On-the-spot report | Web3 lawyers interpret the latest changes in US stock tokenization | Bee Network
DTCC, short for Depository Trust & Clearing Corporation, is an American conglomerate that includes various entities responsible for custody, stock clearing, and bond clearing. DTC, short for Depository Trust Company, is a subsidiary of DTCC and the largest securities custodian in the United States. It is responsible for the unified custody of securities such as stocks and bonds, as well as settlement and transfer. Currently, the scale of securities assets under custody and accounting exceeds 100 trillion US dollars. DTC can be understood as the ledger administrator of the entire US stock market. II. What is the relationship between DTC and tokenization of US stocks?
In early September 2025, news broke that Nasdaq had applied to the SEC to issue shares in tokenized form. DTC was already mentioned in that application. Nasdaq stated that the only difference between tokenized shares and traditional shares lies in the clearing and settlement of orders on the DTC platform.
(The image above is a screenshot from the Nasdaq application proposal)
To make this easier to understand, we’ve created a flowchart. The blue section represents the changes Nasdaq proposed in its September filing. It’s clear that DTC is a key implementing and operational body for tokenization in the US stock market. III. What does the newly released “Letter of No Action” say?Many people equate this document directly with the SEC’s approval of the DTC’s use of blockchain for US stock market accounting, which is inaccurate. To understand this correctly, it’s essential to understand a clause in the US Securities Exchange Act: Section 19(b) of the Securities Exchange Act of 1934 requires any self-regulatory organization (including clearing houses) to submit a request for rule change to the SEC and obtain its approval when making changes to rules or significant business arrangements. Both of Nasdaq’s proposals were submitted based on this rule. However, the rule filing process is typically lengthy, potentially taking months, up to 240 days. If every change requires application and approval, the time cost would be prohibitively high. Therefore, to ensure the smooth operation of its securities tokenization pilot program, the DTC applied for an exemption from the obligation to fully comply with the 19b filing process during the pilot period, which the SEC granted. In other words, the SEC has only temporarily exempted the DTC from some procedural reporting obligations, and has not substantially permitted the application of tokenization technology in the securities market. So, how will the tokenization of US stocks develop next? We need to clarify the following two questions: (1) What pilot activities can the DTC conduct without reporting? Currently, the custodial accounting system for US stocks operates as follows: assuming a brokerage firm has an account with DTC, DTC uses a centralized system to record every stock purchase and sale, and the corresponding share amount. DTC has now proposed offering brokerage firms the option to record these stock holdings again using blockchain tokens. In practice, participants first need to register a qualified, DTC-approved registered wallet. Once a participant sends a tokenization instruction to DTC, DTC will do three things: a) Move these shares from the original account to a general ledger pool; b) Minting tokens on the blockchain; c) Depositing tokens into the participant’s wallet represents the participant’s interest in these securities. After this, these tokens can be transferred directly between these brokerages without each transfer needing to go through DTC’s centralized ledger. However, all token transfers will be monitored and recorded in real time by DTC through an off-chain system called LedgerScan, and LedgerScan’s records will constitute DTC’s official ledger. If a participant wishes to exit the tokenized state, they can issue a “de-tokenize” instruction to DTC at any time. DTC will then destroy the tokens and revert the securities rights back to their traditional accounts. NAL also details the technical and risk control restrictions, including: tokens can only be transferred between wallets approved by DTC, so DTC even has the authority to forcibly transfer or destroy tokens in wallets under certain circumstances; the token system and DTC’s core clearing system are strictly isolated, etc. (2) What is the significance of this letter? From a legal perspective, it is important to emphasize that the NAL is not equivalent to legal authorization or rule modification. It does not have universally applicable legal effect, but only represents the enforcement attitude of SEC staff under given facts and assumptions. The U.S. securities law system does not contain a separate provision “prohibiting the use of blockchain for ledgers.” Regulators are more concerned with whether existing market structures, custodial responsibilities, risk control, and reporting obligations are still met after the adoption of new technologies. Furthermore, in the U.S. securities regulatory system, letters like the NAL have long been regarded as an important indicator of regulatory stance, especially when the recipient is a systemically important financial institution like the DTC, where their symbolic significance is actually greater than the specific business itself. Based on the disclosed information, the premise of the SEC’s exemption is very clear: DTC does not issue or trade securities directly on the blockchain, but rather tokenizes existing securities interests in its custody system. These tokens are essentially a “stake mapping” or “ledger representation” used to improve back-end processing efficiency, rather than altering the legal attributes or ownership structure of securities. The related services operate in a controlled environment on a permissioned blockchain, with strict limitations on participants, usage scope, and technical architecture. Crypto Law believes this regulatory stance is very reasonable. On-chain assets are most prone to financial crimes such as money laundering and illegal fundraising. 토큰ization technology is a new technology, but it should not become an accomplice to crime. Regulators need to acknowledge the potential of blockchain applications in securities infrastructure while adhering to the boundaries of existing securities laws and custody systems. IV. Latest Developments in US Stock Market Tokenization
The discussion surrounding tokenization in the US stock market has begun to shift from “whether it’s compliant” to “how to implement it.” If we break down current market practices, we can see at least two parallel but logically different paths emerging: DTCC and DTC represent tokenization paths led by official 가이드lines, with the core objective of improving settlement, reconciliation, and asset transfer efficiency. Their primary target audience is institutional and wholesale market participants. In this model, tokenization is almost “invisible”; for end-investors, stocks remain stocks, only the back-end system has undergone a technological upgrade. 대조적으로, brokerages and trading platforms may play a leading role. Take Robinhood and MSX MetQ as examples; in recent years, they have continuously explored products related to 암호화폐 assets, fragmented stock trading, and extended trading hours. If the tokenization of US stocks gradually matures in terms of compliance, these platforms naturally possess the advantage of becoming user entry points. For them, tokenization does not necessarily mean reshaping their business model, but rather a technological extension of the existing investment experience, such as closer real-time settlement, more flexible asset splitting, and the integration of cross-market product forms. Of course, all of this is predicated on the gradual clarification of the regulatory framework. Such explorations typically operate near regulatory boundaries, with risks and innovation coexisting. Their value lies not in short-term scale, but in validating the next generation of securities market forms. From a practical perspective, they are more like providing samples for institutional evolution than directly replacing the existing US stock market. To make it more intuitive for everyone to understand, please see the following comparison chart: V. Viewpoints on Encrypted Salads
From a broader perspective, the real problem that US stock tokenization attempts to solve is not simply turning stocks into “cryptocurrencies,” but rather how to improve asset circulation efficiency, reduce operating costs, and reserve interfaces for future cross-market collaboration while maintaining legal certainty and system security. In this process, compliance, technology, and market structure will engage in a long-term, parallel interplay, and the evolutionary path will inevitably be gradual rather than radical. It is foreseeable that the tokenization of US stocks will not fundamentally change the way Wall Street operates in the short term, but it is already an important project on the US financial infrastructure agenda. This interaction between the SEC and DTCC is more like a “trial run” at the institutional level, setting initial boundaries for broader exploration later. For market participants, this may not be the end, but rather a starting point truly worth continued observation. Special Note: This article is an original work by the CryptoShaLaw team and represents only the author’s personal views. It does not constitute legal advice or counsel on any specific matter. For reprint authorization, please contact shajunlvshi via private message. 이 글은 인터넷에서 퍼왔습니다: On-the-spot report | Web3 lawyers interpret the latest changes in US stock tokenization Related: Tiger Research: We maintain our $200,000 price target amid heightened market volatility. Amid heightened market volatility, we maintain our $200,000 price target. This report assesses the nature of the current pullback and the sustainability of the long-term fundamentals. Key points summary The US government shutdown has lasted 35 days, causing short-term pressure —the US Treasury’s TGA liquidity is frozen, and Polymarket predicts there is a 73% chance the shutdown will continue beyond mid-November. Record-breaking forced liquidations dampened market sentiment – the forced liquidations on October 10th amounted to $20 billion, affecting 1.6 million traders, clearing out excessive leverage and triggering a temporary pullback in the market. The fundamentals remain solid, and the long-term upward trend remains unchanged – global liquidity is expanding, with M2 broad money supply exceeding $96 trillion, institutional investors are maintaining strategic buying, and the target price for Bitcoin… # 분석# 암호# 교환# 가이드# 마켓# 토큰# 웹3© 版权声명배열 上一篇 암호화폐 시장 매크로 연구 보고서: 연준 금리 인하, 일본은행 금리 인상, 크리스마스에 따른 유동성 가격 재조정 下一篇 Is the DA war coming to an end? Deconstructing PeerDAS: How can it help Ethereum reclaim "data sovereignty"? 상关文章 The Man Who Shilled SOL the Loudest Exits the Crypto World 6086cf14eb90bc67ca4fc62b 7,904 KTA conspiracy group was exposed, revealing the extramarital affair of former Google CEO Schmidt 6086cf14eb90bc67ca4fc62b 28,243 1 A look at the Solana AI Hackathon projects: Which innovations are worth paying attention to? 6086cf14eb90bc67ca4fc62b 47,100 1 Why did HashKey become the “first crypto stock in Hong Kong”? 6086cf14eb90bc67ca4fc62b 19,492 Telegram Cocoon is now online; your graphics card can now mine TON! 6086cf14eb90bc67ca4fc62b 16,475 4 Capital bets on the prediction market, who is better, Polymarket or Kalshi? 6086cf14eb90bc67ca4fc62b 30,835 1 Bee.com 세계 최대의 Web3 포털 파트너 코인카프 바이낸스 코인마켓캡 코인게코 코인라이브 갑옷 Bee Network 앱을 다운로드하고 web3 여정을 시작하세요 백지 역할 자주하는 질문 © 2021-2026. 모든 권리 보유. 개인 정보 정책 | 서비스 약관 꿀벌 네트워크 앱 다운로드 Web3 여정을 시작해보세요 세계 최대의 Web3 포털 파트너 CoinCarp Binance CoinMarketCap CoinGecko Coinlive Armors 백지 역할 자주하는 질문 © 2021-2026. 모든 권리 보유. 개인 정보 정책 | 서비스 약관 찾다 찾다사이트에온체인사회의소식 熱门推荐 : 에어드롭 헌터 데이터 분석 암호화폐 유명인 함정 탐지기 한국어 English 繁體中文 简体中文 日本語 Tiếng Việt العربية Bahasa Indonesia हिन्दी اردو Русский 한국어
智能索引记录
-
2026-02-28 03:43:02
综合导航
成功
标题:Privacy Policy – M22
简介:Privacy: At M22 we value your privacy and are committed to s
-
2026-02-27 14:59:24
综合导航
成功
标题:Fkk Monte Carlo "Frühlingsparty mit Jenna Jane und Trinity Smith " [Archiv] - BW7 Forum
简介:Samstag, 28. April ein Tag den man im Kalender ankreuzen sol
-
2026-02-27 20:55:17
综合导航
成功
标题:6 Reasons Why Sydney is the Best Place to Study English
简介:Discover why Sydney is an awesome place to explore while you
-
2026-02-27 18:27:17
综合导航
成功
标题:AMERICAN WEIGH Calibration Services Tektronix
简介:Tektronix can manage 100% of your calibration needs.Tektroni
-
2026-02-28 03:35:31
综合导航
成功
标题:Close quarters. World English Historical Dictionary
简介:Close quarters. World English Historical Dictionary
-
2026-02-28 06:34:02
综合导航
成功
标题:VINTAGE WASH SWEATSHIRT – M22
简介:Get the lived-in look with the M22 Vintage Wash Sweatshirt.
-
2026-02-27 15:09:50
综合导航
成功
标题:CENTRAL CAROLINA SCALE Calibration Services Tektronix
简介:Tektronix can manage 100% of your calibration needs.Tektroni
-
2026-02-28 10:32:40
职场办公
成功
标题:海南省2019年中级注册安全工程师成绩合格名单(154人)-中级注册安全工程师-233网校
简介:海南省2019年度中级注册安全工程师职业资格考试成绩合格人员公示,详情如下:根据《司法部关于印发开展证明事项告知承诺制试
-
2026-02-28 07:14:11
综合导航
成功
标题:Get a PS5 for NOTHING up front with a monthly payment plan T3
简介:You don
-
2026-02-27 23:39:24
新闻资讯
成功
标题:602《赤月传说》59服6月2日13时震撼开启 - 新闻公告 - 602游戏平台 - 做玩家喜爱、信任的游戏平台!cccS
简介:602《赤月传说》59服6月2日13时震撼开启
-
2026-02-28 07:18:37
综合导航
成功
标题:Specialty Building Products Homepage United States
简介:Located in Georgia, SBP is the leading distributor of specia
-
2026-02-27 22:18:34
综合导航
成功
标题:Schulmöbel - a2s.com
简介:Entdecken Sie unser vielfältiges Schulmöbel-Sortiment. In De
-
2026-02-28 00:22:20
综合导航
成功
标题:シングルテイクで撮影する Galaxy Z Fold5 SCG22 オンラインマニュアル(取扱説明書) au
简介:auのスマートフォン「Galaxy Z Fold5(ギャラクシー ゼット フォールドファイブ)SCG22」Android
-
2026-02-28 06:20:17
综合导航
成功
标题:Expert Services - Sir Robert McAlpine
简介:View our construction service.
-
2026-02-28 10:44:41
综合导航
成功
标题:au
简介:auのオフィシャルサイト。個人のお客さま向けサービスをご紹介します。
-
2026-02-27 16:00:34
综合导航
成功
标题:福汇官方
简介:福汇:提供自动报靶设备,智能移动靶,单兵起倒靶,多功能靶,导电升降靶等设备,射击瞄准分析系统,影像报靶系统等产品技术解决
-
2026-02-27 22:59:03
综合导航
成功
标题:DAMI Artisans du numérique pour les pros - Valence
简介:Artisans du numérique depuis 1990, Dami basée à Valence, faç
-
2026-02-27 20:17:19
综合导航
成功
标题:Tara Jackson CBN
简介:Tara has been working at CBN since 2019. You can catch her a
-
2026-02-27 19:42:23
综合导航
成功
标题:Домен GEN IN: купить доменное имя в зоне GEN IN и зарегистрировать на Рег.ру
简介:Открыта регистрация домена в зоне ✔️ GEN.IN! Зарегистрируйте
-
2026-02-28 10:27:26
综合导航
成功
标题:ISG job portal - Code of Conduct
简介:Code of Conduct. ISG Personalmanagement GmbH commits itself
-
2026-02-27 20:45:16
综合导航
成功
标题:Color Pixel Art Classic - Free Online Game on 4J.com
简介:Color Pixel Art Classic is a free online game on 4j.Com. You
-
2026-02-27 16:25:29
新闻资讯
成功
标题:数据中心各种冷却技术的应用与发展, 站长资讯平台
简介:为了满足各种类型和规模数据中心的冷却需求,冷却技术仍在不断发展,例如托管数据中心、云平台、企业内部部署数据中心以及边缘数
-
2026-02-27 19:05:44
综合导航
成功
标题:乳腺增生的症状 - 云大夫
简介:乳腺增生症主要表现为月经之前乳房会有肿块,伴有疼痛、压痛,月经过后这些症状会消失。对于绝大多数的乳腺增生症来说,都是不需
-
2026-02-28 10:39:00
综合导航
成功
标题:Press Release Distribution - Grow Your Business - PR.com
简介:Achieve your marketing and communications goals with PR.com&
-
2026-02-28 06:02:29
综合导航
成功
标题:Morgan Stanley’s 24th Annual Asia Pacific Summit: CNBC Report Morgan Stanley
简介:Watch Morgan Stanley Co President Dan Simkowitz and Asia CEO
-
2026-02-28 10:08:38
综合导航
成功
标题:Pufferlager
简介:Ein Pufferlager oder auch Kurzzeitlager ist ein vorübergehen
-
2026-02-28 06:21:13
综合导航
成功
标题:免费预约短信提醒,不错过2020年河南安全工程师报名时间!-中级注册安全工程师-233网校
简介:2020年河南安全工程师报名时间暂未公布,预计8月份启动。233网校为了避免考生错过报名考试,特免费提供短信提醒功能,下
-
2026-02-28 09:27:45
综合导航
成功
标题:Confronta gli Apple Watch - Apple (IT)
简介:Confronta le specifiche tecniche dei nuovi modelli di Apple
-
2026-02-27 15:05:38
综合导航
成功
标题:Producto - Grupo CHT - Químicas especiales
简介:CHT - aditivos químicos y productos químicos especiales para
-
2026-02-27 19:16:25
综合导航
成功
标题:Объявления RIA.com: Бесплатная доска объявлений Украины
简介:Быстрая покупка и продажа товаров на бесплатной доске объявл