🗳️ How should TAD rule changes be affected?

[JFWooten4]

There are some material legacy securities law applications which the Syndicate will need to clarify. What approach could we best take in the legacy securities oversight framework?

I presently forsee two options:

SRO Rulemaking

Without giving consideration after the entity governed, this would generally involve SEC recognition as an SRO. We could make rule changes through the traditional process forum, which has the added benefit of simplifying the organization of a large number of changes. I forsee at least a few of these, and it might be a good way to get the regulator input IF they don't join the DUNA.

No-Action Letters

Technically existing SROs like the DTC could operate by (at least in theory) submitting request for interpretive deference for each of their rule changes. Generally, these are used for more specific one-off items related to unique corporate activities or market changes. I could definitely get a lot done here, but it might mess you up the relatively brief list of existing transfer agent no-action letters. Nothing against it, but it does loosen the position of protections enhanced and provided by a specific TAD framework using digital assets.¹

Footnotes

1. Uh, why did DTC have to ruin that term for me every time I consider it now? 😂 ↩