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DTCC builds out tokenisation platform after SEC no-action letter to DTC

DTCC is laying groundwork for a tokenisation platform after SEC staff issued a Dec. 11, 2025 no-action letter to DTC for a preliminary tokenised entitlement service covering select liquid DTC-custodied assets, with operational constraints and off-DTC DvP.

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Depository Trust & Clearing Corporation (DTCC) is positioning its tokenization initiative as a market-infrastructure build-out following regulatory clearance for a limited service at its depository subsidiary, according to a February 19 Global Custodian feature that said DTCC had secured “regulatory backing” and was laying groundwork for a flagship tokenisation platform. The article teaser identifies the interview subject as Nadine Chakar, DTCC Digital Assets’ global head, and frames the effort as an infrastructure project rather than a standalone issuance programme .

The regulatory milestone underpinning DTCC’s effort is a U.S. Securities and Exchange Commission (SEC) Division of Trading and Markets staff no-action letter to The Depository Trust Company (DTC), dated December 11, 2025, covering a “Preliminary Base Version” of what DTC describes as “DTCC Tokenization Services”. DTCC said the staff position supports tokenization of a defined set of highly liquid DTC-custodied assets—Russell 1000 equities, certain index-tracking ETFs, and U.S. Treasuries—and stated the service is anticipated to be production-ready in the second half of 2026.

Operationally, DTC’s model would record certain security entitlements using distributed ledger technology while keeping registered ownership unchanged in the name of DTC’s nominee, Cede & Co., with tokens representing “tokenized entitlements” minted to participant-registered wallets on supported blockchains. The letter describes how securities would be moved into a DTC “Digital Omnibus Account” pursuant to a tokenization instruction, with on-chain transfers tracked by DTC systems for its official books and records; it also states any delivery-versus-payment settlement would occur away from, and without involvement by, DTC in the preliminary version.

The SEC staff position is framed as time-limited and conditional. The no-action letter states it would be withdrawn without further action three years after DTC launches operation of the Preliminary Base Version, and outlines reporting and operational limitations, including wallet registration controls and compliance checks. In a statement discussing the staff letter, SEC Commissioner Hester Peirce characterized the initiative as a pilot with operational constraints and tied it to the Commission’s broader engagement with tokenization mechanics under existing market structure rules.

Market-structure work is also developing at the exchange level. A Federal Register notice published January 30 describes a Nasdaq proposed rule change designed to allow trading of securities in tokenized form during the pendency of DTC’s pilot programme operated pursuant to the SEC staff no-action letter, including order-entry flags for participants indicating tokenized clearing and settlement preferences. The same notice sets conditions for fungibility—tokenized and traditional shares would need to share the same CUSIP and rights to trade together—and contemplates public trader alerts to identify which securities are eligible in tokenized form during the pilot.

In parallel, DTCC has pointed to specific technology pathways. DTCC’s tokenization programme materials describe supporting multiple blockchain ecosystems that meet DTC standards and list DTCC’s AppChain and the Canton Network among “current networks,” alongside a set of token controls such as mint, burn and clawback. DTCC also announced a partnership with Digital Asset and Canton to enable tokenization of a subset of DTC-custodied U.S. Treasury securities, with an MVP planned in a controlled production environment in the first half of 2026.

What this affects is primarily regulated intermediaries and market utilities—DTC participants, exchanges, and service providers—who would need to adapt operational processes for wallet registration, entitlement transfers, and off-DTC settlement mechanics under the pilot constraints described by the SEC staff. Issuers and investors are indirectly affected to the extent eligible securities may be traded and held in tokenized form under exchange and depository frameworks, while supervisors gain a bounded test case anchored to no-action conditions and reporting commitments rather than a wholesale rule change.

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