1/ On Wednesday, we submitted the 11th of our 13 planned responses to @SECGov Commissioner @HesterPeirce’s request for input to the Crypto Task Force from the industry, addressing a range of questions related to the tokenization of securities.

2/ This letter responds to Questions 40–46 of the request for input related to the tokenization of securities-- an issue central to the ongoing evolution of U.S. capital markets and to the United States maintaining its global leadership position.

3/ TDC encourages @SECGov to commence efforts on a new holistic initiative in the tradition of Market 2000, exploring and investigating the potential for blockchain technology across all aspects of the U.S. public markets.

4/ In the meantime, @SECGov’s regulatory approach to the continued growth of blockchain technology in the securities markets, including tokenization, should be fit for purpose and serve @SECGov’s stated mission.

5/ U.S. tokenized securities markets are in an early developmental stage, and TDC believes that the SEC should foster the maturation of market practice through allowing differing applications to survive and compete.

6/ TDC supports Commissioner @HesterPeirce’s recent reminder to market participants that existing securities regulation applies equally to tokenized securities.

7/ @SECGov should adopt a technology-neutral general "enabling rule" for blockchain and DLT specifying that the mere use of blockchain or DLT alone does not violate U.S. securities laws and regulations.

8/ @SECGov should acknowledge that blockchain technology – as a distributed ledger – eliminates single point of failure risk and can satisfy Exchange Act recordkeeping requirements without requiring the maintenance of duplicate off-chain records.

9/ @SECGov should provide renewed clarity that tokenized representations do not constitute separate securities.

10/ TDC recommends three steps that @SECGov should take to enable market participants to explore the benefits and challenges of a shortened market trade settlement cycle and the use of atomic settlement.

11/ It is clear that tokenization of securities will significantly advance our markets, and it is critical that market participants feel confident that the United States is a safe environment to build blockchain-enabled financial services solutions for the long term.

12/ We thank @FinReGatti and Jesse Overall of @CliffordChanceLLP, along with our contributing members. We will continue to roll out our final responses to Commissioner Peirce’s additional questions over the coming days. Read our full letter here:

12/ We thank @FinReGatti and Jesse Overall of @Clifford_Chance, along with our contributing members. We will continue to roll out our final responses to Commissioner Peirce’s additional questions over the coming days. Read our full letter here: