Blockchain Association supports SEC proposal to modernize transfer agent rules, urges adaptation to tokenization and permissionless blockchains
Blockchain Association posted on X on November 4, 2026, saying that it supports the U.S. Securities and Exchange Commission (SEC)’s proposal to modernize transfer agent rules and has submitted a comment letter recommending targeted clarifications and amendments to support tokenization while preserving investor protection.
The association said the rules should accommodate public, permissionless blockchains; onchain tools that can achieve the same regulatory outcomes should satisfy the rule requirements. In addition, the SEC should make clear that neutral software or infrastructure itself does not make its developers transfer agents.
The association said a workable framework can both protect investors and support the United States’ leadership in next-generation markets, and thanked the SEC for advancing the modernization of transfer agent rules. The SEC’s related proposal was issued in September 2026, and the comment deadline was November 3.
Original source:
Title: 1/ Clear rules are essential to bringing capital markets onchain. ... Publisher: Blockchain Association (@BlockchainAssn) Publication date: 2026-11-04 URL: https://x.com/BlockchainAssn/status/2118042456336069033 Source nature: official post by an industry organization (including thread) Verification status: full thread actually read in this review, verification date 2026-11-04 Supporting content: supports all key facts in the main text, including support for the SEC proposal, submission of a comment letter, suggestions aimed at tokenization, accommodation for public permissionless blockchains, clarification regarding neutral software developers, and the statement on investor protection
ABAB AI Insight
Transfer agents are responsible for maintaining the official records of securities holders. The SEC’s modernization proposal issued in September 2026 (Release No. 34-106246) is the first substantial update in decades; it explicitly allows distributed ledger technology, including blockchain, to be used as the principal securities holder record or as part of it, and introduces related reporting requirements.
Blockchain Association’s comments focus on ensuring the rules are technology-neutral, adaptable to public permissionless chains, and do not wrongly classify mere software developers as transfer agents. This is consistent with the industry’s push to bring capital markets onchain and reduce unnecessary compliance burdens. The comment deadline has passed, and the final rule text still depends on the SEC’s subsequent review.
The key point to watch is how the SEC defines “exclusive control” and the boundary for neutral infrastructure, and whether the proposal will further clarify the recordkeeping and reporting path for tokenized securities.
ABAB News · Cognitive Law
A comment letter from an industry organization is support for and suggestions on a proposal, and does not mean the rule has been finally adopted or implemented.
Adaptation to public permissionless blockchains and clarification of developer status are specific suggestions in the comments, and their final scope depends on the SEC’s rulemaking outcome.