The SEC's proposed transfer agent rules, explained
On September 1, 2026 the SEC proposed the first broad update of its transfer agent rules in decades, including how transfer agents may keep records on a blockchain. The rules are proposed, not final, and may change.
Key dates
SEC proposes the rules (Release No. 34-106246). SEC,
Published in the Federal Register, which starts the 60-day comment period. Federal Register,
Public comments due (File No. S7-2026-30). SEC,
What the SEC proposed
The proposal would modernize the rules for registered transfer agents to reflect electronic and blockchain-based recordkeeping and uncertificated securities, and would amend the registration and annual reporting forms, Forms TA-1 and TA-2. (SEC, )
It would add two new rules. Proposed Rule 17ad-30 would require written policies and procedures reasonably designed to achieve compliance with the securities laws that apply to transfer agents. Proposed Rule 17ad-31 would set requirements for placing and removing restrictive legends, and would require a transfer agent to refrain from facilitating an unregistered transaction unless it has a reasonable basis to believe the transaction does not violate Section 5(a) of the Securities Act. (SEC, )
It would reframe Rule 17ad-12 as a broad risk management rule, including a business continuity plan, set a single retention period for most records, align turnaround and posting times with the current settlement cycle, and rescind the Rule 17ad-4 exemptions. (SEC, )
What it means for tokenized securities
The proposal would let a transfer agent use a blockchain or other distributed ledger as its master securityholder file, or as part of it, without requiring it, provided the proposed standards for electronic recordkeeping systems are met. (SEC, ; Federal Register, )
A securityholder's registration details would include a digital wallet address in the case of a tokenized security. (SEC, )
Form TA-2 would report the number of tokenized issues serviced, by tokenization model (issuer-sponsored or third-party sponsored) and by security type. (SEC, )
How Keystone Registry relates
Keystone Registry's tokenized securities rule pack is built to the SEC's proposed transfer agent framework, with report formats kept as configuration so they can follow the final rule.
See the tokenized securities rule pack
Official sources
Sources checked . If a source and this page disagree, the source governs.
See it on your token
We walk through testnet tokens end to end with synthetic data: a holder record, a blocked transfer, a prepared freeze, a reserve coverage check, and chain verification.