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ARTICLE · 24 DECEMBER 2025

SEC Staff Issues No-Action Relief For DTC Tokenization Pilot

Hogan Lovells Cadwalader
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On December 11, 2025, the staff of the SEC's Division of Trading and Markets issued a no-action letter (the "DTCC No-Action Letter") stating that it would not recommend...

United StatesFinance and Banking
Peter Y. Malyshev
Peter Y. Malyshev
Christina Mille
Christina Mille
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On December 11, 2025, the staff of the SEC's Division of Trading and Markets issued a no-action letter (the "DTCC No-Action Letter") stating that it would not recommend enforcement action against The Depository Trust Company ("DTC") in connection with the launch of a pilot version of its DTCC Tokenization Services. The relief permits DTC to operate a preliminary tokenization program that records participants' security entitlements using distributed ledger technology, rather than exclusively through DTC's centralized ledger, subject to limitations.

Under the pilot, eligible DTC participants may elect to tokenize security entitlements—real world assets ("RWAs")—in certain highly liquid securities, including U.S. Treasury securities, Russell 1000 equities, and selected index-tracking ETFs. Tokenized entitlements would be represented by tokens held in participant-registered wallets on approved blockchains, while the underlying securities would remain registered in the

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