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Today, the SEC announced a proposal to modernize the rules governing registered transfer agents. We are encouraged to see the Commission recognize that these rules should evolve as the industry adopts new technologies, including blockchain. As the first operational transfer agent leveraging blockchain technology, we have always believed that transfer agents are a critical part of market infrastructure, in fact, it’s something we said in our initial response to the SEC’s Crypto Task Force: “Transfer agent rules need to be modernized to leverage the power of tokenized securities, including using a public blockchain, as augmented by the transfer agent.” Modernization should raise standards, not lower them. Updating the regulatory framework to reflect how securities markets and their underlying technology are evolving is exactly the right move. Credit to Chairman Atkins, Director Jamie Selway, Commissioner Hester Peirce, and the SEC for continuing to move the regulatory framework forward. This regulatory momentum, alongside real industry adoption, is a strong tailwind for digital securities. We will submit comments during the public comment period and look forward to engaging with the Commission.

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