Evidence behind each letter

The order does not provide meaningful investor or issuer protection.

The opening thesis is that the order fails its stated protective purpose, and the letter asks for no change that would keep it.

We support the Innovation Exemption.

Supports the order and asks for additions to the notice and the published data.

A holder should be able to designate an adviser or reporting agent that can read the holder's fills and positions on a TSV without being a trading participant.

Would require venues to give a holder's designated adviser read access to the holder's records.

Each TSV's public notice should include a published registry of the token contracts it trades, mapped to the underlying security's CUSIP and FIGI

Adds a required machine-readable registry of token contracts to the notice.

We recommend that TSVs and tokenizers publish corporate action events in a standard form

Adds a requirement to publish corporate action events in a standard form, so that equal treatment of holders can be traced across venues.

We recommend a public, timestamped event log for halts, pool parameter changes and access-standard changes

Adds a required public log of halts, pool changes and access-standard changes.

We ask the Commission to work with Treasury on a basis carrying standard for tokenized NMS stock

We suggest the Commission treat that determination, rather than the mechanism that produces it, as the object of the condition.

Supports the order and proposes conditions for a permanent version.

The determination should be made against the current state of the relevant records at the time access is exercised, not only at onboarding.

Adds conditions that access be checked at the time of trading and that each check leave an independently verifiable signed record.

is workable and, in our experience, is the design that scales.

Supports the public, permissionless ledger condition as granted.

We suggest that the public notice ask a venue to state how parity was verified at listing and how it is monitored thereafter

Adds notice content on how rights parity is verified and monitored, and a signed record of each determination.

We note that the same two properties apply to the Covered Firm Exemption

Would apply the same access-check conditions to liquidity providers.

We support making the TSV Exemption permanent

Supports a permanent exemption with the current conditions; keeps five years for the interim order.

Owning something fake is un-American.

Rejects the order as serving market makers and hedge funds rather than investors.

The following reporting details would help outside readers interpret the resulting evidence

Asks for added reporting detail and disclaims a view on the order's overall merits.

A machine-readable revision identifier, effective time, change category and predecessor reference could make those versions easier to compare.

Adds machine-readable revision metadata to notice versions.

Preserve stable event and instrument references alongside the fields already required by II.G.

Adds required timestamp, identifier and revision detail to the published transaction data.

For II.H, retain the reference stoppage, relevant venue action and evidence of scope.

Adds a requirement to keep evidence of each stoppage and its scope.

Keep the same-rights line. Make it machine-checkable.

Accepts the order's conditions and asks for additions.

Do not expand the exemption to synthetics.

Supports the exclusion of synthetic products as granted.

issuer notice and objection must be verifiable by a party other than the listing TSV.

Requires issuer notice and objection records to be verifiable outside the listing venue.

require each TSV listing to publish a structured attestation covering dividend rights, voting rights, same-class privileges, tokenizer kind, and notice/veto state.

Adds a required published attestation of rights for each listed token.

require periodic public data on listed symbols, notional versus cap, halt state versus the primary listing exchange, and the attestation hash for each listed token.

Adds required public data on each symbol's use of its cap.

Bitcoin Bancorp supports the Commission’s use of a temporary and conditional framework

Supports the framework and asks for guidance and one amendment.

That perimeter should remain bright during the initial observation period.

Supports the NMS-only perimeter for now and asks for OTC stock to be considered in a separate proceeding.

Bitcoin Bancorp respectfully requests clarification that providing one or more of those services does not, standing alone, cause the provider to operate the TSV or to act as a broker or dealer

If granted, identity, funding, conversion and wallet providers that perform no securities functions would sit outside the TSV and outside broker or dealer status.

In one prominent, plain-English statement, a notice should identify whether the token represents the underlying security

Adds a required consolidated plain-English statement to the notice.

confirm that forming or using an additional affiliated venue does not reset a symbol limit, volume limit, or required trading pause.

Supports the limits and asks how affiliation applies to on-chain arrangements, without a change in the limits.

The Commission or staff should consider going one step further and publishing a simple common data schema for the machine-readable reports required from TSVs.

A common schema would fix the format of the required transaction reports; the letter supports keeping ten-minute reporting.

should stop affected trading whenever reliable halt-status information is unavailable

Adds a requirement to stop trading when reliable halt information is unavailable.

The conditions applicable to Covered Firms also provide an appropriate starting point.

Supports the Covered Firm conditions as granted.

Bitcoin Bancorp supports the five-year term

Supports the five-year term as granted.

Bitcoin Bancorp encourages the Commission to consider, in a separate public proceeding, a comparable framework for tokenized OTC equity securities

I support the Order. By conditioning relief on the token conferring

Supports the order and asks for changes to several conditions.

the Order should say expressly that it draws no inference about the status of any pool that has no TSV

If granted, a person who deploys a pool and keeps no control would not provide it, and pools with no operator would be marked as outside the order's reasoning.

My answer is yes as to securities tokenized by or on behalf of their issuer

Asks to admit issuer-tokenized securities of non-NMS companies and fully backed, redeemable tokens.

a TSV whose ledger ceases to qualify have a fixed period in which to migrate or wind down, after which the exemption lapses

Asks for a definition of public and permissionless based on who holds power over the ledger, continuing checks, and lapse of the exemption when a ledger stops qualifying.

The Commission should confirm that a group may rely on the exemption through a U.S. legal entity which the group has designated to perform the TSV's obligations

Would let a dispersed group, including non-U.S. members, rely on the exemption through a designated U.S. entity.

Accordingly, I ask the Commission to add the following conditions.

Adds conditions: published tokenization documents, a statement of what the token legally is, published transfer-agent policies, and no exemption where the token's link to the stock rests on unbounded off-chain trust.

ask the Commission to carry that statement into the dealer rulemaking noted in footnote 114 without limiting it to pools operated under the TSV Exemption.

Asks that liquidity provision be treated as trader activity beyond TSV pools, and for a period to withdraw liquidity before a Covered Firm loses the exemption.

committing that the exemptions will remain in effect until a final rule replacing them becomes effective

Asks that the exemptions run until a replacing final rule takes effect, in place of the fixed 2031 end date.

the Order should say so in its operative text rather than leaving it to a press statement.

We propose these adaptations of the existing TSV conditions.

Accepts the order and asks for it to reach a further category of securities.

We ask that the exemption allow this mechanism under the same transparency and smart-contract conditions.

Asks that an on-chain order book be allowed alongside AMM pools.

Our answer is yes, for one category: equity tokenized by its own issuer, where the issuer is not listed.

Asks to admit issuer-tokenized equity of non-listed issuers, with adapted conditions.

The U.S.-person requirement for TSVs is sound for sanctions compliance.

Supports the U.S.-person condition as granted.

A five-year window is long enough to gather data.

Supports the five-year term.

We are filing a petition for rulemaking under Rule 192 alongside this letter that sets out the framework in full

I support responsible technological innovation in U.S. capital markets.

Supports innovation and asks for rules before the market grows.

One legitimate share should have one accountable and auditable chain of ownership and availability across the entire market infrastructure.

Asks for rules on backing verification, prevention of duplicate claims and an end-to-end audit trail between the token and the underlying share.

Can a tokenized NMS share support, directly or indirectly, a Regulation SHO locate

This comment identifies a framework the Commission could evaluate

Accepts the order and proposes a further category for evaluation.

Tier 2 Regulation A securities present a concrete category for the Commission to evaluate

Asks the Commission to consider admitting Regulation A Tier 2 equity through a pilot with its own conditions.

The exemption creates an important controlled environment for learning how tokenized NMS stock behaves in production.

Describes research on downstream investor systems and asks for no change to the order.

the Commission could encourage empirical work on how firms map, aggregate and supervise economically equivalent exposures across conventional and tokenized holdings.

The Commission should address those questions now.

Accepts the order and asks for its approach to be extended now.

urges the Commission to expand its tokenized-securities initiative beyond the narrow relief in the September 17, 2026 order.

Asks for a parallel exemption for OTC equity, including automated market makers and decentralized systems.

as a petition under Rule of Practice 192(a) for rules implementing the substance described above.

We ask the Commission to confirm that changing the recording format of the same duly issued share

Condition G should be modified.

Accepts the order and asks for one change.

Add the following paragraph to Condition G (new text; nothing above is deleted):

Adds a required size-indexed round-trip recovery series, with fee tiers and block references, to the transaction data.

I respectfully suggest that the Commission consider a controlled pilot

Accepts the order and asks for it to reach further securities.

Modify or expand the TSV framework, whether now or through a subsequent pilot, to permit the secondary trading of appropriate securities beyond Tokenized NMS Stock.

Asks to admit lawfully issued securities beyond NMS stock, including tokenized investment fund interests.

I believe that principle is important and should be retained if the framework is expanded.

Supports the same-rights condition as granted.

Include qualifying tokenized interests in investment funds among the securities considered for such a pilot.

In answer to the requests for modifications in Questions 1, 3, 5 and 6, we suggest four properties

Accepts the order and proposes properties for the published data.

we suggest four properties that the Commission could expect from a TSV's transaction data under Section II.G.

Adds required publication properties: records recomputable from the ledger, named abstentions, signed and chained digests, and dated periods.

Vertalo supports the Order. This comment is about what it leaves out.

Supports the order and asks for changes on the record layer beneath it.

It should, and the register is what makes it safe.

Asks to admit Regulation A, D and Crowdfunding securities and OTC equity tokenized from the issuer's register, with issuer consent.

The Commission should confirm that a TSV may meet its verification by relying on that record

Asks for confirmation that a venue may rely on the transfer agent's eligibility record for participant verification, with the venue remaining responsible.

The Notice should ask the TSV to describe which of its compliance functions are automated, which are performed by a service provider, and where a person intervenes.

Adds notice content on which compliance functions are automated or delegated.

Confirm that an issuer may lodge a standing objection in advance, effective against all TSVs

Asks for a standing objection effective against every venue and a public register of objections; also asks to confirm that tokenization by the issuer's transfer agent on its instruction counts as issuer tokenization.

Item III.i should ask for more:

Adds notice content on the custodian, how often and how token supply is reconciled to shares, who attests to it, and who is holder of record while tokens sit in a pool.

The Commission or the staff should confirm that a TSV may satisfy the conditions in Sections II.D through II.L through automated systems operated by a service provider identified under Item III.aa

Asks for confirmation that automated service-provider systems with an audit trail, and records kept with a registered transfer agent, can meet the books-and-records condition.

While I applaud the Commission’s overall efforts in the Order, I have serious concerns

Supports the order and asks for one change.

I recommend that the definition of “permissionless” in section II.A be revised at minimum as follows:

Asks for a narrower definition of permissionless that excludes ledgers where a gatekeeper controls consensus.

Three amendments follow:

Corrects the author's earlier letter and keeps its request for a change.

Require the venue to enumerate the pools it routes through, across protocol versions and factories, and to publish how that list was enumerated.

Adds required fields to the transaction data: filled fraction, one-sided slippage, and the list of pools routed through.

So far, the SEC deserves credit for its pro-innovation stance

Commends the order and recommends keeping it temporary.

a five-year period provides a sufficient starting point.

Recommends keeping the exemption temporary at five years; a seven-year term is offered only as an alternative.

The Commission is not free to exempt anyone from a congressional mandate.

Argues the order is unlawful.

Such usurpation of the legislative power that rightly belongs to Congress

is the order’s central protection for investors.

Accepts the order and asks for additions to the notice.

The Notice could identify each paired asset’s issuer, reserve custodian and redemption terms, with a date.

Adds required disclosure about each paired asset.

A short machine-readable summary per stock could give the same comparability

Adds a required machine-readable summary per stock and new events that trigger a revised notice.

The Commission may wish to have each Notice state, per Tokenized NMS Stock, the date of verification, the documents examined, who performed it, and whether that party is independent of the tokenizer.

Adds required notice content on the scope, date and author of each rights verification and on the redemption route.

clarity on how tokenized money market fund pairing interacts with it would help participants.

we support the Commission

Supports the framework and asks for implementation guidance.

We would welcome implementation guidance or illustrative scenarios explaining how

Asks for guidance on how broker-dealers may connect their own on-chain infrastructure to venues under the existing framework.

we respectfully suggest that the Commission consider convening broker-dealers, transfer agents

Accepts the order and asks for stricter conditions and enforcement.

Adds a required public registry of issuer notices and objections.

Asks that the same-rights condition be enforced as granted.

Asks that the symbol limits, affiliate aggregation and trading pause be kept and enforced as granted.

Adds a requirement to report venue transactions to the Consolidated Audit Trail in real time.

Adds auditable verification of Covered Firms' assets.

We commend the Commission for establishing the important notice and objection protections

Supports the issuer notice and objection protections and asks for changes to how they operate.

publish a register of TSVs operating under the Order in a centralized, searchable format

Asks the Commission to publish the notices of intent it receives from TSVs and keep a searchable register of operating TSVs and the tokenized stocks each one trades.

provide prompt guidance that an issuer may establish a standing objection to the trading on any TSV

Asks that an issuer be able to file one standing objection, posted on its own or its transfer agent's website and sent to the Commission, that applies to every TSV; that the Commission publish a register of issuer objections; and that TSV notices reach issuers by email and mail and also go to the issuer's transfer agent.

a move to ensure the validity of stock ownership is a good thing

Calls the order a good thing on the condition that ownership can be publicly verified.

but only if every step of ownership can be publicly verified

Accepts the token-to-share link only if every step of ownership can be publicly verified and the holder keeps the full rights of a directly registered shareholder.

We submit this comment to raise a distinction we believe the Commission should consider as it refines the Innovation Exemption framework

Accepts the order and asks for changes as the framework is refined.

Tokenized registered-fund shares do not need, and should not receive, AMM or TSV venue relief.

Asks that relief not be extended to shares of registered investment companies, which trade at net asset value through the fund and its transfer agent rather than on a venue.

requiring that any tokenized security traded on a TSV be subject to an authoritative recordkeeping function equivalent to that of a registered transfer agent

Supports the same-rights condition and asks that every tokenized security traded on a TSV be backed by a register kept to the standard of a registered transfer agent.

tokenized shares of a registered fund present a materially different structure from the tokenized NMS equities the exemption addresses

PAG's principal recommendation is that the Commission distinguish initial compliance with the Innovation Exemption from continuing evidentiary sufficiency after material change.

Accepts the order and asks for an added duty to revisit compliance after material change.

PAG therefore recommends that Tokenized Securities Venues maintain a concise Reliance and Revalidation Record

Asks that each TSV keep a record of the evidence that a token carries the same rights as the share, its dependencies and the changes that would require that evidence to be checked again.

We propose two solutions for the Commission’s consideration:

Does not challenge the order and asks for two changes to the issuer notice and objection condition.

the Commission should amend the Order to require an issuer’s affirmative consent to the tokenization of its securities by any third party, including a TSV, without any deadline to do so.

Asks that a TSV need the issuer's affirmative consent, with no deadline, in place of the 30-day objection period, and that the Commission keep a public list of issuers that do not want their stock tokenized under the order.

We strongly support the Commission’s efforts to develop this regulation, but urge the Commission to clarify the definition of

Supports the order and asks for one clarification of the distributed ledger condition.

We suggest that the current exemption clarify this distinction by stating that smart contracts used by a TSV may be deployed on public distributed ledgers without delineating between permissionless and permissioned networks.

Asks that the condition refer to a public distributed ledger without the term permissionless, so that a public ledger whose node operators are approved qualifies; the letter states that its own network already meets the order's definition.

Tokenized stocks should be subject to the same registration, transparency, and market integrity standards that apply to traditional securities.

Says tokenized stocks should be subject to the same registration and related standards as traditional securities and asks the Commission to evaluate whether the relief preserves them; asks for no change that would keep the order.

We support the Order.

Supports the order and asks the staff for guidance on oracle and market data sources and on dollar conversion, without a change to the order.

We respectfully request that the staff consider providing vendor-neutral principles that a TSV should consider when it relies on an oracle or market data source for price bands, volatility safeguards, manipulation surveillance, or the other purposes disclosed under Order items (s), (z) and (cc)

Asks the staff to publish principles for evaluating oracle and market data sources, which a TSV would describe in its Notice under the existing market data item; the letter says this needs no modification of the order.

We ask the staff to confirm that a TSV may satisfy the “consistent, impartial, and reasonable” standard by applying the principles described above and identifying the source in its notice under item (s).

Asks the staff to confirm how a TSV may derive the dollar values the transaction data and records require, using a reference price that meets stated principles.

The Order therefore creates a natural experiment that can show what traders pay for trading oversight.

Treats the order as a natural experiment on trading oversight and asks for seven added data conditions, none of which requires a TSV to perform oversight.

(1) full disclosure of conversion terms in each Notice;

Asks that each Notice state whether, by whom, when and at what cost a token converts into the underlying stock, and that each TSV report yearly the proxy distribution and votes cast through the pass-through mechanism.

(2) public retention of transaction data for the full term of the exemption; (3) hourly publication of AMM Liquidity Pool sizes

Asks that transaction data stay public for the full term in place of 30 days, that pool size and near-price liquidity be published hourly, and that volume by type of participant and counts of oversight outcomes be published.

(7) confidential researcher access to TSV books and records under agreements that protect trader identity and account-level data

Asks that TSV books and records be open to researchers designated by the Commission under confidentiality terms, with yearly aggregate statistics published.

I support the Commission's decision to try this in a time-limited, conditioned way instead of waiting for a full rulemaking.

Supports a time-limited, conditioned order and proposes 50 provisions, each of which the letter says can be adopted on its own.

The TSV definition should also expressly allow permissioned onchain limit order books with atomic settlement, since a pool is not the only design that could meet the Order's goals

Asks that the definition admit permissioned on-chain order books and periodic batch auctions that settle atomically, and that a person who publishes an AMM contract and keeps no control not count as providing a pool.

A redeemable wrapper issued by an unaffiliated party should not be treated as a Tokenized NMS Stock

Asks that the order not expand beyond NMS stock for now and that a wrapper or a token giving the holder no direct interest or security entitlement not count as Tokenized NMS Stock.

For paired assets, require the disclosures in section 8 but do not limit the types now.

Asks for added Notice disclosures about each paired asset and a pause when a stable-value paired asset departs from its stated value, without limiting the types of paired asset.

A TSV must apply its standards for access to trading, including screening against the Specially Designated Nationals and Blocked Persons List under 31 CFR chapter V, at the time of each transaction

Asks that access standards, including sanctions screening, apply at the time of each trade or on a stated refresh cycle of no more than 24 hours, with annual re-verification, written reasons for a denial and consistent application.

A distributed ledger is public and permissionless for purposes of this Order only if (i) any person may read the state of the ledger and submit transactions to it without the authorization of any person

Asks for a definition of public and permissionless that depends on who holds validation power and upgrade authority, with disclosure of control, rules for layered ledgers and administrative controls, and independent audits of ledger applications.

the requirement to be a U.S. person under this section II.B is satisfied if the protocol designates, by binding onchain governance vote, a legal entity organized under the laws of the United States

Asks that a dispersed protocol meet the U.S.-person condition through a designated U.S. legal entity that holds the halt, Notice and records duties and consents to service and examination.

Each Notice and revised Notice must be published in plain English and in a machine-readable form, in the format specified under section II.M, in which each of items a through dd is separately tagged.

Asks for a defined list of material changes, a hash of each Notice recorded on the ledger and copied to the Commission, a tagged machine-readable Notice and a Commission register of Notices.

A Notice of Issuer Objection (1) applies to the Tokenized NMS Stock identified in it and, if it so states, to all Tokenized NMS Stock of that issuer tokenized by a third party; (2) remains effective until the issuer withdraws it in writing

Asks for a continuing issuer remedy after the 30-day period, a standing objection that reaches all of an issuer's third-party tokens until withdrawn, written issuer confirmation that a token is issuer-tokenized, and a new notice for a successor issuer.

For each Tokenized NMS Stock, the registered transfer agent acting for the issuer or, for a token backed by shares held by a custodian, the custodian, must reconcile the number of tokens outstanding to the number of underlying shares recorded or held as of the close of each business day and as of each record date

Asks that a registered transfer agent or custodian keep the master securityholder file, that entitlement follow the ex-date and record date, that tokens be reconciled to shares daily with a pause if uncured, that a custodian attest to segregated and unlent shares, and that pooled holdings pass entitlements to LP token holders.

In calculating volume and the number of symbols under this section II.F, a TSV must aggregate all Tokenized NMS Stock that represents the same underlying NMS stock, regardless of who tokenized it and regardless of the distributed ledger on which it trades

Keeps the tiers and asks that their basis be explained, with aggregation across tokens, chains and affiliates, a breach determination and one-business-day notice including the first exceedance, aggregate monitoring across TSVs, and a fixed tier-transition rule; a TSV could exclude documented wash volume.

in no event later than ten (10) seconds, after the transaction is included in a block on the distributed ledger

Asks that transactions be published within ten seconds of block inclusion in place of ten minutes, with block references, time stamps, finality status, fees, dollar reference rates, a depth disclosure every 30 minutes and 24 months of public history.

the TSV submits to the distributed ledger a transaction pausing trading in the affected Tokenized NMS Stock immediately upon receiving notice of the stoppage, and in no event more than five (5) seconds after receipt

Asks for a measurable meaning of stopping trading concurrently, two independent stoppage status sources, a pause when status is unknown, monthly testing and continued withdrawals during a pause; a TSV could also pause for a corporate action without failing a condition.

The TSV must notify participants within fifteen (15) minutes after it has a reasonable basis to conclude the event occurred, notify the Commission within twenty-four (24) hours, file a supplemental report within five (5) business days, and file a root-cause report within thirty (30) days.

Asks that significant operational events be defined by objective triggers with stated notice deadlines and a root-cause report, and that each ledger application have an independent security audit before first trading and yearly.

A TSV may not extend credit directly, or through an affiliate or an arrangement it controls.

Asks that the no-leverage condition also reach credit extended through an affiliate or an arrangement the TSV controls.

Trading on this venue is not approved or endorsed by the Securities and Exchange Commission.

Asks for a two-page plain-English disclosure sheet for each token carrying a stated disclaimer, added statements on investor protection coverage and broker-dealer status, and a recorded participant acknowledgment.

must preserve the records required by this section II.L for the longer of five (5) years after creation

Asks for a longer retention period and for records of administrative actions, failed transactions, oracle inputs and transaction ordering.

A Covered Firm must fund its deposits in AMM Liquidity Pools from unencumbered proprietary assets and may not use borrowed funds, customer assets, or assets pledged to others for that purpose.

Asks that a Covered Firm fund its deposits from unencumbered proprietary assets, keep a written loss-estimation method, report its wallet addresses and give notice before it first provides liquidity; also asks for a safe harbor and a withdrawal period for a Covered Firm that did not cause a venue breach.

Do not make either exemption permanent now. Five years is reasonable.

Keeps the five-year term and asks that neither exemption become permanent now; adds a staff report by September 2028, a second report in 2030 and a 180-day wind-down at any end of relief.

A TSV Participant that is a registered broker-dealer is not, solely by reason of routing a customer order to, or trading as principal on, a TSV operating pursuant to the TSV Exemption, a trading center or market center with respect to that TSV's AMM Liquidity Pools.

Asks the Commission to confirm that a broker-dealer is not a trading center solely by routing to or trading on a TSV, with its other obligations unchanged; also proposes net capital and customer protection treatment for LP tokens held by a broker-dealer.

The Commission states its position, or grants parallel relief, on clearing agency and transfer agent status (section VIII.8), coordinates anti-money-laundering treatment with FinCEN (section 7), and resolves Investment Company Act status for tokenized money market funds before they serve as paired assets (section 8).

Fifth, clearing agency status. A trade on a TSV settles at once on a public ledger, with no central counterparty and no clearing member.

Tokenized stocks should be subject to the same registration, disclosure, and accountability standards that apply to traditional securities.

Says tokenized stocks should be subject to the same registration and related standards as traditional securities and asks the Commission to evaluate whether the relief preserves them; asks for no change that would keep the order.

Tokenized stocks should be subject to the same registration, disclosure, and market integrity standards that apply to traditional securities.

Says tokenized stocks should be subject to the same registration and related standards as traditional securities and asks the Commission to evaluate whether the relief preserves them; asks for no change that would keep the order.

I want to invest in digital assets, but I need clear rules and consistent protections to do so.

Accepts the prospect of tokenized stocks and asks for clear rules and consistent protections.

I am particularly concerned about the issuer notification and opt-out process.

Asks that the issuer notice and opt-out process be clear, reliable and understandable, without naming a change to what it requires.

I also urge that the Commission develop, and communicate, a plan to ensure that U.S. markets remain stable for retirees.

Raises concern that tokenized stocks could add uncertainty for retirement savers and asks the Commission to monitor volatility and to develop and communicate a plan for market stability; does not ask that the order be withdrawn.

I encourage the Commission to provide clarity around the tokenization process and how it impacts investors.

Asks the Commission to make the tokenization process and its effect on investors clear; does not ask that the order be withdrawn.

The process for notifying companies about third-party tokenization and allowing them to object must be clear.

Asks that the issuer notice and objection process be clear to investors, including whether notice was given and whether the company objected, without naming a change to what the condition requires.

I respectfully ask the SEC to ensure that new rules around tokenized stocks do not introduce avoidable price swings or make existing markets more fragile.

Raises concern that tokenized trading across venues, or while trading in the underlying shares is limited, could make prices less predictable for savers, and asks the Commission to guard against avoidable price swings; does not ask that the order be withdrawn.

I encourage the Commission to clarify how core investor protections will apply to tokenized securities trading under the Innovation Exemption.

Asks the Commission to clarify how investor protections apply under the order and to apply the same basic standards across trading venues regardless of technology.

Investors need clear, consistent information about the rights attached to a token, the safeguards that apply to its trading, and the responsibilities of the platforms offering it.

Asks for clear information about the rights attached to a token, without naming a change to the same-rights condition.

The Innovation Exemption is a welcome measure for venues that intermediate securities transactions.

Welcomes the order for intermediated venues and asks for separate rulemaking on safe harbors for decentralized exchange protocols and their user interfaces; asks for no change to the order.

DEF therefore recommends that the Commission adopt the Exchange Safe Harbor Proposal through notice-and-comment rulemaking.

the Innovation Exemption does not address decentralized exchange protocols (“DEXs”) or user interfaces or other applications that provide access to DEXs.

I offer no view on whether the relief should have been granted, or on the merits of any condition attached to it.

States no view on whether the relief should have been granted or on the merits of its conditions.

State whether the pairing asset must itself be recorded on the public, permissionless distributed ledger on which the TSV's distributed ledger applications are deployed,

Asks the Commission to state whether a paired asset, such as a tokenized money market fund unit, must itself be recorded on the public, permissionless ledger or whether a representation of an asset recorded elsewhere is enough.

state whether the requirement of a public, permissionless distributed ledger is intended to operate as an eligibility criterion for the kind of infrastructure that may use the regime,

Asks the Commission to state, before any exemption is made permanent, whether the public, permissionless ledger condition is meant as an eligibility line or only as a transparency measure, to state the ledger requirement for any added class of security, and to align it with any final Regulation Crypto Assets rule.

I urge the Commission to deny this exemption and protect the integrity of our capital markets from unproven, high-risk cryptographic experiments.

Asks the Commission to deny the exemption, citing surveillance across distributed ledgers, reliance on price oracles, and thin liquidity in trading outside market hours.

SIFMA and its members believe certain operational questions warrant immediate attention.

Accepts that the order is in effect and asks for changes and answers in four areas, among them issuer consent, investor protection and volume limits; would support a delay before venues begin operating.

Will the Commission limit stablecoin pairs to payment stablecoins issued by permitted payment stablecoin issuers under the GENIUS Act, and how should a TSV respond if a paired stablecoin loses its peg or its regulatory status?

Asks whether stablecoin pairs will be limited to payment stablecoins from permitted issuers under the GENIUS Act and how a venue should respond if a paired stablecoin loses its peg or its status.

Will the Commission require any minimum customer verification standards that align to the risks posed?

Asks whether customer verification and anti-money laundering procedures, which a venue discloses only if it has them, are optional, and whether the Commission will require minimum verification standards.

Can the SEC further define what characteristics would make a blockchain network public and permissionless?

Asks the Commission to define what makes a network public and permissionless and whether smart contract source code must be universally accessible.

SIFMA believes that a third-party tokenized version of an issuer’s NMS stock should trade on a TSV only with the issuer’s affirmative consent (an opt-in).

Asks the Commission to replace the objection model with issuer opt-in consent; short of that, to set up an official portal for notices and issuer elections, a 90-day objection period from confirmed receipt, a universal opt-out, and objection at any time.

Will the SEC set a baseline and ongoing verification standards, including to confirm that third-party tokens remain backed one-for-one by the underlying security?

Asks how beneficial owners will be identified for corporate actions, whether the Commission will set verification standards for one-for-one backing, and whether tokens traded on a venue should be redeemable for the underlying share.

The portal recommended in Section A should also publish TSV trading volume by symbol, both for each venue and in aggregate across all TSVs.

Asks that trading volume by symbol be published for each venue and in aggregate across all venues, so that cumulative trading across unaffiliated venues can be monitored against the per-venue limits.

TSVs publish trade data on their own websites within 10 minutes of execution, and that data does not reach the consolidated tape. Why is this approach appropriate?

Asks why trade data is published on venue websites within 10 minutes and outside the consolidated tape, and how the Commission will keep an audit trail comparable to the Consolidated Audit Trail.

Will TSVs be required to implement Limit Up-Limit Down (“LULD”) or comparable price-band mechanisms?

Asks how venues will apply halts tied to the listing exchange without a connection to its data feeds, and whether price bands, change-management standards for smart contract upgrades and a liability framework will apply.

How frequently, and with what scope and staffing, does the Commission expect to conduct such examinations, and will access to books and records adequately substitute for the examination regime that applies to registered exchanges and broker-dealers?

Asks how often and with what scope staff will examine venue books and records, and whether that access can stand in for the examination regime that applies to registered exchanges and broker-dealers.

The five-year term is unusually long for exemptive relief, being inconsistent with the approach taken to other large pilot programs, including the DTCC tokenization services pilot, and could result in a de facto permanent framework that would be hard to undo.

Describes the five-year term as long against other pilot programs, asks for its rationale, and asks whether the Commission will seek comment before making any part permanent.

May a registered broker-dealer provide liquidity to AMM pools, or route customer orders to an affiliated TSV, and on what terms relative to Covered Firms?

Asks whether and on what terms a registered broker-dealer may supply liquidity to pools or route customer orders to an affiliated venue, and how it would meet custody and best-execution obligations.

A request for comment on possible modifications is not a substitute for notice-and-comment rulemaking.

Does the LP token constitute an interest in an investment company under the Investment Company Act of 1940?

I encourage the Commission to provide that clarity as tokenized securities enter the market.

Asks the Commission to make the issuer notice process and token rights clear to investors; does not ask that the order be withdrawn.

The Commission can make this process more workable by requiring plain-language disclosures at the point of sale and a reliable way to check an offering's status.

Asks for required disclosure of whether the company received notice and objected, a way for investors to check an offering's status, and a consistent process for sending and recording notices.

Those disclosures should identify the token's issuer and relationship to the underlying shares, explain the rights and limitations,

Asks that required disclosures name the token's issuer, its relationship to the underlying shares, and the rights and limits attached to it.

As the framework takes effect, I ask that the Commission consider how tokenized trading could disrupt orderly market activity and impact investors.

Asks the Commission to consider how tokenized trading could affect orderly markets and long-term savers; does not ask that the order be withdrawn.

This framework was implemented very quickly and without input from investors.

I ask the Commission to address the practical consequences of fragmented liquidity and out-of-sync trading before those problems land on investors to sort out.

Asks the Commission to address thin liquidity and trading out of step with the underlying market; does not ask that the order be withdrawn.

What should a platform do when liquidity dries up? When should trading pause?

Asks when trading should pause, how pauses will be coordinated across venues and how investors will be told that a token's price may not track the share, without naming a change to the stoppage condition.

I encourage the SEC to explain how it will evaluate the exemption in practice and give the public a clear chance to comment on what it learns.

Asks the Commission to explain how it will evaluate the exemption and to seek public comment on what it learns; does not ask that the order be withdrawn.

But the Innovation Exemption took effect immediately and will shape this area of the market for years.

Please clarify how issuer notices and objections should work before uncertainty becomes a routine part of the market.

Asks the Commission to settle how issuer notices and objections work; does not ask that the order be withdrawn.

I encourage the Commission to set a clear, workable standard for delivery, required notice contents, the start of the 30-day period, and the submission and acknowledgment of objections.

Asks the Commission to set a standard for delivery of the issuer notice, its required contents, when the 30-day period starts, and how objections are submitted and acknowledged.

Tokenization Systems supports the Commission’s decision to let this market develop under conditions, and offers these recommendations so that the evidence the Order generates will support the rulemaking the Commission anticipates.

Supports the order and its public ledger condition and asks for seven changes so that the order collects facts the Commission can check against the ledger.

in the meantime the Notice identify, for each paired payment stablecoin, whether its issuer is a permitted payment stablecoin issuer.

Asks that the notice state, for each paired payment stablecoin, whether its issuer is a permitted issuer under the GENIUS Act; recommends no limit on paired asset types.

Tokenization Systems recommends a Notice item that lists, for each Tokenized NMS Stock and each paired asset made available on the TSV, each function by which any person can mint, burn, freeze, block, force the transfer of, pause, restrict the transfer of, or upgrade or replace the code governing the asset;

Asks for a new notice item listing, for every asset in a venue's pools, each function that can mint, freeze, move, pause or replace the asset, who holds it and whether more than one approver or a delay applies; asks the Commission to confirm that auditable code includes control over replacing it.

Tokenization Systems recommends that the Commission state that the Section II.E verification, and the Notice item (i) description of it, must address five things:

Asks that the same-rights verification and its notice description cover the tokenization model, the controlling ownership record and reconciliation, the holder's position if an intermediary fails, corporate actions and conversion; also asks the notice to state when each leg of a trade is final and who bears loss if it is reversed or frozen.

Tokenization Systems recommends that the Commission confirm that control “by contract, or otherwise” includes the ability to exercise the privileged functions described in Recommendation 2,

Asks the Commission to confirm that control for the affiliation test includes holding a pool's privileged functions, so that venues sharing such a key holder aggregate their volume and symbols; the letter states this adds no new category of affiliation.

Tokenization Systems recommends adding to the Section II.G minimum fields (vi) the identifier of the transaction on the distributed ledger and (vii) for any pair whose other asset is not denominated in U.S. dollars, the conversion rate used to state the price in U.S. dollars and the source of that rate.

Asks for two added transaction fields: the ledger transaction identifier and the dollar conversion rate and its source.

An exercise of any such function should be treated as a significant operational event under Section II.I,

Asks that freezing, burning, moving or pausing an asset held in a pool, or any such power held by the venue or a Covered Firm, count as a significant operational event.

Tokenization Systems recommends adding to the Covered Firm notification, and to the records a Covered Firm must keep, any key, role, or governance right held by the Covered Firm or its affiliates that can set or alter the parameters, fees, code, or pause state of an AMM Liquidity Pool to which it supplies liquidity,

Asks that the Covered Firm notification and records include any control the firm holds over a pool's parameters, fees, code or pause state and its monthly share of each pool's liquidity.

It does recommend that the Commission, with Treasury, state before July 18, 2028 how section 3(b)(1) applies to a TSV’s pairing of a payment stablecoin,

I urge the Commission to address these issues as it evaluates the exemption and considers next steps.

Asks the Commission to address thin liquidity, price drift from the underlying share and trading pauses; does not ask that the order be withdrawn.

I encourage the Commission to clarify how trading pauses and other market safeguards will work across tokenized and traditional markets.

Asks the Commission to clarify how trading pauses and other safeguards work across tokenized and traditional markets and how venues will tell investors about differences in liquidity, pricing and hours.

I encourage the Commission to address these open questions carefully so that any path forward strengthens, rather than weakens, the safeguards that make our markets trusted worldwide.

Supports efforts to clarify open questions about the exemption and asks for clear rules on registration, disclosure, oversight and accountability; does not ask that the order be withdrawn.

In response to Questions 1 and 5, I recommend targeted clarifications to the Public Notice requirements.

Accepts the order and asks for added public notice content on upgrade powers, trading halts, rights verification and changes after admission; does not ask that the order be withdrawn.

The Notice could also explain, where material, the consequences for positions and permissions outstanding when those powers are exercised.

Asks that the notice explain what happens to existing holdings and permissions when powers to change or suspend the distributed ledger applications are used.

The Commission could clarify how the existing update provisions address material post-admission changes relevant to that notice, including changes to the tokenizer, custodian or arrangements supporting issuer communications.

Asks how the existing update provisions apply when the tokenizer, custodian or issuer-communication arrangements change after admission; says this is not a continuing veto or a new consent right.

The Commission could clarify how the Notice should describe the date, scope and material dependencies of that verification, and how material subsequent changes should be reflected.

Asks that the notice give the date, scope and dependencies of the rights verification, update it after changes in custody or tokenization arrangements, and separate a documented arrangement from an independent check of how it operates.

Where material and reasonably known, the Notice could explain whether the suspension affects transfers outside the TSV, redemption, or use in other arrangements

Asks that the notice say whether a venue halt also affects transfers outside the venue, redemption or other uses, so a holder can tell a venue halt from a wider restriction.

We support the Order as a bridge to rulemaking and respond to Questions 3, 5 and 10.

Supports the order as a step toward rulemaking and asks for added data, notice content and conditions on trading while the underlying market is closed, surveillance and Covered Firm compensation.

We recommend that monitoring for self-trading and trading between linked wallets be a condition rather than a disclosure, with results kept under Section L.

Asks that monitoring for self-trading and trading between linked wallets become a condition, because venue volume counts toward the symbol caps, and that per-venue daily volume be published in a common format so caps can be compared across venues.

We recommend adding a periodic depth measure, such as size available within set percentages of the pool price

Asks that published data add a periodic measure of pool depth and, for each stock, the gap between the last pool price before the open and the opening price.

(b) that notice items s and cc describe how the TSV prices and protects pools while the underlying is closed, including any oracle, price band or dynamic fee.

Asks that the notice describe how a venue prices and protects its pools while the primary market is closed, including any oracle, price band or dynamic fee.

We recommend that the public disclosure under the Covered Firm conditions state whether any compensation from a TSV or issuer is linked to traded volume

Asks that Covered Firm disclosure state whether any compensation is linked to traded volume and that the liquid-assets record be tested against a price gap when the underlying market reopens.

I urge the SEC to establish a straightforward, verifiable notification and objection process and require clear investor-facing information about its outcome.

Asks for a verifiable issuer notice and objection process and investor information on its outcome; does not ask that the order be withdrawn.

The Commission should spell out how notice must be delivered, what information it must include, and how a company can object within the 30-day period.

Asks the Commission to set how notice is delivered, what it contains and how an issuer objects, and to require that investors can find out whether notice was received and whether the issuer objected.

any extension should be conditioned on a substitute architecture that replaces, rather than borrows, the conditions this Order derives from the national market system.

Accepts the order and answers Question 4 with a functional definition of pairing assets and a staged extension to other securities under substitute conditions.

We suggest the Commission consider extensions in the following order.

Asks for a staged extension to Regulation A Tier 2 securities, Rule 144A securities, private funds and then single-asset private interests, each under substitute conditions such as issuer authorization, a holder-of-record cap and independent valuation with a pause when it goes stale; keeps synthetic exposure excluded.

A permitted pairing leg should be a non-security crypto asset, or a security whose price is administratively struck at or about a fixed value or net asset value and whose role in the pair is to serve as the settlement or numéraire leg.

Asks that permitted pairing assets be defined by function, so that equivalents of a tokenized money market fund qualify, while keeping the requirement that each leg be paired directly with a Tokenized NMS Stock; also asks for guidance on a stablecoin whose legal status changes.

we urge the Commission to, at a minimum, withdraw the Order and propose any potential changes to the manner of trading of NMS stocks (or their equivalents) consistent with the requirements of the APA.

Asks the Commission to rescind the order and proceed by notice-and-comment rulemaking, citing oversight of venues and Covered Firms, trade-through protection, cybersecurity, trading pairs, investor protections, Section 31 fees, the Consolidated Audit Trail and the burden on issuers.

This action is unlawful.

Whether LP tokens qualify as securities raises attendant issues around net capital calculations, possession-or-control requirements, and treatment under the Investment Company Act of 1940.

I urge the Commission to address these practical issues in its guidance on the exemption.

Asks for a verifiable issuer notice record and clear investor communications; does not ask that the order be withdrawn.

A public, searchable record could identify the proposed token and platform, document when and how notice was delivered, show whether an issuer responded, and indicate the status of any objection.

Asks for a public, searchable record of each issuer notice: the token and platform, when and how notice was delivered, whether the issuer responded and the status of any objection.

Investor communications should plainly distinguish an issuer’s own tokenization from a third-party product

Asks that investor communications state whether a token is the issuer's own tokenization or a third-party product.

We commend the Commission for issuing the Innovation Exemption.

Supports the order and asks the Commission to define the public, permissionless ledger condition.

We therefore urge the Commission to define the term “public, permissionless distributed ledger” for purposes of the Innovation Exemption, and to do so using a functional, control-based standard

Asks for a definition based on control, so that a ledger where one party or group can control sequencing, transaction inclusion, validation or rule changes would not qualify; also asks that disclosed, temporary incident-response measures not disqualify a ledger.

I urge the Commission to rescind the Order and address any proposed changes through full notice-and-comment rulemaking under the Administrative Procedure Act.

Asks the Commission to rescind the order and proceed by rulemaking with an economic analysis, or failing that to suspend or narrow reliance on it; lists safeguards for any later rule, among them affirmative issuer consent.

the Order makes significant changes to the market structure for U.S. equities before the public comment process can inform the decision

Please ensure that market safeguards and clear risk information keep pace with the technology

Asks for required risk explanations before tokenized trading expands; does not ask that the order be withdrawn.

the Commission should require clear and understandable explanations of how tokenized prices are formed, what can happen when trading is thin or outside regular market hours, and how pauses or disruptions are handled.

Asks the Commission to require explanations of how token prices are formed, what happens when trading is thin or outside market hours, how pauses are handled and whether a token can trade when the share cannot.

We offer recommendations to improve the Order's effectiveness while preserving the stability of the underlying markets.

Accepts the order and asks for the volume limits to be removed or recalibrated, with ongoing assessment of AMM effects.

We believe the volume limits are too restrictive, undermine the innovation the exemption seeks to enable, and may harm market participants.

Asks that the volume limits be removed or, if kept, calibrated for each stock to a level at which an AMM can offer competitive trading costs, arguing that the caps constrain arbitrage, fee income and liquidity.

My recommendations concern the application of those provisions to material changes in network properties.

Accepts the order and asks how its notice and update provisions apply when the underlying network changes; takes no position on which networks qualify.

Where material, the Public Notice could identify the network and relevant deployment, the date and scope of the assessment, the sources reasonably relied upon, and material uncertainties.

Asks that the notice describe, layer by layer, the network properties a venue relies on (ledger access, transaction submission, validation, contract deployment, governance, exit), with the date, scope, sources and limits of its assessment and how it will learn of changes.

The Commission could explain how those provisions apply when an underlying network changes through governance, an external operator or an emergency process.

Asks how the existing duties to revise the notice apply to network changes the venue does not initiate, and what a venue should do if it concludes a condition is no longer met; says advance notice cannot be assumed feasible for every external event.

The respondent supports the approach the Commission has taken: granting conditional, time-limited relief now and allowing experience under it to inform any subsequent rulemaking is well suited to a market structure whose operating characteristics are not yet settled.

Supports conditional, time-limited relief and proposes drafting changes across the order, naming standardized transaction records as the change it values most.

Retain NMS stock as the scope for this relief period and accumulate the resulting data.

Recommends keeping NMS stock as the scope for this term and opening a separate inquiry into tokenized fixed income; ranks exchange-traded products first only if expansion is considered.

Identify each non-security crypto asset made available for trading in a pair with a Tokenized NMS Stock, the issuer of that asset, and the proportion of the TSV's aggregate paired-asset exposure attributable to each issuer.

Asks that the notice name each paired asset, its issuer and each issuer's share of the venue's paired-asset exposure, with the thresholds at which a pool pauses if a paired asset loses its stated value; asks the Commission to say whether tokenized money market funds can be used now.

Wallet addresses admitted to a TSV are bound to a verifiable credential carrying the participant's legal identity, with grants and revocations recorded in a tamper-evident log.

Asks that each admitted wallet address be tied to a credential carrying the participant's legal identity, with a log of grants and revocations.

A TSV shall apply at least one measure designed to mitigate abusive activity involving Maximal Extractable Value affecting its participants

Asks that a venue be required to apply at least one measure against front-running by validators and others who order transactions on the ledger, where the notice now may say it has none; also asks for disclosure of any cross-chain transfer support and its failure modes.

Provide an exception: remediate first, and notify the Commission and participants simultaneously within 24 hours of remediation

Asks for an exception to the 20-day advance notice of material changes, so that a security patch can be applied first and announced within 24 hours.

A TSV shall verify that a mechanism exists by which a holder of each Tokenized NMS Stock made available for trading may convert that security into the underlying NMS stock

Asks that a working route to convert a token into the underlying share, independent of the venue, become a condition; also asks the notice to give each token's Digital Token Identifier beside the share's identifier and to describe tax withholding on distributions.

Specify objective conditions under which the volume limitations relax, rather than leaving relaxation entirely to discretion.

Asks for stated conditions under which the volume caps step up, a rolling volume base, selling and withdrawal of liquidity during a pause, and a cure period for symbol-count breaches; also asks that tiers reflect depth and that foreign issuers' depositary receipts be treated as their own category.

shorten the interval to as near real time as practicable, and in any event to no more than sixty seconds.

Asks that transaction data be published within 60 seconds in place of ten minutes, possibly tiered by a venue's daily transaction count, because readers of the ledger see trades at once.

a reference price band, anchored to the most recent official closing price of the underlying NMS stock, beyond which trading in that Tokenized NMS Stock is paused

Asks that venues trading while the listing exchange is closed set a price band around the last official close, pause before the opening and label displayed prices as not consolidated market prices.

Clarify that the obligation is not to provide leverage rather than not to permit it, so that TSVs are not held to an obligation they cannot discharge

Asks the Commission to confirm that the no-leverage condition bars the venue from extending credit and does not require it to stop participants who borrow elsewhere.

Records maintained under this condition shall identify each participant to a transaction by a standardised identifier.

Asks that records identify each participant by a standard identifier (the Legal Entity Identifier for firms) and be produced in a registered machine-readable format such as ISO 20022; also asks whether a separate U.S. copy of ledger records is required.

A Covered Firm may establish and maintain positions outside an AMM Liquidity Pool for the sole purpose of hedging exposure arising from liquidity it has supplied to such a pool.

Asks that Covered Firms may hedge outside the pool and that non-U.S. liquidity providers may rely on the exemption with a U.S. agent; also asks for a periodic statement of loss capacity and disclosure of the risks of liquidity positions.

Publish the treatment at expiry now, while leaving the relief temporary.

Asks the Commission to state now what follows expiry, such as a streamlined route to registration or successor relief with a transition period; for Covered Firms, proposes expiry 12 months after a new dealer rule or in 2031, whichever is earlier, with an extension announced if no rule is adopted.

shall not, by reason of that execution alone, be regarded as having failed to satisfy its duty of best execution or its obligations under Rule 611

Asks for a safe harbor under which a broker-dealer executing on a venue meets its best-execution and order-protection duties if the customer consents and the firm records and discloses the national best price; keeps broker-dealers' audit-trail reporting.

The Commission may wish to coordinate with the Department of the Treasury and the Internal Revenue Service

The United States imposes a 30 percent gross-basis tax on U.S.-source income of non-residents, collected by withholding at the point of payment.

I ask the Commission to ensure that tokenized securities are subject to clear, consistent execution standards and that investors can see the pricing information needed to compare trades.

Asks for consistent execution standards across venues, pricing information to compare trades and plain-language disclosure; does not ask that the order be withdrawn.

Disclosures should explain, in plain language, what the token represents and how its protections differ, if at all, from those of a traditional stock.

Asks for required plain-language disclosure of what a token represents and how its protections compare with an ordinary share.

My request is that the Commission clarify how these equal protections will be carried out, require plain-language disclosure of what a buyer is actually getting, and let the public see the protections are upheld.

Asks how the same-rights condition will work in practice for ordinary buyers; does not ask that the order be withdrawn.

require plain-language disclosure of what a buyer is actually getting

Asks who ensures that a token's vote or dividend reaches the holder and for required plain-language disclosure of what a buyer receives.

That is my worry about the notification and opt-out steps in the Innovation Exemption for tokenized stocks.

Accepts the order and asks that the issuer notice and opt-out steps be written down; does not ask that the order be withdrawn.

I urge the Commission to spell out the notification and opt-out process in plain terms, and to make clear how investors can tell if a company objected.

Says the order does not set how notice is delivered, who receives it or how an issuer objects, and asks the Commission to set that process and let investors see whether an issuer objected.

I support new ways to invest, and I want them to earn the public

Supports the order's aim and asks how anti-money laundering and sanctions rules apply to every venue; does not ask that the order be withdrawn.

I urge the Commission to confirm which anti-money laundering and sanctions requirements apply to every platform under the exemption

Asks the Commission to confirm which anti-money laundering and sanctions requirements apply to every venue, who checks compliance and how it is enforced, without naming a change to the U.S.-person condition.

I support using the temporary exemption to learn from a limited, supervised setting.

Supports the temporary exemption as a supervised trial and asks that information for investors during trading interruptions build on the existing notice; asks the Commission to review interruptions by cause and duration before relying on the period to support a permanent exemption.

Where a transfer, conversion or alternative trading route actually exists, the Notice should explain its eligibility conditions, fees, dependencies and ordinary processing steps.

Asks that the notice show who supplies issuer communications, handles voting instructions and resolves entitlement errors, and describe any transfer or conversion route out of the token, or state that none exists.

A common format could connect such notifications with other stoppages described under section III.cc

Keeps the order's notification of volume-limit pauses and asks for a common format across stoppage types that says separately whether trading, settlement and shareholder-rights services are available.

The Commission could ask a Tokenized Securities Venue to make a concise operational status statement available through its usual participant interface when a material interruption occurs.

Asks for a status statement at each material interruption, linked to the notice, naming the stock, start time, known scope and time of the next update, and for a worked interruption example in the notice.

The Commission should also explain how it will monitor price deviations, execution quality, and liquidity fragmentation as trading develops under the exemption.

Accepts the exemption as limited and conditional and asks how the Commission will monitor price deviations, execution quality and fragmentation between tokenized and conventional venues.

including the treatment of tokenized trading interests in consolidated pricing

Asks how trading on the venues will be treated in consolidated pricing for the national market system, without naming a change to the order's publication condition.

the application of best-execution obligations to intermediaries handling tokenized securities

Asks how best-execution obligations apply to brokers that handle tokenized securities across tokenized and conventional venues.

I respectfully encourage the Commission to weigh whether this relief leaves gaps in investor protection

Asks the Commission to weigh whether the relief leaves gaps in investor protection, to require plain disclosure and to apply the same standards as for traditional securities; does not ask for the same registration or that the order be withdrawn.

to require clear disclosure written for ordinary people

Asks that the risks the order already lists, such as smart contract flaws and lost keys, be disclosed in language written for ordinary investors.

I ask the Commission to ensure that tokenized stocks are subject to the same registration, disclosure, and market integrity standards as traditional securities.

Says tokenized stocks should be subject to the same registration and related standards as traditional securities and questions whether the relief keeps those safeguards; asks for no change that would keep the order.

I encourage the Commission to hold tokenized stocks to the same registration, disclosure, and market integrity standards as traditional securities

Asks for the same registration and related standards as for traditional securities and, alongside that, for a shorter duration or added conditions, an ask that would keep the order in place in a narrower form.

to consider a shorter duration or added conditions so that this relief does not become a lasting gap

Asks the Commission to consider a term shorter than five years so that the relief does not become lasting.

I urge the Commission to confirm that the conditions in this exemption deliver disclosure and accountability that match what traditional securities provide, and to be ready to tighten them if they fall short.

Accepts the exemption's conditions and asks the Commission to confirm they give disclosure and accountability matching traditional securities, and to tighten them if they do not; names no specific condition.

Please make sure tokenized stocks are held to the same registration, disclosure, and market integrity standards as traditional securities.

Says tokenized stocks should be held to the same registration and related standards as traditional securities and asks for accountability and recovery if something goes wrong; asks for no change that would keep the order.

I respectfully ask the Commission to evaluate whether this relief keeps the protections that apply to traditional securities

Asks the Commission to evaluate whether the relief keeps the protections of traditional securities, to require plain explanations of risk and to keep the duration and conditions under review; does not ask for the same registration or that the order be withdrawn.

to require plain explanations of risk

Asks that venues explain the risks of trading in plain terms.

I respectfully ask the Commission to make sure tokenized stocks carry the same registration, disclosure, and market integrity protections as traditional securities, and to treat this relief as truly temporary.

Says tokenized stocks should carry the same registration and related protections as traditional securities and that the relief should stay temporary; asks for no change that would keep the order.

I ask the Commission to consider three things as it reviews public comment.

Accepts the relief and asks for plain-language risk disclosure, a clear route to recourse if a venue or liquidity provider fails, and readiness to shorten or end the relief if early results show harm.

require plain language risk disclosure that an ordinary investor can understand before trading

Asks that risk disclosure be written in plain language and be available to an investor before trading.

be prepared to shorten or end the relief if early results show harm

Asks the Commission to be ready to shorten or end the five-year term if early results show harm to investors.

We commend the Commission for the Innovation Exemption’s careful, control-based approach to permissioned on-chain trading

Supports the order's control-based approach and asks for a confirmation on third-party wallets and for a later permanent framework; also asks that self-custody remain a permitted way to hold any asset class later made eligible.

A non-custodial wallet that directs a user to a TSV’s own hosted trading interface should not, by virtue of that referral alone, risk being characterized as functionality the TSV

Asks the Commission to confirm that a wallet or aggregator that links to or embeds a venue's order-entry interface, without setting the terms of a trade or of access, is a third party and not functionality the venue provides; if granted, such software would sit outside the venue.

and the Proprietary Accounts condition in Section IV.A (91 FR at 60182) are preserved

Asks that the Covered Firm condition limiting the exemption to a firm's own accounts be kept in any permanent framework.

Ledger supports the Commission’s eventual transition of both the TSV Exemption and the Covered Firm Exemption to a permanent framework

Supports moving both exemptions to a permanent framework after the five-year evaluation period, with the venue definition and the own-accounts condition kept.

Ledger reiterates its request in File No. 4-894 for notice-and-comment rulemaking on non-custodial interfaces

The two interim instruments should be aligned.