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ARTICLE · 06 NOVEMBER 2026

The SEC’s Innovation Exemption

The SEC has issued a groundbreaking order creating a five-year framework for secondary trading of tokenized U.S. public company stocks through permissioned automated market makers and liquidity pools. Under this conditional pathway, unaffiliated persons can tokenize any national market system stock and make it available for trading on qualifying venues, unless the issuer objects within 30 days of receiving notice.

United StatesFinance and Banking

A Conditional Path for On-Chain Trading of Tokenized U.S. Stocks

Key Takeaways

PUBLIC COMPANIES REGULATORY PERIMETER MARKET STRUCTURE
A TSV notice sent to the principal executive office of a publicly-listed company starts a 30-day objection period for stock tokenization by an unaffiliated person.
The SEC order addresses exchange status and limited dealer activity, not Securities Act, antifraud, broker, custody, transfer agent, clearing or Investment Company Act requirements binding on the issuer.
TSVs are a conditional secondary trading pathway. The SEC order does not change the primary exchange listing standards applicable to the issuer’s stock.

The SEC Order

If you work in a public company environment but have been ignoring blockchain technology, you should probably read this report. The SEC has issued an order and request for comments via Release No. 34-106402, available at https://www.sec.gov/rules-regulations/2026/09/4-927 (the Order), creating a

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