Vertalo orchestration for the Innovation Exemption · Release 34-106402
Transfer agents
Release 34-106402 lets a venue trade a token of your issuer's stock after a firm your issuer never met tokenizes it. The order puts the notice, the 30-day clock and the rights check on the venue, and never says who keeps the record underneath. Vertalo licenses that orchestration to any transfer agent, and you stay the agent of record.
A registered transfer agent that keeps share registers for listed companies.
The conditions that turn on who owns the shares are work a transfer agent already does. The order names nobody to do it: "transfer agent" appears zero times in its 60 pages.
Each Issuer Notice an issuer forwards is dated on arrival, its 30-day clock runs from the date of receipt, and the decision goes to the people the issuer names. (II.D)
An objection is a written instrument, drafted by one person and confirmed by a second, delivered to the contact the venue's notice gives, with proof of receipt kept. (II.D)
Where a custodian holds the shares behind a third party's token in registered form, its position sits on your issuer's register as its own line, recorded by your staff. Vertalo's team reconciles token supply against it and produces the attestation a venue's item i cites. (III)
Positions by security come straight from the register of record, the same book your agency acts are recorded on.
list_holdings_by_security · list_holdings_by_investor · get_security
At each record date the positions behind every wrapped issuance are resolved to holders, so dividends and votes can be passed through and your issuer can see where they went. (II.E)
Notices, clocks, objections, reconciliations and attestations are kept as dated records, exportable in human-readable and electronic form. (II.L)
Transfers, issuances and cancellations on your book stay with your staff, and your fees to your issuers stay yours.
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.
The license year starts on go-live, the day Vertalo confirms the service is running on your records.
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.
Name your project lead and the two people who approve every objection record. Choose the issuers to start with.
Your vendor and security review of Vertalo, and the data terms for your issuers' records.
Vertalo stands up your instance of the console on the Vertalo platform, under your name.
Vertalo loads the registers of the starting issuers from your files, and your staff reconcile the load before it is used.
Each starting issuer names who opens mail at its principal executive offices and forwards any Issuer Notice to its desk on arrival.
Vertalo confirms the service is running on your records. The license year starts.
Every notice, clock and wrapped issuance on your book, in one report.
No. You choose which issuers start. The license covers your book on the platform and every wrapped issuance on it.
You do. Your issuers' records are your customer data and can be exported at any time in a machine-readable format.
No. Vertalo licenses this to any transfer agent. Where an issuer's agent runs on Vertalo, the issuer is served through its agent.
Yes, as an option: the Tokenization Service, priced per program in the proposal. Tokens are optional, and the register is the record either way.
One tokenized representation of one of your issuers' securities, whether a third party's program or the issuer's own class, counted once however many venues admit it. The count is measured on each anniversary.