KETJU Research

← Eligibility files

Eligibility file · Mixed

DTC Tokenization Service: tokenized security entitlements to DTC-held stocks, ETFs, and Treasuries

What the client owns
SPDR S&P 500 ETF Trust; Invesco QQQ Trust. DTC-tokenized (same CUSIP): The listed share itself, held through DTC under the same CUSIP.
Who may hold it
US retail investors. First purchase minimum not stated. State coverage not confirmed by the issuer. DTC’s terms admit only DTC Participants as wallet holders and entitlement holders. A Participant may open wallets for customers and give them keys, but DTC recognizes only the Participant. DTC sets no investor eligibility rule or minimum; any rule for retail investors is the Participant’s. No Participant had published retail terms as of 2026-09-22. For now, DTC excludes Participants with DTC tax-withholding or TIC reporting obligations (about 11% in Oct. 2025). The eligible securities are Russell 1000 stocks, major-index ETFs, and U.S. Treasury bills, notes, and bonds. This file lists SPY and QQQ because DTCC names them in its July 15, 2026 production trades.
Who can freeze or claw back
DTC holds a root wallet on every chain that can convert, transfer, mint, or burn any token without the holder’s key. No contract is public, so Ketju cannot read the keys yet.
How a holder redeems
Sell on the listing exchange, T+1 through DTC. The Participant instructs DTC to de-tokenize; DTC burns the token and credits the shares to the Participant’s DTC account. To get cash, the holder sells the shares in an ordinary sale, which settles T+1. DTC states no time for the de-tokenization step. Settles in USD.

In plain words on RIADeFi: The SEC’s tokenized stock exemption, explained · DTC-tokenized shares, explained.

Subscribers see which of their clients hold this program and whether each household qualifies under these terms, and Ketju emails them when the file changes. $299 per firm per month, first 30 days free.

The verdict is on the memo: DTC Tokenization Service (DTC-tokenized stocks, ETFs, and Treasuries) Not approved

Issuer
The Depository Trust Company (token issuer and securities intermediary; each underlying security keeps its own issuer)
Registration
NMS stock via DTC
Official record
The Depository Trust Company (securities intermediary; SEC-registered clearing agency). Issuer transfer agents record Cede & Co. as holder., SEC-registered transfer agent
Instruments
SPY QQQ
Chains
None
Reviewed
2026-09-23
Next review
2026-12-23

Other programs tokenize the same securities. Every version side by side: SPY, QQQ.

Eligibility

Each answer quotes the issuer’s own words from the document named under it. Ketju reads each document again and records whether the words are still there. Where the documents say nothing, the row states that.

What the holder owns

The Participant keeps a security entitlement against DTC under UCC Article 8; the token records that entitlement and is not a separate security.

“The Participant would (until it transfers the Tokens) remain the entitlement holder with a security entitlement to the Subject Securities subject to the full suite of Article 8’s provisions and protections.”

SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025) · DTC request, Section II.a, p. 7 · words found 2026-09-23

Who may hold it

Only DTC Participants register wallets. A Participant may open one for a customer and hand over keys, but DTC recognizes only the Participant as holder.

“While a Participant may register a wallet for the benefit of its customer and even provide that customer with the keys to the wallet”

SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025) · DTC request, Section II.e ’Only Participants May Register Wallets’, p. 12 · words found 2026-09-23

First purchase minimum

DTC sets no minimum. Any minimum is the Participant broker’s, and no Participant has published terms.

Not stated in SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025), DTCC, SEC No-Action Letter & DTC Tokenization Service FAQ (rev. 3.3.26; archived copy, live URL now returns 404), DTCC, Tokenization Service product page, DTCC press release, U.S. trades processed using DTC-tokenized assets (July 15, 2026).

Who it may be transferred to

Tokens move only between wallets that DTC has registered to Participants and screened against OFAC lists; no other wallet can receive them.

“The tokens would only be transferable to Registered Wallets.”

SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025) · Staff response, bullet ’Limited to Participants/Registered Wallets’, p. 6 · words found 2026-09-23

How a holder redeems

The Participant tells DTC to de-tokenize. DTC burns the token and credits the shares back to the Participant’s ordinary DTC account.

“Upon acceptance of such instruction, DTC would burn the Token in the DTC Participant’s Registered Wallet, debit such securities from the Digital Omnibus Account, and credit those securities to the Participant’s Account.”

SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025) · Staff response, facts bullets, p. 3 · words found 2026-09-23

Who keeps the official record

DTC keeps its official books for tokenized positions in LedgerScan, an off-chain DTCC system that reads the chain. Token balances on the chain are not DTC’s official books.

“For recording Tokenized Entitlements, LedgerScan’s record would constitute DTC’s official books and records.”

SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025) · DTC request, Section II.a ’Operational Flow’, p. 7 · words found 2026-09-23

What the issuer says it can freeze or take back

DTC holds a root wallet on every chain that can convert, transfer, mint, or burn any token without the holder’s key.

“DTC would have a “root wallet” on each blockchain with keys that it can use to convert, transfer, mint, or burn any of the Tokens, even without the private key for the Registered Wallet.”

SEC Division of Trading and Markets, no-action letter to DTC with DTC’s request attached (Dec. 11, 2025) · DTC request, Section II.e ’Override Keys’, p. 12 · words found 2026-09-23

FactAnswer
Who onboards the holderbroker dealer
Voting rightsYes
Distributionscash
SIPC coverage of the walletNo

The transfer agent’s SEC record

DTC is an SEC-registered clearing agency. Clearing agencies register under Exchange Act section 17A(b)(2), not on Form TA-1, so EDGAR holds no transfer-agent registration to read.

Who controls it

Ketju read these powers from the deployed contracts and their verified source code: the token and every contract it checks on a transfer. A power listed here is something the issuer can do; it does not mean the issuer has used it.

No token contract for this program is public, so Ketju cannot yet read anything from the chain. The issuer’s own statement of its powers is quoted above. Ketju will read the contract on the day the issuer publishes it.

Where it trades

VenueKind
Nasdaq Stock Market (SR-NASDAQ-2025-072, approved 2026-03-18; effective after DTC post-trade service and 30-day notice)exchange
New York Stock Exchange (SR-NYSE-2026-17, immediately effective)exchange
NYSE Arca (SR-NYSEARCA-2026-45, immediately effective)exchange
NYSE American (SR-NYSEAMER-2026-36, immediately effective)exchange
NYSE Texas (SR-NYSETEX-2026-13, immediately effective)exchange
NYSE National (SR-NYSENAT-2026-09, immediately effective)exchange
24X National Exchange (SR-24X-2026-20, immediately effective)exchange

Redemption

RouteSettlementSettles in
Sell on the listing exchange, T+1 through DTCThe Participant instructs DTC to de-tokenize; DTC burns the token and credits the shares to the Participant’s DTC account. To get cash, the holder sells the shares in an ordinary sale, which settles T+1. DTC states no time for the de-tokenization step.USD

Daily checks

No contract is public yet, so Ketju has nothing to read on chain. Ketju reads the documents quoted above every day and opens a review when any of them changes; that is how Ketju learns of a newly published contract. Ketju adds the contract to its daily checks on the day it is published.

File history

Ketju has not revised this file since filing it. If Ketju revises it, the earlier version stays as published, with the reason.

DateChange
2026-09-23Filed.

Sources

Every file is public. With a subscription, Ketju checks each of your households against the file and checks the file every day. $299 per firm per month, first 30 days free. Start the trial.