Is the blockchain the official ownership record for a tokenized security?

It can be, but only if the transfer agent makes it so. SEC trading and markets staff said in May 2025 that a registered transfer agent may use distributed ledger technology as its master securityholder file or a component of it, without keeping a duplicate off-chain copy, provided it meets the transfer agent rules. Many issuers instead keep the official record off-chain and treat the chain as a secondary record; Franklin's FOBXX documents describe the transfer agent's book entry as the official record. Read the documents for which record controls.

Why is personal information not on the chain?

Because the master file includes names, addresses, tax numbers and other private data that should not be public. Staff described a split in which transaction information, such as wallet address, balance, number of shares, purchase date and transaction ID, is kept on-chain while personal information is kept off-chain in the transfer agent's systems, the two linked together as one record.

What is a record difference?

A mismatch between the total in the master securityholder file and the total in the control book, or a transferred security whose details differ from the master file in a way that cannot be resolved immediately. For a token issued on several chains, the sum of balances on every chain and in book entry must equal the shares issued; any gap is a record difference to be researched, and old ones trigger buy-in requirements.

If the chain and the transfer agent disagree, who wins?

Whatever the documents say. Most make the transfer agent's records authoritative and give it power to correct the chain, burn and reissue tokens or freeze wallets. FOBXX's prospectus says shares on the transfer agent's system are under its unilateral control and that it can correct the records.

Does every token count as a registered holding?

Only tokens the transfer agent recognizes. A wrapped or bridged copy minted by someone else is not an entry in the issuer's master file; the locked original is. A token held through a broker or custodian is usually registered in the intermediary's name, with the investor's position on the intermediary's books.

Master Securityholder File

Custody & Settlement

Definition

The master securityholder file is the official list of individual securityholder accounts for an issue of securities, in the words of Exchange Act Rule 17Ad-9(b). It is kept and updated by the issuer's recordkeeping transfer agent, and it is the record that says who the registered owners are and how many shares or what principal amount each holds. For uncertificated securities of registered investment companies the rule allows it to consist of multiple linked automated files. Alongside it sits the control book, the record of the total amount the issuer has authorized and issued; when the two do not agree, there is a record difference the transfer agent must research and resolve. For a tokenized security, SEC staff describe issuer-sponsored tokenization as integrating a blockchain into the systems that record owners so that a transfer of the token on the network results in a transfer of the security on the master securityholder file. Whether the chain is the official record, part of it, or a secondary copy is set by the transfer agent's system and the offering documents.

Why it matters

Tokenization is often described as putting ownership on the blockchain. Legally, ownership of a security is whatever the issuer's official register says, and the master securityholder file is that register. A token holder's rights therefore depend on how the transfer agent connects the chain to the file: whether a transfer on the chain is itself a transfer on the register, whether the agent must record it first, and which record prevails when they disagree. The answer decides what happens when a wallet is lost, when tokens are sent to an ineligible holder, when a bridge mints unauthorized copies, or when an issuer fails and a successor agent has to rebuild the register. AltStreet reads the documents of every tokenized product it reviews for this point, because two tokens that look identical on-chain can rest on very different records.

Common misconceptions

•The token contract is not the register by default. It is the register only if the transfer agent's system makes it the official record or a component of it.
•An on-chain balance is not proof of registered ownership. A wrapped copy or an unrecognized transfer may not be on the master file at all.
•Keeping the record on-chain does not put personal data on-chain. Identity data stays in the transfer agent's off-chain systems, linked to wallet records.
•A blockchain record does not remove the transfer agent's duties. Posting, reconciliation, safeguarding and retention rules still apply.
•Multi-chain issuance does not mean several registers. It is one master file whose entries sit on several networks and in book entry.

Technical details

The definitions in Rule 17Ad-9

Master securityholder file: the official list of individual securityholder accounts; for uncertificated registered fund shares, it may consist of multiple linked automated files.

Control book: the record of the total shares or principal amount the issuer has authorized and issued.

Credit and debit: the addition or cancellation of holding details on the master file.

Record difference: the master file total does not equal the control book, or a transferred security's details differ from the master file and cannot be resolved immediately.

Recordkeeping transfer agent: the registered transfer agent that maintains and updates the master file.

Using a blockchain as the master file

SEC staff view (May 15, 2025 FAQ): a registered transfer agent may use distributed ledger technology as its master securityholder file or a component, and need not keep a duplicate off-chain 'digital twin', if it meets the transfer agent rules.

Rules that still apply: records and retention (Rules 17Ad-6 and 17Ad-7), prompt posting (17Ad-10), record differences and buy-ins (17Ad-11), safeguarding (17Ad-12) and accounting controls (17Ad-13), plus SEC examination access.

Typical split: on-chain wallet address, balance, ownership percentage, shares, purchase date and transaction ID; off-chain name, investor ID, address, tax ID and other private information.

Issuer-sponsored tokens (SEC statement of January 28, 2026): the issuer or its agent integrates the chain into its ownership records so that a token transfer results in a transfer on the master file.

Reconciliation across chains: a worked check

Control book: 10,000,000 shares issued.

Master file entries: 9,600,000 on chain A, 300,000 on chain B, 99,000 in book entry, total 9,999,000.

Record difference: 1,000 shares, to be researched (a delayed posting, a mint without a control book entry, or a burn not recorded).

If unresolved, aged record differences require buy-ins or equivalent action under Rule 17Ad-11.

What an investor can check: published supply per chain and in book entry against total shares outstanding, as Superstate's fund pages show.

Which record controls: examples

Franklin FOBXX: the transfer agent's book entry is the official record and the blockchain a secondary record; the prospectus gives the agent unilateral control over shares on its system and the right to correct records.

Securitize: consent-gated transfers with official records kept off-chain by its registered transfer agent.

Superstate: Superstate Services keeps each fund's register across the networks it supports and book entry, publishing the share count for each.

Figure YLDS: certificates recorded by Figure Equity Solutions through a proprietary blockchain-integrated system on Provenance, with the agent able to correct records.

Questions for any tokenized security

Is the chain the master file, a component of it, or a secondary record?

Does a token transfer change the register immediately, or only after the agent records it?

Which chains and contract addresses does the agent recognize?

How are record differences researched, and are reconciliations published?

If the transfer agent stops operating, who takes over the master file and how?

Frequently asked questions

Is the blockchain the official ownership record for a tokenized security?: It can be, but only if the transfer agent makes it so. SEC trading and markets staff said in May 2025 that a registered transfer agent may use distributed ledger technology as its master securityholder file or a component of it, without keeping a duplicate off-chain copy, provided it meets the transfer agent rules. Many issuers instead keep the official record off-chain and treat the chain as a secondary record; Franklin's FOBXX documents describe the transfer agent's book entry as the official record. Read the documents for which record controls.
Why is personal information not on the chain?: Because the master file includes names, addresses, tax numbers and other private data that should not be public. Staff described a split in which transaction information, such as wallet address, balance, number of shares, purchase date and transaction ID, is kept on-chain while personal information is kept off-chain in the transfer agent's systems, the two linked together as one record.
What is a record difference?: A mismatch between the total in the master securityholder file and the total in the control book, or a transferred security whose details differ from the master file in a way that cannot be resolved immediately. For a token issued on several chains, the sum of balances on every chain and in book entry must equal the shares issued; any gap is a record difference to be researched, and old ones trigger buy-in requirements.
If the chain and the transfer agent disagree, who wins?: Whatever the documents say. Most make the transfer agent's records authoritative and give it power to correct the chain, burn and reissue tokens or freeze wallets. FOBXX's prospectus says shares on the transfer agent's system are under its unilateral control and that it can correct the records.
Does every token count as a registered holding?: Only tokens the transfer agent recognizes. A wrapped or bridged copy minted by someone else is not an entry in the issuer's master file; the locked original is. A token held through a broker or custodian is usually registered in the intermediary's name, with the investor's position on the intermediary's books.