Securitize, Figure Push SEC on Wallet IDs

Securitize, Figure, Equiniti, Plume and Centrifuge are urging the U.S. Securities and Exchange Commission to give digital identifiers a larger role in the official recordkeeping of tokenized securities. In their joint November 3 comment letter, the companies support the SEC’s transfer-agent modernization effort but argue that mandatory names and physical mailing addresses are too prescriptive for direct onchain holdings.

The filing was signed by executives from all five organizations, including Figure Chief Legal Officer Brian Crist and Securitize Chief Operating Officer Billy Miller. Securitize CEO Carlos Domingo later highlighted the submission publicly. The coalition wants wallet addresses, email addresses and other reliable electronic identifiers to be capable of satisfying identification and communication requirements when appropriate, rather than remaining only supplementary information.

Wallet Addresses Challenge Legacy Recordkeeping

The SEC’s proposed amendments to Rule 17ad-9 would still require a securityholder’s full name and, at minimum, a physical mailing address while allowing wallet addresses, phone numbers and emails as additional information. The coalition instead favors a principles-based standard focused on whether a transfer agent can uniquely identify and reliably communicate with the holder.

That distinction becomes more important when securities are held directly rather than through the traditional DTC structure. In conventional markets, transfer agents may record Cede & Co. as the registered holder while brokers maintain beneficial-owner records downstream. Tokenized securities can instead place individual wallet holders directly on the issuer’s ownership infrastructure. The letter argues that forcing transfer agents to collect physical addresses from potentially thousands of direct holders recreates legacy processes inside a digital ownership model.

The SEC proposal already goes further than existing rules in recognizing blockchain recordkeeping. It would allow a transfer agent to use blockchain or another distributed ledger as its master securityholder file, or as one component of that authoritative ownership record, provided the transfer agent maintains exclusive control. That model is increasingly relevant as projects such as the NYSE tokenized securities venue add both traditional and blockchain-native transfer agents.

Securitize already operates across that boundary. Its infrastructure supports regulated tokenized funds and equities, including the ARK Venture Fund’s Ethereum-based ownership layer, while maintaining eligibility and transfer controls around the securities themselves. Blockchain representation therefore does not eliminate transfer-agent obligations; it changes how ownership records and transfer instructions can be maintained.

SEC Proposal Extends Beyond Tokenization

The broader SEC rulemaking is considerably wider than the wallet-identifier debate. Proposed Rule 17ad-31 would require transfer agents to maintain current lists of issuer personnel authorized to direct restrictive-legend changes and to establish a reasonable basis before facilitating certain unregistered securities transactions. Those requirements apply to transfer-agent compliance generally and are not recommendations created by the joint Securitize-Figure letter.

Form TA-2 would also gain several new reporting fields. These include the number of issues maintained using distributed ledger technology, the identity of tokenization and DLT service providers, and a breakdown of tokenized securities by issuer-sponsored versus third-party-sponsored models. The SEC is trying to collect more detailed information about how transfer agents use blockchain infrastructure, but those reporting changes are separate from the coalition’s main request over holder identification.

The regulatory debate is becoming more consequential as regulated tokenization expands. Securitize is adding additional blockchain rails through initiatives such as its planned Stellar integration, while Wall Street firms are increasingly evaluating how tokenization can coexist with conventional ownership and settlement systems.

The unresolved question is therefore not whether transfer agents can use blockchain, because the SEC proposal already accommodates that possibility. The dispute is over how much traditional personally identifiable information federal rules should mandate when a regulated transfer agent can identify, communicate with and administer a direct holder through digital infrastructure.