Vertalo Innovation Exemption Demo

Vertalo orchestration for the Innovation Exemption · Release 34-106402

Listed companies

A stranger's token of your stock can now trade. You get 30 days to say no.

When a firm unaffiliated with your company tokenizes your stock, a venue that wants to trade the token must first send written notice to your principal executive offices. It then waits 30 calendar days from the day you receive it. Object in writing inside that window and the venue cannot make the token available for trading. Vertalo runs that process for you, alongside the transfer agent you already have.

A company listed on a U.S. exchange, whatever firm keeps its register.

What the order does to you

  • The notice goes to the physical or email address for your principal executive offices on the cover of your Exchange Act reports. The 30 days run from the day you receive it. (II.D)
  • An objection in writing on or before the 30th calendar day means the venue cannot make that token available for trading. Say nothing and the right to object to that token on that venue is gone. (II.D)
  • The order names the reason a company might object: an issuer "may be concerned about the risk of maintaining its shareholder register related to onchain transfers." (II.D)
  • A token holder is owed the same dividends, votes and share on liquidation as a shareholder, and the third party must make proxy materials available to token holders at no cost to you or your shareholders. (II.E)
  • A company can instead tokenize its own stock, or have it tokenized on its behalf. The third-party notice and objection provisions are written for tokens made by a third party unaffiliated with the company. (II.D)

The gap

Corporate mail was not built to start a legal clock. The order names nobody to receive the notice for you, run the 30 days, or keep the record of what was decided.

What Vertalo runs

A desk for every notice

Run by Vertalo's team

You forward each Issuer Notice as it arrives. Vertalo's team dates it, starts the 30-day clock from the day you received it, and puts the decision in front of the people you name, with reminders until it is made. (II.D)

What you need to decide

Run by Vertalo's team

For each notice, one file: the venue, the third party, where the shares behind the token are held, how often supply is reconciled, and how dividends and proxies reach holders. It draws on the venue's public Notice and the third party's own disclosures, and names what they leave out. (III)

The objection, if you make one

Run by Vertalo's team

Drafted by one person and confirmed by a second, then delivered to the contact the venue's notice gives inside the 30 days, with proof of receipt kept. The venue then has five business days to amend its public Notice, and the desk checks that it did. (II.D, II.C)

Tokens of your stock, tracked

Run by Vertalo's team

Which venues admitted a token of your stock, which firm made it, and the position behind it, kept current with the data your transfer agent provides under your authorization.

Evidence that rights arrived

Run by Vertalo's team

At each dividend and each meeting, a record of whether the payment and the proxy materials reached token holders, for your securities team to rely on. (II.E)

Your transfer agent, your decision

Stays with you

Your current transfer agent keeps your register. Whether to object is your decision, made with your counsel.

What Vertalo is not

  • Vertalo does not replace your transfer agent and does not ask you to switch. It works alongside the agent you have.
  • Vertalo does not decide for you. Nothing it provides is legal advice, and nothing here makes a company compliant.

How day one works

From go-live, Vertalo's team runs the orchestration for you on your records, with the console you can walk today on sample data at innovation.vertalo.com. Fees start when your service goes live.

Billing starts on go-live, the day Vertalo confirms your desk is running.

See your side working

innovation.vertalo.com is a working model of the whole arrangement on sample data: a listed company's stock, tokenized by a firm unaffiliated with the company and traded on a Tokenized Securities Venue. Six seats read one record: the transfer agent, the issuer, the tokenizer, the venue, the token holder and the examiner. Every provision the model runs is quoted word for word at innovation.vertalo.com/order.

See your side workingReal company, sample numbers, real rules.

Your plan

  1. 1KickoffBothOct 2, 2026

    Name who decides on a notice, who confirms an objection, and your counsel's contact.

  2. 2Mail routingYouOct 5, 2026

    Whoever opens mail and email at your principal executive offices forwards any Issuer Notice to your desk on the day it arrives.

  3. 3Data authorizationYouOct 7, 2026

    You sign a letter authorizing your transfer agent to give Vertalo the position data the service reads. Vertalo supplies the letter.

  4. 4Your deskVertaloOct 12, 2026

    Vertalo opens your desk with your listing facts and any tokens of your stock already known.

  5. 5Go-liveVertaloOct 14, 2026

    Vertalo confirms the desk is running. Billing starts.

  6. 6First status reportVertaloOct 21, 2026

    Every notice, clock and token of your stock known to the desk, in one report.

Where you stand

If an Issuer Notice arrived at your principal executive offices tomorrow, who would open it?
Do you know of tokens of your stock today, anywhere?
Would your company consider tokenizing its own stock?

Your estimate and proposal

Your details

What you type here, your name, email and company, goes to Vertalo with the counts you entered, so somebody can follow up, along with the name of the link that brought you, if you followed one. It does not record your IP address or your browser.

Questions

Do we have to change transfer agents?

No. Vertalo works alongside the agent you have, with position data your agent provides under your authorization.

What does it cost if nobody tokenizes our stock?

The same flat monthly fee. It does not change with the number of tokens of your stock, because the desk has to be ready before the first notice arrives.

Can Vertalo object for us?

Vertalo drafts, records and delivers the objection your people confirm. The decision is yours, made with your counsel.

Does an objection stop the token from existing?

An objection stops the venue from making that token available for trading on the venue. It does not reach the firm's wrapping of your stock. (II.D)

What if we want our own token?

The order allows tokenization by or on behalf of the issuer, and Vertalo can set out the options with your transfer agent. Tokens are optional; your register stays the record.