US Tokenization Series | Status board
The 21-item status board, the fee stack, the players by layer, the guardrails by layer and the numbered sources behind all four parts. Updated when a rule or product changes.
← Series indexSeries v1.0, status as of 5 November 2026. In-page links: Status board | Fee stack | Players | Guardrails | Corrections | Open items | Change log | Sources
LIVE APPROVED in force. STAFF VIEW NO-ACTION ANNOUNCED guidance or announced, not law. PROPOSED PENDING not final. STALLED UNSETTLED blocked or contested.
| Item | Status | Key facts | Source |
|---|---|---|---|
| SEC staff no-action letter to DTC (tokenization service) | LIVE | Issued 11 Dec 2025; covers a three-year service period on pre-approved blockchains. | [S13][S14] |
| DTCC Tokenization Service | LIVE | Launched 28 Oct 2026. 34 securities (about $30T underlying market value; DTC holds over $114T). 20 participants. Canton and private Besu; Stellar and Circle's Arc planned for 2027. Conversion target about 15 minutes; selected third-party wallets must be registered; transfer restrictions apply. | [S9][S10][S11] |
| Nasdaq tokenized securities rule | APPROVED | SEC approved in March 2026. Same order book, same priority, same CUSIP and symbol, same rights. Tokenized trades settle T+1 through DTC. | [S15][S16][S17] |
| NSCC 24x5 clearing | LIVE | Sunday 8:00 pm ET to Friday 8:00 pm ET. A trade at 8:00 pm ET keeps same-day trade date and T+1 settlement. | [S54] |
| SEC Innovation Exemption (TSVs) | LIVE, TEMPORARY | Issued 17 Sep 2026, expires 17 Sep 2031, comments invited. A TSV must publish a notice at least 30 days before operating. Issuer has a 30-day right to object. | [S2][S3][S8] |
| SEC staff Statement on Tokenized Securities | STAFF VIEW | 28 Jan 2026. Tokenized securities remain securities. Issuer-sponsored vs third-party-sponsored (custodial or synthetic) taxonomy. | [S21][S22][S23] |
| SEC staff broker-dealer custody statement (Rule 15c3-3 possession) | INTERIM | 17 Dec 2025. Covers tokenized equity and debt. Commission still weighing formal rule amendments. | [S50] |
| Ondo US custodial tokenized IVV and MU | LIVE | 2 Jul 2026. Oasis Pro TA mints entitlement tokens; Broadridge ProxyVote for voting and disclosures. | [S28] |
| Computershare Issuer-Sponsored Tokens with Securitize | ANNOUNCED | 29 Apr 2026 agreement. Computershare stays transfer agent and processes corporate actions. No issuer count found. | [S26][S27] |
| NYSE digital trading platform (24/7, onchain settlement) | PENDING | Announced 19 Jan 2026 subject to SEC approval. Securitize named first eligible digital transfer agent (24 Mar 2026 MOU). I found no approval order in this pass. | [S19][S20] |
| Securitize and Cantor onchain IPO framework | ANNOUNCED | 15 Jul 2026. No issuer, date or size named. | [S30][S31] |
| Rule 611 and 610(e) rescission | PROPOSED | Voted 11 Jun 2026, 60-day comment period. Not final. | [S41] |
| Transfer agent rule modernization | PROPOSED | 1 Sep 2026. Contemplates blockchain as the official ownership record; new Form TA-2 tokenized-issue reporting. | [S24] |
| Regulation Crypto Assets | PROPOSED | 18 Aug 2026, comments closed 20 Oct. Targets non-security crypto assets sold under investment contracts, so it is not the route for tokenized equity. | [S51] |
| SEC adviser and fund crypto custody proposal | PROPOSED | 1 Oct 2026. | [S52] |
| GENIUS Act (payment stablecoins) | PARTLY FINAL | Signed 18 Jul 2025. OCC final rule issued (Bulletin 2026-50); Treasury, FinCEN and OFAC proposals out. Effective on the earlier of 18 Jan 2027 or 120 days after final rules. | [S44][S45][S46] |
| CLARITY Act | STALLED | House passed 17 Jul 2025 (294 to 134). Senate Banking 15 to 9 on 14 May 2026. Cloture failed 49 to 50 on 15 Sep 2026. | [S51][S53] |
| Fed limited "payment account" | PROPOSED | Proposed May 2026; target about 90-day review; Kraken got a 12-month pilot limited master account in Mar 2026; Waller targeted Q4 2026 operation. | [S47][S48] |
| CFTC tokenized collateral pilot | LIVE PILOT | Dec 2025 launch for BTC, ETH and USDC as FCM margin; expanded 6 Feb 2026 to stablecoins of national trust banks. | [S49] |
| DTCC Collateral AppChain | NOT YET LIVE | Reports conflict: Q4 2026 in some, Q1 2027 in later ones. I use Q1 2027 (uses Chainlink CCIP). | [S14] |
| Tax form for tokenized securities | UNSETTLED | Sources conflict on 1099-B vs 1099-DA. See stage 10. | [S58] |
Only the numbers carry sources. Every "plausible future" cell is analysis and is highlighted.
| Cost layer | Traditional today (US) | Tokenized today (US) | Plausible future | Confidence |
|---|---|---|---|---|
| SEC registration | About $138.10 per $1M offered (implied) [S40] | Same | No change; set by statute | High |
| Underwriting spread | 4% to 7%; 7% mid-size [S36][S38] | No disclosed deal pricing | Pressure on the 60% selling concession if onchain books reach investors directly | Low |
| Transfer agent | Per-account and per-event fees; $1,000 per new CUSIP at DTC [S55][S56] | TA still paid by issuer; no new CUSIP for same-class tokens [S15][S25] | Event fees may compress if corporate actions automate; fight over who gets paid is the STA petition [S25] | Medium |
| Trading commission | $0 at major retail brokers [K] | Nasdaq treats fees identically [S16]; TSV fees unpublished | Zero-commission model persists; spread and incentive structure in AMMs matters more | Medium |
| Regulatory pass-through | Section 31 $20.60 per $1M of sales; CAT about $0.000003 per share [S32][S34] | Same on tokenized shares traded on Nasdaq (same rules) | Rate resets annually with SEC appropriations | High |
| Clearing | NSCC value-into-net $0.44 per $1M [S35] | Not published for DTC tokens | Real savings are in margin and liquidity buffers, not the fee line [S13] | Low |
| Custody and settlement | Bundled | Not published | Wallet and key-control costs replace some account costs; unclear net | Low |
| Cash movement | Wire and bank hours | Bank deposit tokens inside bank pricing | 24/7 funding after GENIUS and Fed account decisions | Low |
Worked example: a $100M IPO at a 7% spread is $7.0M of spread plus about $13,810 of SEC registration fee, before legal, accounting and underpricing. A $10,000 stock sale at $0 commission carries a $0.206 Section 31 fee.
| Layer | Incumbents | Tokenization moves | Disruptors and new entrants | Exposure (analysis) |
|---|---|---|---|---|
| Issuer registers and records | Computershare, Continental and other transfer agents | Computershare ISTs with Securitize [S26] | Securitize TA, Oasis Pro TA (Ondo) [S20][S28] | Transfer agents hold the register that issuer-sponsored models need, so the fight is over who is paid, not who is necessary |
| Underwriting | Bulge-bracket syndicates | Cantor Fitzgerald onchain IPO framework [S30] | Securitize Markets | Unproven; no deal yet |
| Venues | Nasdaq, NYSE/ICE, Cboe, Texas Stock Exchange, 24X | Nasdaq tokenized rule; NYSE digital platform (pending) [S15][S19] | TSV operators (Tradecraft, Canton-linked) [S4] | Caps keep TSVs small until Commission acts again |
| Brokers | Wirehouses, retail brokers | DTC participants including Edward Jones, Apex, DriveWealth, Alpaca [S9] | Dinari; offshore Kraken, Robinhood EU, Coinbase tokens not offered to US persons [S59] | Retail access is the contested part |
| Clearing and depository | DTCC (DTC, NSCC) | DTC Tokenization Service, Collateral AppChain [S9][S14] | Canton (Digital Asset), Broadridge DLR, Chainlink CCIP | DTCC is inside the tokenization path, which limits displacement |
| Cash | JPMorgan, Citi, BNY, the Fed | JPMD, ICE tokenized deposits [S19][S42] | Circle, Coinbase, Kraken, Block and Ripple pursuing Fed access [S71][S72] | Decided by the GENIUS final rules and the Fed account |
| Shareholder communications | Broadridge | ProxyVote for tokenized securities [S28] | Wallet-native voting (future) [S68] | Broadridge is positioned on both sides |
| Layer | Authority | Instrument | Binding? | What it does |
|---|---|---|---|---|
| Offering | SEC | Securities Act of 1933; Jan 2026 staff statement | LAW STAFF VIEW | Tokenized securities are securities; offers must be registered or exempt [S21] |
| Corporate law | Delaware | DGCL 219(c), 224 (2017) | LAW | Distributed ledger may serve as the stock ledger [S57] |
| Transfer agents | SEC | Proposal of 1 Sep 2026 | PROPOSED | Blockchain as official record, controls, tokenized-issue reporting [S24] |
| Exchange trading | SEC, SROs | Nasdaq rule approval (Mar 2026) | APPROVED | Same book, CUSIP, rights [S15] |
| Onchain venues | SEC | Innovation Exemption (to 17 Sep 2031) | EXEMPTIVE ORDER | TSVs and Covered Firms relieved from exchange and dealer definitions under caps and conditions [S5][S7] |
| Order protection | SEC | Rule 611 and 610(e) rescission | PROPOSED | Replaces trade-through ban with broker best execution under FINRA Rule 5310 [S41] |
| Clearing and settlement | SEC | No-action letter to DTC (Dec 2025); NSCC rule filings | NO-ACTION APPROVED FILINGS | Authorizes DTC tokenization on pre-approved chains for three years [S14][S54] |
| Broker-dealer custody | SEC staff | 17 Dec 2025 statement on Rule 15c3-3 | INTERIM | Possession by exclusive key control and reconciliations [S50] |
| Stablecoin cash leg | OCC, Fed, FDIC, Treasury, FinCEN, OFAC | GENIUS Act and implementing rules | LAW RULES PARTLY FINAL | Reserves, redemption, custody, capital, AML and sanctions [S44][S45] |
| Fed access | Federal Reserve | Limited payment account | PROPOSED | Faster, narrower master-account access for fintech and crypto [S47] |
| Derivatives collateral | CFTC | Digital asset pilot and tokenized collateral guidance | PILOT | BTC, ETH, USDC and bank-issued stablecoins as margin [S49] |
| Market structure statute | Congress | CLARITY Act | STALLED | Would divide SEC and CFTC authority; cloture failed 49 to 50 [S51] |
| Tax | IRS | 1099-DA and 1099-B rules | UNSETTLED | Form and cost-basis treatment for tokenized securities disputed [S58] |
| Version | Date | Change |
|---|---|---|
| 1.0 | 5 Nov 2026 | Initial four-part series and status board. |
Retrieved 5 Nov 2026. Law-firm and agency sources preferred. Aggregator and comparison-site sources are flagged and should be confirmed against primary documents before external use.
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