Securitize, Figure, Centrifuge, Equiniti and Plume Ask the SEC Not to Require Mailing Addresses for Token Holders

Five companies that work with tokenized securities filed a joint comment letter on November 3 on the SEC's proposed transfer agent rules. They are Figure Technology Solutions, Securitize, Equiniti Trust Company, Plume (through its transfer agency) and Centrifuge. The letter doesn't ask the SEC to recognize blockchain recordkeeping, because the proposal already does. Its central objection is narrower: the firms don't want the rules to require transfer agents to collect every securityholder's name and physical mailing address.

The Proposal

The SEC proposed the amendments on September 1, 2026, published in the Federal Register on September 4 (91 FR 56946, Release No. 34-106246, File No. S7-2026-30). It updates rules first adopted in the late 1970s and early 1980s and, as the letter notes, addresses for the first time the traits of uncertificated securities issued and transferred on blockchain-based systems. The comment deadline was November 3, though the SEC's index lists filings dated through November 5. The proposed baseline requires names and physical mailing addresses, with email and digital wallet addresses allowed as additions.

What the Letter Asks For

1. A principles-based approach. Let transfer agents identify and communicate with holders by any reliable means, including wallet addresses, email addresses and phone numbers, without mandating names and mailing addresses.
2. Recognition of wallet addresses. The firms argue a wallet address is unique, can't be duplicated or forged, and enables on-chain messaging with cryptographic proof of receipt.
3. A multi-channel approach for lost holders. Replace the proposed database searches for mailing addresses with at least two contact attempts using all reasonably available information.
4. Federal law only. Transfer agent requirements should come from federal securities law. Parties that need names and addresses can get them through private contract. The letter notes that Delaware and Texas generally require names and mailing addresses while Wyoming lets a wallet address serve as the identifier.
5. No anti-money laundering rationale. The firms argue AML and Bank Secrecy Act aims are outside the statute behind transfer agent rules and belong to FinCEN. They add that broker-dealers already carry customer identification duties at onboarding.

Why Token Holding Is Different

The letter's core argument is structural. For most uncertificated securities, the transfer agent records one holder, Cede & Co., the nominee for DTC, and beneficial owners are identified through the intermediary chain. Holders of tokenized uncertificated securities hold directly through wallets, without DTC, brokers or custodians. For them, the firms say, collecting names and physical addresses imposes a novel burden on agents with no prior relationship to the holder, and may deter participation.

Reading It Fairly

This is advocacy by companies that build and run tokenized securities infrastructure, and the regulatory change would benefit their model. The letter anticipates the counterargument that names and addresses support AML and law-enforcement aims, and answers it. We have not reviewed the other letters. The SEC's index shows filings from Nasdaq, Computershare, Continental Stock Transfer & Trust, Fairmint, SIFMA, Broadridge, Coinbase, Circle, the Stellar Development Foundation, Better Markets and the Blockchain Association, among many others. Securitize also said in its second-quarter report that it partnered with Computershare and Continental on issuer-sponsored tokenized shares, so some of the agents most affected are also commenters.

PANews, citing CoinDesk, also reports that the NYSE brought Broadridge in for on-chain shareholder voting and digital transfer agency services on its planned tokenized platform, alongside Securitize and tZERO, which shows how closely these recordkeeping rules touch live projects.

A sourcing note: The Cryptocurrency Post's article links to a different SEC PDF than the one the SEC's own index lists for this letter. We read the letter the SEC lists.

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