GUARDD Comment Letter to SEC Crypto Task Force: Tokenization, Secondary Trading, and Structured Disclosure Compliance Frameworks

On behalf of GUARDD, we submitted feedback to the SEC Crypto Task Force on the important topics raised during the May 12, 2025 Tokenization Roundtable. We appreciate the leadership of Chair Atkins, Commissioner Peirce, and Commissioner Crenshaw in convening this dialogue and their thoughtful remarks exploring the future of tokenized securities and the regulatory infrastructure necessary to support innovation, compliance, and investor protection.

GUARDD is a technology platform that facilitates lawful secondary trading of exempt, unregistered, and unrestricted securities—including tokenized assets—by supporting issuer disclosures, state blue sky compliance, and broker-dealer readiness under existing frameworks. We serve issuers across Regulation A, Regulation Crowdfunding, and emerging digital asset markets, providing a structured disclosure model that enables cost-effective compliance with both federal and state obligations.

As policymakers consider how best to evolve regulatory treatment for tokenized securities, we respectfully submitted this comment to: (1) highlight structural frictions in secondary trading for tokenized and exempt securities, (2) explain how GUARDD addresses these challenges within the current regulatory landscape, and (3) offer recommendations that support innovation while maintaining transparency and investor protections.

The Market Reality: Tokenization Without Infrastructure

The promise of tokenized securities lies in efficiency, transparency, and accessibility. However, the operational reality for many token issuers remains challenging. Without clear pathways for lawful trading, tokenized securities often remain illiquid, despite the technological advantages that blockchain can provide.