By Dan Kramer, CEO of Equiniti

The Depository Trust and Clearing Corporation (DTCC) recently completed a huge milestone by running its first live production trades of tokenized DTC-held stocks. It was the broadest tokenization production effort to date, spanning multiple asset classes and a wide range of participants, including JPMorgan, BlackRock, and Goldman Sachs. 

Last month, the NYSE signaled a move toward full onchain settlement by announcing partnerships to further the development of tokenized securities markets, while Nasdaq confirmed plans for a 23-hour trading day.  

It’s clear that a major shift is taking place. Tokenized stock trading, or the buying and selling of digital tokens on a blockchain which represents real company shares, has moved past the pilot phase into infrastructure and production. The major question left standing is governance, and specifically, who is accountable for the ownership record once a single stock can trade on more than one exchange or trading venue. 

Understanding Tokenization Models 

Let’s dive deeper. To understand governance’s role in tokenization, we need to first examine the different tokens being utilized and how they will be impacted going forward.  

First, consider third-party sponsored tokenized securities, the traditional back-end model. Here, a third party, like a special purpose vehicle (SPV) or broker-dealer, issues a crypto asset tied to an underlying security, rather than the issuer itself placing the ownership record onchain. This category splits into two models: custodial and synthetic. 

With custodial tokenized securities, the third party issues a crypto asset, such as a tokenized security entitlement, that evidences the holder’s ownership interest, whether direct or indirect, in the underlying security held in custody. 

With synthetic tokenized securities, the third party instead issues a crypto asset representing its own security, such as a tokenized linked security or a tokenized security-based swap, that provides synthetic exposure to the underlying security.  

Depending on their structure, these tokens may not be backed 1:1 by any shares. Here, the underlying blockchain operates primarily as a digital wrapper or asset-tracking ledger, rather than the primary environment where the asset’s economic value is generated. For custodial tokenized securities, a specialized entity (like a SPV or broker-dealer) buys actual shares of a stock and holds them in a traditional custody account. 

The risk here is that the legally binding ownership still lives on a traditional transfer agent or central depository. So, for example, if a wrapper issuer goes bankrupt, the token holders may lose access to the underlying shares. 

In a blockchain-native or issuer-sponsored model, the blockchain can become part of the official ownership record rather than simply representing a claim on securities held elsewhere. The issuer of the stock, working with its transfer agent, chooses to maintain that official ownership record directly on a blockchain or a distributed ledger. Because the blockchain functions as that official record, dividends can be programmed to pay automatically through contracts, and voting rights can be exercised directly through the wallet holding the token. 

This is exactly why ensuring that transfer agents upgrade to blockchain-native infrastructure is vital. If a transfer agent can maintain the official ownership record onchain natively, public companies can issue shares that exist on blockchain while keeping the legal protections of traditional stock. 

Who Is Responsible for Ownership 

The regulatory framework laid out in the SEC’s Statement on Tokenized Securities dictates that changing the medium of a ledger does not absolve any recordkeeper of their legal obligations. 

The SEC explicitly stated that federal securities laws apply to tokenized assets in the exact same way they apply to traditional book-entry interests. The legal status of a security does not change based on whether it’s a paper certificate, a centralized database entry, or an onchain token. 

Stock needs an official ownership record to trade legally. That record can be onchain or offchain, but the issuer or its agent maintains it either way. This focus on strict recordkeeping was further reinforced by SEC no-action relief granted to financial institutions like Franklin Templeton. The regulatory relief focuses on the transfer agent’s ultimate control over the official ownership record, rather than who holds a private cryptographic key. 

The solution requires transfer agents to operate a single registry that tracks both traditional and tokenized shares simultaneously, maintaining one unified view of the official ownership record. Blockchain-native tokenization removes the third-party wrapper and can automate back-office functions like dividend distribution and shareholder voting. This model is already running in production with early adopters, an early signal that it can work within existing regulatory frameworks. 

How Does Tokenization Scale 

The DTCC’s October 2026 commercial launch of its tokenization service for real-world assets requires the infrastructure behind it to be fully operational before going live. If digital books and legacy ledgers drift by even a single basis point, corporate actions could fail, dividend distributions would break, and the market’s legal integrity would go with them. 

When a stock trades on the traditional settlement schedule but settles instantly on blockchain, determining who owns it at the moment of a dividend becomes a key operational problem. The transfer agent stops both systems at that exact moment, compiles one official ownership record, and proceeds with traditional shareholders paid through standard clearing and tokenized shareholders paid directly to their wallets. The two execution paths stay separate while the legal ownership stays unified. 

The mechanics already work in production, and the regulatory framework is clear. What protects your ownership when something breaks is governance. A single accountable party standing behind the official ownership record, whether that record lives onchain or off. When tokenization service goes live, that accountability is what will separate essential infrastructure from a liability.