Transfer Agents Are Having Their Moment

Transfer agents have spent decades operating in the background of capital markets, the quiet plumbing beneath the gleaming facade of Wall Street. That era is ending. This week, the SEC's proposed rulemaking for transfer agents is forcing a conversation that cuts to the heart of what ownership means in a tokenized world, and the firms that have been building for this moment are finally getting their due.

Market KPIs (brought to you by RWA.xyz)

📈 RWA market cap was flat WoW, with limited movement across the board
🏆 Biggest RWA winner: Benji added $100M
🏆 Biggest network winner: BB Chain added $100M

📈 Stablecoin market cap was down ~3.4% WoW to $280.0 billion (second consecutive week of ~$10B outflows)
🏆 Biggest stablecoin winner: Ethena added $300M
🏆 Biggest network winner: ARC, newly on the leaderboard, added $170M

📈 Onchain risk free rates:
Short term treasuries (1m): 3.90% (SOFR crept back down)
Aave / DeFi: 4.24% (stepped down significantly from last week's spike, now slightly above SOFR)

Guest Spotlight: Billy Miller, COO at Securitize

Billy Miller has been in the transfer agent trenches longer than most people in crypto have known what a TA is. As COO at Securitize, he has helped build one of the few platforms that understood from day one that marrying the ledger to the register was the whole game. Securitize has quietly inked partnerships with major incumbent TAs including Computershare, built a fully registered transfer agent operation, and now finds itself at the center of the SEC's most consequential market infrastructure rulemaking in decades.

What stood out to me in our conversation was how Billy framed the opportunity. This is not just a compliance exercise. It is a genuine business moment for transfer agents to reclaim direct relationships with issuers and shareholders that have been slowly eroded since DTC centralized everything in the 1970s. As he put it, the annual meeting used to be a party at the country club. Shareholders knew the issuer. The issuer knew the shareholders. That transparency got traded away for efficiency, and now blockchain gives us a path to have both.

Billy also made a point I want to underscore: regulation is easy to get into and very hard to stay in. Building institutional trust as a TA requires SOC audits, track records, and teams that can service the needs of megacap issuers. The crypto attitude of building fast and dealing with non-securities has to get jammed into a regulated mentality if this technology is going to scale to some of the biggest issuers in the world. The firms that figured that out early, like Securitize, are now in a genuinely powerful position.

The SEC's Proposed Transfer Agent Rulemaking

The SEC recently released a proposed rulemaking on transfer agent modernization, running to over 400 pages and covering rules that have not been substantially updated since the mid-to-late 1970s. There was a concept release floated in 2015, and then largely silence across multiple administrations. So seeing this come out as a full proposed rulemaking rather than piecemeal exemptive relief or no-action letters is genuinely significant. It gives the whole framework staying power across administrations in a way that one-off guidance never could.

What also matters here is the approach the SEC's Division of Trading and Markets and Office of Clearance and Settlement have taken. The staff has been exceedingly thoughtful. They have talked not just to the incumbent TAs but to crypto-native firms, international companies experimenting in the space, and everyone in between. The result is an attempt at technology-neutral rules that can accommodate the speed of change in AI and blockchain without being rendered obsolete in three to five years. That is a genuinely difficult task and I think they deserve credit for taking it seriously.

The 60-day comment window was tight for a document of this size and consequence, and Billy noted that comments will likely continue rolling in beyond the official window. The SEC will have to engage with all of them. This is the beginning of a process, not the end of one.

The Comment Letter: What the Industry Is Asking For

Securitize, together with Centrifuge, Equiniti, Plume, and others, submitted a comment letter responding to the rulemaking. The letter grew out of informal industry conversations rather than a formally convened coalition, and it focused on some of the most practically painful friction points in current TA rules.

The biggest ask, and the one I find most interesting, is around names and addresses. Current rules generally require that the master security holder file contain a shareholder's full legal name and physical address. Many states still mandate this. But Billy made a point that resonated with me personally: his email address has not changed since he graduated high school, but he has moved eight times in twelve years. Physical address as the authoritative identifier for a securities holder is already broken. It just causes mail bounceback, uncashed dividends, and shareholders who have not updated their records in fifteen years.

The letter argues for a more principles-based approach. The TA's core job is to know who owns what and to be able to perform regulated functions on behalf of the issuer. If a wallet address, an email address, or a blockchain identifier tied to off-chain KYC records can accomplish that more reliably than a physical mailing address, regulators should allow TAs the optionality to use those tools. The KYC data still exists. The investor protection is still there. We are just asking whether the master security holder file needs to be the place where that specific piece of information lives.

This matters enormously for DeFi interoperability. If you want a tokenized share class to interact with lending protocols, AMMs, or other permissionless infrastructure, you need rules that can accommodate wallets as the primary means of holding and transacting in those securities. Billy drew a useful analogy to paper stock certificates: historically you could medallion-sign a certificate over to someone and the TA had no idea until the new holder came to tender it. The ledger was technically out of sync the whole time. What we are building toward is a world where that sync happens automatically and onchain, while the KYC and compliance layer handles the in and out gates. That is not less investor protection. That is more of it, applied more intelligently.

Single Stock Perps: The SEC and CFTC Find Common Ground

A few weeks ago, a group including CBOE, Citadel, and the Healthy Markets Association filed a lawsuit trying to block the trading of single stock perpetual swaps in the US, arguing these products are security-based swaps that should fall under SEC jurisdiction rather than CFTC. This week, the SEC effectively shut that argument down, telling the court that it agrees with the CFTC's jurisdictional claim and will not oppose it.

The judge had already denied the request to halt trading when these products first launched. And now with firms like Calci and Coinbase having already built out offerings, the lawsuit looks increasingly like a rearguard action. The more important signal here is that our two core market regulators are not fighting over territory. When FIT21 stalled out, there was real concern that we would see inter-agency turf wars that would create paralysis. What we are seeing instead is regulators dividing responsibilities in ways that feel mostly sensible. I will take it.

The OKX Innovation Exemption: More Opt-Outs, New Venues

The OKX innovation exemption continues its churn. Palantir and Supermicro have now opted out, joining what has become a long list of departures. Palantir's exit stings a little because they seemed like one of the more committed participants. Better.com, the mortgage fintech, has been added, which is interesting given that Figure would have been a natural fit here but appears to be absent, possibly because they want to consolidate everything onto their FGRS token.

The more exciting addition is Direxion, the leveraged ETF shop, which has added 59 ETFs to the exemption. I spent some time thinking through how AMMs would handle leveraged ETF pairs and I actually think there is a genuinely interesting application here. If you pair a broad-market ETF against a single stock, you are using the ETF as a kind of volatility buffer. If the stock rips, you generate fees as the market maker. If the stock craters, you end up long market beta, which is a much more manageable position than holding the single stock outright. Worth watching how this plays out.

Formation Securities also joined as a new venue, running on Solana with Orca's AMM technology. For context, Orca recently merged with LoopScale, a looping-focused lending market, so the combined entity is bringing real DEX infrastructure to bear on regulated securities trading. Formation will be offering access to the issuer-sponsored tokenized securities already on the exemption: Galaxy, Exodus, and others tokenized by Superstate and Securitize. I am chatting with the Formation team and hope to get them on the show soon. It is good to see Solana leaning in here, both through the Solana Policy Institute on the regulatory side and through Formation on the tech side.

NYSE Chooses Avalanche for Its Tokenized Stock ATS

NYSE, which is owned by ICE, has selected an Avalanche subnet as the core ledger powering its tokenized stock alternative trading system. This one means a lot to me personally because the Avalanche team has been building with institutional needs in mind from day one: how do the regulations interact with the onchain ledger, how do you get wires in while settling onchain, what do the SOC requirements look like. These are not glamorous questions but they are the right ones, and the NYSE partnership is the payoff for years of that work.

Charlie raised a good question about the ICE family of products here. ICE also has OKX operating under the innovation exemption, which uses a different technical stack. So you have the parent company running one experiment through one venue and NYSE running a parallel experiment on Avalanche. That could be deliberate portfolio strategy, it could be organizational silos, it probably is some of both. Either way, more experimentation is better than less, and I would not be surprised if these two tracks eventually inform each other.

Project Faro: The Bank Stablecoin Gets a Name and a Budget

The consortium stablecoin project involving Goldman Sachs, Citi, Santander, Deutsche Bank, Wells Fargo, Fidelity, and around 21 other institutions now has a name: Project Faro. I give the name a five out of ten. It is four letters, which is good for branding, but the ticker derivation is not obvious. Faro is a lighthouse in Spanish and also a historical gambling game, which is probably not the brand story they are going for.

More importantly, it has a real budget. Bloomberg is reporting that the consortium has committed approximately $270 million to cover five years of operating costs. I initially assumed this was seed liquidity for the circulating supply, which would have been unimpressive at that size. But if this is the operating budget, it is actually a lot of money for a stablecoin project. Then again, when you have twenty-one institutions that do not get out of bed for less than ten million dollars, reaching a number like that across the group is not that hard.

Bootstrapping liquidity in any new currency is the hardest part of the launch, and having a massive treasury behind you is how you solve that problem. PayPal USD demonstrated the playbook. Network support details have not been announced yet. We will keep watching.

Watch or listen to the full episode on Spotify.