The SEC’s Transfer Agent Modernization Proposal: Implications For Onchain Recordkeeping

On September 1, 2026, the Securities and Exchange Commission (the SEC or Commission) proposed a comprehensive overhaul of the regulatory framework governing registered transfer agents (the Proposal).¹ Transfer agents play a critical role in the US securities markets by maintaining securityholder records, processing transfers of securities ownership, facilitating the issuance of securities and performing other functions necessary to the national clearance and settlement system. As the markets have evolved, so too has the role of transfer agents, with many providing a broader suite of technology services. The Proposal represents the most significant updates to the transfer agent rules in decades and is intended to modernize the regime to reflect technological advancements that have transformed securities ownership and transfer processing, including the widespread use of electronic recordkeeping systems, distributed ledger technology (DLT), tokenization initiatives and cloud-based