Five Companies Urge SEC to Allow Wallet Addresses in Shareholder Records

A significant debate is emerging in the United States over how stock ownership should be officially recorded. Figure, Securitize, Equiniti, Plume, and Centrifuge have submitted a joint letter to the U.S. Securities and Exchange Commission (SEC), calling for digital wallet addresses to be recognized as a means of identifying holders of tokenized securities. The November 3, 2026, submission challenges the requirement to collect shareholders' names and physical mailing addresses in every situation. If regulators adopt the proposal, it could establish a new regulatory framework for recording and managing blockchain-based shares.

Five Companies Submit Joint Proposal to SEC

On September 1, 2026, the SEC published a comprehensive proposal to modernize regulations governing transfer agents. These entities maintain shareholder records for companies and process changes in securities ownership. The foundations of the existing regulatory framework date back to the late 1970s and early 1980s. The SEC's proposal seeks to update these rules in response to developments in electronic recordkeeping systems and blockchain technology.

In their 14-page joint letter submitted to the SEC, the companies expressed support for the regulator's efforts to modernize the framework. However, they argued that the proposed approach to collecting shareholder information lacks sufficient flexibility. Under the proposal, shareholders' names and physical mailing addresses would remain essential records, while digital wallet addresses and email addresses would be treated as supplementary information. The five companies are asking regulators to permit reliable electronic identification methods without necessarily requiring a physical address.

Can Digital Wallet Addresses Identify Shareholders?

At the center of the joint letter is a fundamental question: What role should a digital wallet address play in official shareholder records? According to the companies, a blockchain wallet address can serve as a unique identifier for an account holding securities. This would allow transfer agents to manage shareholder records directly on blockchain networks using appropriate verification mechanisms. However, the uniqueness of a wallet address does not, by itself, establish the legal identity of the person controlling it.

The proposal is particularly relevant to investors who hold tokenized shares directly in their digital wallets without relying on traditional brokerage intermediaries. In conventional financial markets, securities are frequently recorded through intermediary institutions. Blockchain-based models, by contrast, can enable more direct ownership records. The companies argue that requiring every investor to provide an additional physical mailing address could increase operational costs and create further security risks associated with storing sensitive personal information.

A New Framework for Blockchain-Based Shareholder Records

The five companies' recommendations extend beyond digital identity verification. Their joint submission also calls for changes to the rules governing shareholders who have selected electronic communications but subsequently become unreachable. Rather than requiring transfer agents to focus exclusively on locating an updated physical mailing address, the companies propose allowing them to make at least two contact attempts using available communication channels, including email addresses, telephone numbers, and digital wallet addresses.

Other industry organizations have also joined the regulatory discussion. The Blockchain Association supported recognizing blockchain-based records as official shareholder recordkeeping systems and advocated technology-neutral regulations. Meanwhile, the Securities Industry and Financial Markets Association (SIFMA) emphasized the importance of preserving investor protections and regulatory accountability as transfer agents' activities evolve. Another important aspect of the debate concerns how shareholder recordkeeping obligations should be distinguished from anti-money laundering compliance requirements.

Kriptofoni Assessment

The significance of this development extends beyond expanding the use cases for digital wallets. The central issue is how records maintained on blockchain networks should be recognized as part of, or as the entirety of, a legally valid shareholder recordkeeping system. The framework ultimately adopted by the SEC could influence the future relationship between traditional capital markets and tokenization infrastructure.

Nevertheless, no new rule has been approved at this stage. The joint submission represents the views of five companies participating in the SEC's regulatory consultation process. The extent to which digital wallet addresses will be permitted, how shareholder identities will be verified, and what safeguards will protect investors remain open questions. The answers could play a decisive role in determining how blockchain technology becomes integrated into traditional equity markets.