Elizabeth M. Attanasio, CPA, Partner, Accounting and Compliance International
On September 17, 2026, the SEC took a significant step toward bringing blockchain technology into the traditional U.S. securities markets by issuing its new “Innovation Exemption“. The exemption creates a framework for certain venues to trade tokenized versions of traditional exchange-listed stocks onchain.
Think of a regular share of stock, but with ownership represented and recorded using blockchain technology—a shared digital ledger. Today, an entire traditional securities infrastructure sits behind the scenes to execute, clear, settle, hold and record that investment.
That is essentially a tokenized stock.
The basic transaction is still familiar: I own a security. You want to buy it. We agree on a price. Ownership changes hands. Somebody needs to keep an accurate record of what happened.
What changes is the technology behind it.
The SEC’s Innovation Exemption allows certain venues to temporarily experiment with trading tokenized versions of traditional exchange-listed stocks onchain without being treated exactly like traditional securities exchanges – provided they meet the SEC’s conditions.
The SEC isn’t throwing out the securities rulebook. It’s allowing the industry to try a new road while keeping the guardrails up.
So, What Actually Changed?
The SEC temporarily exempted qualifying Tokenized Securities Venues (TSVs) from the Exchange Act definition of an exchange, subject to numerous conditions. TSVs use permissioned automated market makers and liquidity pools to bring together buyers and sellers of tokenized NMS stocks.
The SEC also granted temporary, conditional relief from the definition of dealer to certain liquidity providers that contribute proprietary capital to those liquidity pools.
That second piece immediately gets my FinOp attention. Once we start talking about proprietary capital, securities positions, liquidity commitments and potential settlement exposure, we also need to start talking about net capital.
Tokenized Does Not Mean Unregulated
The technology may be new. The fundamental regulatory responsibilities are not.
The exemption includes meaningful guardrails. Among other things, tokenized NMS stocks are subject to symbol and volume limits; the tokenized security must provide holders the same rights and privileges as the equivalent traditional stock; smart contracts must be auditable and public; issuers have protections when an unaffiliated third party tokenizes their stock; and trading must stop when the underlying stock is halted on its primary listing exchange.
Moving a stock onto blockchain technology does not move it outside the securities regulatory framework. The SEC’s anti-fraud and anti-manipulation provisions still apply.
The Technology Is New. The FinOp Questions Aren’t.
Whenever a broker-dealer introduces a new product or revenue stream, the first question is: What are we actually doing?
Agent or principal? Are we holding a security? Is there a haircut? How does it hit the books, FOCUS Report and net capital – and does it require additional regulatory approval?
The terminology may be new, but the questions aren’t.
New technology. Same fundamental FinOp responsibilities.
Blockchain Doesn’t Replace Books and Records
There can be a misconception that blockchain solves the recordkeeping problem because the transaction exists on a digital ledger. For a regulated broker-dealer, it isn’t that simple.
The firm still needs complete and accurate books and records. Transactions still need to reconcile. Assets and liabilities need to be properly classified. Revenue needs to be appropriately recognized. Proprietary positions need to be identified and valued. Regulatory reports still need to accurately reflect the firm’s financial condition and activities.
The blockchain may tell us a transaction occurred. It doesn’t necessarily tell us where that transaction belongs on a broker-dealer’s books or FOCUS Report.
Please Give Your Fin-Op a Seat at the Table
Don’t wait until an entirely new tokenized-securities business is up and running and transactions have already been executed to bring in your FinOp at month-end and ask, “How should we book this?”
By then, the more important question may be: “Were we permitted and properly capitalized to do this in the first place?”
Your FinOp should understand the transaction structure, flow of funds, settlement mechanics, custody arrangements, proprietary exposure and anticipated balance-sheet impact before the business goes live.
Innovation can move quickly. So can a net capital problem.
Innovation Changes. Good FinOp Judgment Doesn’t.
The SEC has made clear that the Innovation Exemption is temporary. It is effective through September 17, 2031, and the Commission is soliciting public comment as it considers modifications and potential next steps.
So this area will continue to evolve – and we will continue to follow it for our clients.
Because whether a security moves through traditional market infrastructure or a smart contract on a blockchain, I’m still going to ask:
- What did we do?
- Where does it go on the books?
- What does it do to net capital?
- And were we permitted and prepared to do it?
Technology changes. Good FINOP judgment doesn’t.
How Can Broker-Dealers Navigate This?
ACI has long been at the forefront of our industry’s evolution. ACI served as the FinOp for the first SEC-approved Alternative Trading System (ATS) and as the first FinOp for a digital asset firm.
Our work also happens behind the scenes. We engage with regulators as new products and market structures develop, bringing practical broker-dealer experience to the conversation and helping our clients navigate the rules as they evolve.
As tokenized securities develop, we can help firms evaluate transaction flows; identify potential net capital, haircut and balance-sheet implications; assess accounting, FOCUS reporting, books-and-records and reconciliation requirements; and coordinate with compliance and regulatory counsel when appropriate.
That experience allows us to anticipate the financial and operational questions that come with innovation – not simply react to them after the fact.
As the industry evolves, ACI evolves with it – working to make regulatory change more manageable for our clients. Get in touch with us today to learn more about how we can support your business.
Sources:
- U.S. Securities and Exchange Commission, Press Release 2026-90, “SEC Issues Innovation Exemption to Facilitate the Trading of Tokenized NMS Stock and Request for Comment,” Sept. 17, 2026.
- Paul S. Atkins, SEC Chairman, “Statement on the Innovation Exemption: A Bridge Toward Durable Rulemaking,” Sept. 17, 2026.
- Mark T. Uyeda, SEC Commissioner, “Statement on the Innovation Exemption,” Sept. 17, 2026.