A transfer agent rule pack for tokenized securities
Built to the SEC's proposed transfer agent framework: the master securityholder file with wallet addresses, restrictive legends, examiner exports, and tokenized-issue report drafts, on every supported chain.
The SEC proposed these rules on SEC, . Comments are due November 3, 2026 (SEC, ). The rules are proposed, not final, and may change. Read our plain-English explainer, last reviewed .
Mapped to the proposed rules
Each feature next to the proposed requirement it is designed to support, with honest build status as of . Report fields are configuration, so they can follow the final rule.
- Holder file with wallet addressesBuilt
- Every row carries the holder, the chain, the wallet address, and the quantity, read at a finalized height.
- Proposed requirement: Position-detail records capture digital wallet addresses (proposed)
- Examiner exportsBuilt
- A readable CSV whose header names the chain height and block hash it was read at.
- Proposed requirement: Records produced promptly in human-readable electronic form (proposed)
- Examiner accessPlanned
- Read-only, time-limited examiner accounts, with every view written to the audit trail.
- Proposed requirement: Viewing blockchain records can count as access if copies can be furnished promptly (proposed)
- Legends and restrictionsBuilt
- Legend rules with evidence, the restriction engine, and the chain's own enforcement transaction prepared for signing.
- Proposed requirement: Proposed Rule 17ad-31: restrictive legends and preventing unregistered transfers
- One recordkeeping agent per issuePlanned
- One recordkeeping tenant per asset; co-agents get read-only links.
- Proposed requirement: Proposed Rule 17ad-9(h): a single recordkeeping transfer agent
- Policies vaultPlanned
- Versioned written procedures with staff attestations, with the audit trail as evidence.
- Proposed requirement: Proposed Rule 17ad-30: written policies and procedures
- Tokenized issue report draftBuilt
- Holders of record, wallets, quantity, unmapped wallets, and reconciliation, split by sponsorship category. Marked draft; you file.
- Proposed requirement: Expanded Form TA-2 reporting on tokenized issues (proposed)
- Security programIn development
- Encryption, access control, incident response, and a Regulation S-P breach procedure.
- Proposed requirement: Proposed Rule 17ad-12 overhaul (cybersecurity) and Regulation S-P
Restrictions the engine checks
Every proposed transfer is checked against each rule that applies, after built-in checks for balance and linked wallets. The engine returns every violation, not just the first.
- Legend
- Blocks a transfer when the sender carries an active restrictive legend that has not been removed for them.
- Lockup
- Blocks a transfer when the transfer falls before the lockup ends.
- Identity
- Blocks a transfer when the sender's or recipient's identity verification is not complete.
- Accreditation
- Blocks a transfer when the recipient is not recorded as accredited.
- Jurisdiction
- Blocks a transfer when the recipient's country is on the blocked list.
- Holder limit
- Blocks a transfer when the transfer would push holders of record over the limit.
- Freeze
- Blocks a transfer when either wallet is frozen under a legal order, sanctions, or issuer policy, with evidence.
Who is responsible for what
The registered transfer agent keeps its registration and its compliance obligations. Keystone Registry is software that supports them.
You decide and sign
- Which restrictions apply to each issue, and when legends come off
- Every enforcement transaction, signed in your own custody
- Every report you file, after reviewing the draft
The software keeps the record
- The holder file at any finalized height, reconciled to the chain
- Every decision and change in an append-only, hash-chained audit trail
- Exports an examiner can read and verify
Open questions that depend on the final rule include the final Form TA-2 fields, and whether stored snapshots alone satisfy point-in-time record production on chains without historical reads.
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.