The U.S. Securities and Exchange Commission on September 1, 2026, proposed the first substantive overhaul of transfer agent regulations since the late 1970s, explicitly writing blockchain-based recordkeeping into the federal securities rulebook. The proposal covers approximately 342 registered an...
The U.S. Securities and Exchange Commission on September 1, 2026, proposed the first substantive overhaul of transfer agent regulations since the late 1970s, explicitly writing blockchain-based recordkeeping into the federal securities rulebook. The proposal covers approximately 342 registered and anticipated transfer agents, introduces two new compliance rules (17ad-30 and 17ad-31), and carries an estimated initial industry compliance cost of $23.3 million.
Separately, the SEC announced a September 17 roundtable on 24-hour equity trading, bringing 17 major market participants — including NYSE, Nasdaq, Citadel Securities, DTCC, BlackRock, and Citi — to discuss operational readiness for around-the-clock markets. The two actions, released on the same day, represent the clearest signal yet that U.S. securities regulators are building a framework in which blockchain-native infrastructure and traditional market plumbing operate under a single set of rules.
The timing is not incidental. Tokenized real-world assets (excluding stablecoins) now exceed $31 billion on-chain, up roughly 300% year-over-year. Firms such as Securitize already operate as SEC-registered transfer agents for tokenized funds, including BlackRock's BUIDL. The proposal acknowledges this reality and attempts to bring regulatory standards up to speed.
The proposal, released under SEC Chairman Paul Atkins' ACT (Advance, Clarify, Transform) agenda, amends registration and reporting requirements on Forms TA-1 and TA-2. It modernizes rules governing recordkeeping, securities transfer processing, safeguarding of investor assets, and restrictive legends on securities.
Key structural changes include:
Two new rules are introduced:
The comment period runs 60 days from Federal Register publication.
The proposal does not create a separate regulatory category for blockchain-based transfer agents. Instead, it modifies existing requirements so that blockchain-based recordkeeping, distributed ledger technology, and uncertificated securities operate within the same framework as traditional systems.
According to the SEC, "market participants are actively seeking to bring blockchain-native, or 'onchain' transfer agents into the U.S. market." The proposal responds by:
Recognizing blockchain as an acceptable recordkeeping medium. Transfer agents may use distributed ledgers as official records of ownership and transactions, provided they meet the same safeguarding, cybersecurity, and retention standards as traditional electronic or paper records.
Requiring disclosure of supported blockchains and tokenized assets. Expanded reporting on Forms TA-1 and TA-2 mandates that transfer agents disclose which blockchains they operate on and what tokenized assets they administer.
Mandating written cybersecurity policies. Transfer agents using DLT must implement controls addressing blockchain data integrity, security of tokenized securities, and distributed ledger operational models.
Covering cross-chain interoperability. The proposal addresses risks arising from tokenized fund administration and cross-chain interoperability, acknowledging that on-chain transfer agents increasingly operate across multiple networks.
Establishing AI and automation controls. Transfer agents adopting AI or automated technologies must ensure accurate representations of system capabilities and effective oversight of automated processes.
The proposal does not endorse any specific blockchain or technology stack. It is technology-neutral by design, applying the same compliance standards regardless of whether a transfer agent uses Ethereum, Stellar, Avalanche, or any other network.
Jamie Selway, Director of the SEC's Division of Trading and Markets, described the proposal as "another important step in Chairman Atkins' efforts to advance our regulatory framework for the modern era."
The SEC estimates total initial compliance costs at $23.3 million across approximately 342 registered and anticipated transfer agents. The breakdown:
| Category | Estimated Cost | |---|---| | Recordkeeping overhaul (Rules 17ad-6, 17ad-7) | $12.6 million | | Unresponsive-payee notifications (Rule 17ad-17) | $5.1 million | | Turnaround standards (Rule 17ad-2) | $2.8 million | | Compliance policy rule (Rule 17ad-30) | $2.4 million | | Total | $23.3 million |
Per-entity costs average roughly $68,000 for initial compliance. Ongoing annual costs are described as "comparatively modest" post-implementation. The SEC did not specify a target date for final rule adoption; the 60-day comment period is the immediate next step.
For context, $23.3 million is a modest figure relative to the assets under administration. The nontraded and semi-liquid alternative investment sector alone — including nontraded REITs, business development companies, and interval funds — held over $530 billion in net assets by end-2025, according to the SEC filing. Transfer agents serve as the sole ownership record system for these unlisted securities.
The same day it published the transfer agent proposal, the SEC released the agenda for a September 17 roundtable on preparations for 24-hour equity trading. The roundtable will run from 10 a.m. to 4 p.m. ET at SEC headquarters in Washington, D.C.
Seventeen firms are confirmed as panelists, including:
Panel topics cover exchange and broker-dealer operational readiness, surveillance capabilities for overnight sessions, clearance and settlement mechanics, and Regulation SCI (Systems Compliance and Integrity) requirements.
The connection to the transfer agent proposal is structural. Around-the-clock equity trading would require settlement infrastructure that operates continuously, not just during business hours. Blockchain-based transfer agents and tokenized securities offer a technical path to continuous settlement, since on-chain systems already operate 24/7. The SEC appears to be building both sides of the equation simultaneously: the regulatory framework for on-chain transfer agents and the operational framework for extended-hours trading.
The regulatory action arrives as on-chain tokenized assets reach record levels.
Long-term projections remain wide-ranging. Boston Consulting Group estimates tokenized RWAs could reach $16 trillion by 2030. McKinsey projects $2-4 trillion in a base case. Citigroup estimates $4-5 trillion by 2030.
For traditional transfer agents. The rescission of Rule 17ad-4 exemptions brings previously exempt entities — including those handling fewer than 500 items per six months — under full regulatory coverage. The 95% turnaround standard (up from 75%) raises operational bars across the industry. Smaller agents may face proportionally higher compliance burdens.
For on-chain transfer agents. The proposal provides regulatory clarity that has been absent. Firms operating on blockchain infrastructure now have a defined compliance framework rather than operating in ambiguity. The requirement to disclose supported blockchains and tokenized assets creates transparency but also establishes a public record of which networks serve as securities infrastructure.
For tokenized fund issuers. The rule strengthens the legal foundation for tokenized securities. Fund issuers using on-chain transfer agents — as BlackRock does with Securitize for BUIDL — gain a clearer regulatory basis for their operations. The enhanced restrictive-legend requirements (Rule 17ad-31) add compliance overhead but also reduce legal risk around securities transfer restrictions.
For the broader market. The simultaneous release of the transfer agent proposal and the 24-hour trading roundtable suggests the SEC views blockchain infrastructure and extended trading hours as complementary rather than competing priorities. If both advance, the result could be a securities market that operates continuously on blockchain-based rails with traditional regulatory oversight.
The SEC's transfer agent proposal is a regulatory catch-up action, not a forward-looking experiment. The rules being updated were written before the internet existed. The assets being regulated — tokenized funds, on-chain ownership records, cross-chain interoperability protocols — already exist and are already operating under the oversight of registered transfer agents like Securitize.
What the proposal does is remove ambiguity. Blockchain-based recordkeeping is now explicitly within scope of transfer agent regulation, not in a gray zone adjacent to it. The $23.3 million compliance cost estimate signals that the SEC views this as an incremental modernization, not a structural upheaval.
The more consequential development may be what happens on September 17, when the SEC convenes NYSE, Nasdaq, Citadel, DTCC, and 13 other firms to discuss 24-hour trading. If U.S. equity markets move toward continuous operation, blockchain-based settlement and transfer infrastructure becomes not merely permissible but functionally necessary. The transfer agent proposal builds the regulatory floor. The 24-hour trading discussion points toward the ceiling.