](https://www.sec.gov/files/rules/sro/nyse/2026/34-105260.pdf), U.S. Securities and Exchange Commission
[^7]: [DTCC advances development of new tokenization service (2026-05-04)](https://www.dtcc.com/news/2026/may/04/dtcc-advances-development-of-new-tokenization-service), DTCC
[^8]: [DTCC turns tokenization into reality (2026-07-15)](https://www.dtcc.com/news/2026/july/15/dtcc-turns-tokenization-into-reality), DTCC
[^9]: [No-action letter: Franklin Templeton (2026-08-12)](https://www.sec.gov/rules-regulations/no-action-interpretive-exemptive-letters/division-investment-management-staff-no-action-interpretive-letters/franklin-templeton-081226), SEC Division of Investment Management
[^10]: [Transfer Agent Rules, proposed, Release 34-106246](https://www.sec.gov/files/rules/proposed/2026/34-106246.pdf), U.S. Securities and Exchange Commission
[^11]: [Fact sheet: Proposed Transfer Agent Rule Modernization](https://www.sec.gov/files/34-106246-fact-sheet.pdf), U.S. Securities and Exchange Commission
[^12]: [Transfer Agent Rules (Federal Register, 2026-09-04)](https://www.federalregister.gov/documents/2026/09/04/2026-18190/transfer-agent-rules), Federal Register
[^13]: [Innovation Exemption order for Tokenized NMS Stock, Release 34-106402 (2026-09-17)](https://www.sec.gov/files/rules/exorders/2026/34-106402.pdf), U.S. Securities and Exchange Commission
[^14]: [SEC issues “Innovation Exemption” to facilitate trading of tokenized NMS stock (Press Release 2026-90)](https://www.sec.gov/newsroom/press-releases/2026-90-sec-issues-innovation-exemption-facilitate-trading-tokenized-nms-stock-request-comment), U.S. Securities and Exchange Commission
[^15]: [ARK Venture Fund order, Release IC-36333 (2026-09-21)](https://www.sec.gov/files/rules/ic/2026/ic-36333.pdf), U.S. Securities and Exchange Commission
[^16]: [What SIPC Protects](https://www.sipc.org/for-investors/what-sipc-protects), Securities Investor Protection Corporation
[^17]: [UCC § 8-503: Property interest of entitlement holder](https://www.law.cornell.edu/ucc/8/8-503), Legal Information Institute, Cornell Law School
[^18]: [xStocks Product Legal Overview](https://docs.xstocks.fi/docs/product-legal-overview), Backed Assets (JE) Limited
[^19]: [xStocks Frequently Asked Questions](https://docs.xstocks.fi/docs/frequently-asked-questions), Backed Assets (JE) Limited
[^20]: [xPort: In-Kind Flow](https://docs.xstocks.fi/docs/issuance-and-redemption/in-kind-flow-xport), Backed Assets (JE) Limited
[^21]: [Ondo Stocks: Overview](https://docs.ondo.finance/ondo-stocks/overview), Ondo Finance
[^22]: [Ondo Stocks: Legal & Regulatory](https://docs.ondo.finance/ondo-stocks/legal-and-regulatory), Ondo Finance
[^23]: [Ondo Stocks: Trust & Transparency](https://docs.ondo.finance/ondo-stocks/trust-and-transparency), Ondo Finance

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