As the U.S. Securities and Exchange Commission (SEC) weighs the first rewrite of its transfer agent rules in more than four decades, OpenAssets, a digital asset infrastructure provider focused on global equities, said its affiliate SEC-registered transfer agent, OpenAgent, already operates the recordkeeping model the proposal would permit: the shareholder record onchain, investor identity offchain.

According to the company, OpenAgent records position and transaction data onchain as part of the register — wallets, quantities, and every mint, burn, or transfer. Personal data stays in private systems, and a wallet-to-customer mapping joins the two. For issuers, that means the register is designed to be read as it changes, rather than received as a finished file after the fact.

Transfer agents are the entities responsible for maintaining the official shareholder record — the master file on which core shareholder processes such as dividend distributions and proxy voting depend. Under the SEC's September 1 proposal, a registered transfer agent would be allowed to use a distributed ledger for all or part of its master securityholder file. Personal data would remain in private systems, while position data — including share counts and wallet addresses — would sit onchain.

How tokenized stocks are structured, the company argues, makes all the difference. A token recorded on a company's own shareholder register, with the company's consent, is a different instrument from a token issued by an unrelated party that tracks a share's price. The SEC's proposed Form TA-2 reporting would count the two separately, as issuer-sponsored and third-party-sponsored. The distinction now carries into trading as well: under the SEC's Innovation Exemption of September 17, tokenized stocks on qualifying venues must give holders the same rights as the underlying shares.

"A tokenized stock is only as good as the register behind it," said Gabor Gurbacs, Chairman and CEO of OpenAssets. "The SEC is right to let the official record live onchain, and the market should hold that record to the same standard as any shareholder register. OpenAgent already works this way: every transfer is recorded as it happens, and investor identity stays private. Choosing a transfer agent now means choosing which record the market will trust."

OpenAgent is designed for issuers of tokenized securities, as well as the exchanges and counsel that work with them. The SEC is accepting comments on the proposal through Nov. 3; once the period closes, the agency would review the feedback before any final rule could take effect, setting the ground rules under which registered transfer agents may keep their master securityholder files on a distributed ledger.