SEC proposes first major transfer agent overhaul since 1980s, writing blockchain into ownership records

Sep 1, 2026

On September 1, 2026, the SEC proposed its first major overhaul of transfer agent rules since the late 1970s and early 1980s, explicitly allowing blockchains to serve as official records of share ownership. The 421-page proposal introduces cybersecurity, business continuity, and tokenization reporting requirements, with a 60-day comment period. Separately, the SEC scheduled a September 17, 2026 roundtable with major financial institutions to explore continuous 24-hour U.S. securities trading.

SEC transfer agent rule proposal

▪The proposed transfer agent rule would require firms to maintain a separate bank account for issuer and securityholder funds and align turnaround standards with the current settlement cycle
▪The U.S. Securities and Exchange Commission proposed a rule on September 1, 2026, to overhaul regulations for transfer agents, opening a 60-day public comment period
▪The SEC's proposed rule would require transfer agents to implement written risk-management policies covering cybersecurity, business continuity, and the safeguarding of securities and investor records

Blockchain recordkeeping for securities

▪Firms operating in the digital asset space, including Injective, Securitize, tZERO, and Plume, have registered as transfer agents with the SEC
▪The SEC's proposed rule would explicitly allow the use of blockchain technology and distributed ledgers as official records of securities transactions and share ownership
▪SEC Commissioner Hester Peirce questioned whether the proposed rule should allow transfer agents to collect digital wallet addresses and emails instead of physical names and addresses

Tokenized securities reporting requirements

▪The SEC's proposed rule would require transfer agents to categorize tokenized issues into issuer-sponsored and third-party-sponsored categories
▪Proposed additions to Form TA-2 would require transfer agents to report the number of issues with master securityholder files on a distributed ledger

24-hour securities trading roundtable

▪The SEC's September 17, 2026 roundtable will feature participants from NYSE, Nasdaq, DTCC, Citadel Securities, State Street, BlackRock, Robinhood, Blue Ocean, 24X, and FINRA
▪The SEC announced a roundtable on September 17, 2026, to discuss overnight surveillance, closing-price practices, and clearing and settling for continuous 24-hour securities trading

First overhaul since 1980s

▪SEC Commissioner Mark T. Uyeda criticized the Commission's previous regulation-by-enforcement approach for failing to provide clarity or predictability after a 2015 concept release
▪The SEC's proposed transfer agent rule represents the first major, substantive overhaul of these regulations since the late 1970s and early 1980s