Fidelity Investments has submitted a letter to the SEC Crypto Task Force responding to Commissioner Hester Peirce’s December request for information on how national securities exchanges and alternative trading systems (ATSs) could support tokenized securities trading. Unlike many respondents to SEC consultations, Fidelity has direct skin in the game: its carrying broker dealer, National Financial Services, operates CrossStream, an NMS stock ATS.
The letter makes four broad asks, but three of them surface regulatory friction points the SEC has yet to resolve.
Fidelity’s most pointed request is for brightline standards that would allow ATSs to rely on the regulatory status ascribed to a tokenized instrument by its issuer, without independently underwriting the legal analysis.
The concern is practical. The SEC’s January 2026 statement on the taxonomy of tokenized securities identified several distinct structures: direct issuances, indirect entitlements, structured products linked to securities (eg. xStocks), and instruments that may constitute securities-based swaps (eg. Robinhood’s tokenized stocks). The last category carries retail restrictions, and the analysis turns on economic substance rather than labeling. A broker dealer operating an ATS is not well placed to make that determination for every instrument it lists.
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