Digital Chamber Urges SEC to Keep Transfer-Agent Rules Blockchain-Neutral

The Digital Chamber submitted a November 3 comment on the SEC’s proposed transfer-agent rule overhaul. It supports electronic modernization but asks the agency to state explicitly that a distributed ledger may constitute all or part of the official master securityholder file without a mandatory offchain duplicate.

The group also recommends allowing lead, sub-transfer-agent and co-equal structures for a single securities issue, including arrangements that divide responsibility between conventional and tokenized positions or across blockchains. It argues that registration should follow the regulated function performed, rather than treating software developers, node operators or tokenization providers as transfer agents solely because they supply technology.

The letter separately opposes the proposed Section 5 gatekeeping duty, requests electronic contact alternatives and supports direct examination of reliable onchain records. These are policy requests in an open rulemaking; the SEC has not adopted them or issued a final rule.

Sources

• Digital Chamber — SEC transfer-agent rules comment letter
• U.S. Securities and Exchange Commission — Transfer Agent Rules proposal

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