Request of the SEC
On December 12, Templum issued a formal letter to the SEC, outlining not only the potential impact that blockchain can have on various industries, but recommendations for asset treatment.
What did it entail?
Digital securities as a whole clearly need clarity. However, the request on behalf of Templum focused, primarily, on ‘guidance related to post-trade activities in the digital asset space.’
After listing various examples in detail that require guidance, Templum leaves the SEC with 3 simple points of recommendations. The following points are a directly from their letter:
- Clearly define when a blockchain technology platform must register as a clearing corporation and define how blockchain technology may be used by such firms.
- Provide clear guidance to the industry as to when a blockchain technology platform must register as a transfer agent and provide guidance to issuers of digital assets as to when they must use a transfer agent.
- Modernize the Custody Rule and the Customer Protection Rule to take in to account and encourage the use of blockchain technology’s ability to track securities transactions.
Closing out their request, Templum imparted their positive view on the potential of blockchain. They stated, “We believe that blockchain is a potent modernizing force in financial services. Blockchain has the potential to increase efficiencies in post-trade mechanics and increase auditability, both benefits that would greatly benefit the industry. In order to best take advantage of this potential, the SEC must modernize regulations related to clearance and settlement.”
The full request from Templum can be viewed HERE.
Not the first request
It should be noted that Templum is not the first to request clarity from the SEC. In September, 12 members of Congress implored the SEC to do the same.
This particular request was the result of a meeting in Washington. The meeting involved not only politicians, but individuals from within both the world of crypto, and wall-street.
Might be in vain
Despite the murky waters in which blockchain resides, requests on behalf of the SEC may soon become a moot point.
Recently making headlines has been the push for the re-classification of digital assets on behalf of multiple Senators. This particular charge is led by Congressman, Warren Davidson, who hopes to develop a new set of rules, better suited for modern technology. A far cry from the securities definition created 72 years ago.
SEC – A Brick Wall
Months ago, SEC chairman, Jay Clayton, made it explicitly clear that they would not be changing to definition of securities. At the time, Clayton stated, “We are not going to do any violence to the traditional definition of a security that has worked for a long time…We’ve been doing this a long time, there’s no need to change the definition.”
The SEC has every right to take this stance. However, the requests for guidance from various entities indicates that the SEC has not clearly articulated themselves.
It is baffling that at this point the SEC has not released better clarification on how digital assets are governed.
Templum was founded in 2017, and is based out of New York City. Above all, Templum specializes in offering blockchain services tailored towards digital securities. This includes platforms for both secondary markets and initial fundraising efforts.
In a past interview with Forbes, Templum cofounder, Vincent Molinari, best described what it is that Templum does. He stated, “Templum is a fintech and blockchain holding company that is focused on the modernization of securities law that intersects with the most innovative technologies. Templum will continue to create new market infrastructure in clearance, settlement, custody and transfer of digital assets as securities to create standardization, best practice, and investor protection and will allow large pools of institutional capital to enter the digital frontier market.”
Dan Doney, CEO of Securrency – Interview Series
You have a very distinguished career having served in various roles with NSA, the Department of Homeland Security (DHS), the Defense Intelligence Agency (DIA), and the Federal Bureau of Investigation (FBI). How did you transition from working with some of the most respected intelligence agencies in the world, to launching Securrency?
I have been fortunate enough to work on some of the most advanced technology innovations with the best minds during my time at various intelligence agencies from the DIA to the FBI, providing the perfect springboard to launch Securrency. This gave me an insight into how fragmented the information transfer is between agencies and the inherent inefficiencies of centralized systems. My experience, combined with my passion for software development, and cybersecurity to artificial intelligence and dynamic asset pricing got me in front of some interesting individuals across real estate and finance who wanted to find technological solutions for widespread industry issues such as asset illiquidity. In search of a solution to these issues, I discovered blockchain technology and tokenization and recognized the huge impact it could have on financial services. Through the development of Securrency, it is our vision to transform the digital asset space using tokenization to deliver true market efficiencies.
You initially designed Securrency’s core identity server, credentialing (rules) engine, and interoperating rails in a hybrid architecture (linking on and off-chain functions). What made you choose this structure versus depending on a specific distributed ledger (blockchain) solution?
As Securrency’s market infrastructure technology is first and foremost designed to provide convenience and support to all market makers, it needed to encompass both legacy and blockchain functions to ensure the widespread participation and adoption of digital securities. Frankly, most STOs are bridges to nowhere. Without a built-out, integrated, and interoperable marketplace in which digital assets can move about, there isn’t enough back-end liquidity to make the exercise worthwhile for most issuers. We hope that this infrastructure will be transformational in the long run, but the near-term objectives are more incremental in nature. It is important to keep this in mind so we can move past the hype and toward the mature, professional adoption of these technologies.
WisdomTree Investments together with Abu Dhabi Investment Office (ADIO) and other investors invested in Securrency, as they aim to integrate blockchain technology into the exchange-traded fund (ETF) ecosystem. Could you share with us how Securrency’s technology will be integrated into ETF exchanges?
WisdomTree is a high-profile, highly-credible asset manager, and, as a strategic investor in Securrency, provides an incredible opportunity to deploy its technology into the ETF ecosystem. The bottom line is the market needs recognizable products that already enjoy substantial liquidity, so ETFs are a logical and exciting use case for our technology. Most of the ETF-related digital securities activity has been focused on cryptocurrency ETFs, and WisdomTree has been active in this space in Europe. ETFs will not only attract the large, household-name exchanges, transfer agents, and investment services providers, but will also make it easier and safer for a much broader base of investors to participate in these digital investment products.
On January 7th, Securrency announced the successful completion of a Series A raise for $17.65 Million. What are the plans for the raised funds?
Securrency plans to use its Series A funding to advance its software and platform development, integrate with strategic partners and other customers and, build out its operational structure. Thanks to the ongoing support of our strategic partners; the Abu Dhabi Investment Office, Monex Group, Inc,. RRE Ventures, Strawberry Creek Ventures, and Panthera Capital Investments, we can achieve our strategic vision and mission.
Could you tell us more about the Securrency RegManager™?
The Securrency RegManager encompasses both our Rules Engine interface and the patent-pending Compliance Aware Token framework. Our Rules Engine is a plain-language abstraction layer that allows companies and their lawyers to not only rapidly create policies but to be able to readily audit those policies and update them instantaneously. This level of convenience is essential for widespread adoption. The RegManager interface is fundamentally about providing multi-jurisdictional compliance tools and unprecedented convenience to financial services providers and market participants.
I was also interested in learning more about the Securrency InfinXchange™ and the benefits it offers?
InfinXchange is Securrency’s biggest technology IP. It’s an API library and finance ontology which maps various financial services to a set of basic functions, e.g. capital formation, payments, exchange routing, transfers, corporate actions, asset pricing, and compliant value transfer across DLT and legacy networks. It’s a plug-in framework made to be integrated with third-party service providers.
2019 was a bit slower of a year than we would have liked to see for the emergence of security tokens, do you believe that 2020 will be different?
We expect to see an acceleration in the tokenization of publicly traded assets in 2020. This, along with financial service providers partnering with emerging security token firms to tokenize institutional-grade assets will be a major trend in 2020. Tokenization platforms built by big tech firms like Microsoft and Facebook are also likely to emerge in 2020, coupled with digital asset issuances from highly trusted investment firms and asset managers.
What are some of the projects that Securrency is currently working on?
Our primary objective is to facilitate high-quality, yield-bearing token issuances as we unlock the accessibility which fuels mass global adoption of distributed ledger technology in financial services – the dream of blockchain enthusiasts for over a decade. This requires working closely with regulators, market participants, and intuitive user interfaces.
Darius Liu, Chief Operating Officer for iSTOX – Interview Series
What is iSTOX?
iSTOX is the first regulated capital markets platform in any major financial centre to support the one- stop issuance, custody and trading of digitized securities. Drawing on the power of advanced smart contract and distributed ledger technology to streamline the issuance and trading process, iSTOX seeks to redefine private capital markets by allowing investors and issuers to connect and transact directly. Compared with traditional trading venues, iSTOX is a more flexible, affordable and inclusive alternative, and offers investment options that were previously inaccessible.
iSTOX’s key shareholders include the Singapore Exchange (SGX), Asia’s leading international multi- asset exchange; Heliconia, a subsidiary of Temasek Holdings focused on investing in fast growing companies; and Phatra, a leading Thai investment and private bank and a member of Kiatnakin Phatra Financial Group. Other key shareholders include Japan-based Tokai Tokyo Financial Holdings (Tokai), a well-established Japanese financial services firm, and more recently Hanwha Asset Management, a leading asset management company in Korea.
Before iSTOX, you worked for GIC, which manages Singapore’s foreign reserves. How did this experience inspire you to launch iSTOX?
Actually, before I worked at GIC, I worked as a policymaker in the Singapore government, including a stint at the Ministry of Finance. Thus, my experience spans both policy making and asset management / investment within a commercial context. I can therefore relate to considerations from both sides of the fence (government and industry):
- On one end, the government wishes to promote industry transformation and innovation, while maintaining stability and protections for users.
- On the other hand, industry players see gaps in the market, and inefficiencies in current process In the case of capital markets, this takes the form of frictions arising from legacy processes involving multiple intermediaries. While technology exists to bridge the gap, the capital market space is a regulated arena – industry players often see regulation as an impediment to innovation.
Having experience in both spaces made me see that regulation is the friend – and not the enemy – of innovation. The innovation I’m talking about is innovation by serious, long-term players looking to add value to the economy as a whole. There is a gap in the market and working with regulation can add value. That led me to believe that iSTOX was an idea that was not only sound conceptually, but feasible from an execution standpoint.
The concept of digitized securities, as well as the whole capital market end-to-end infrastructure layer built on a blockchain is a new concept, both in terms of technology and operating model. The sandbox has been useful for iSTOX to start operating in a “live” environment with real issuers and investors, while simultaneously co-creating the regulatory environment together with MAS. This gave assurance to us, MAS and market participants that the iSTOX platform is stable and secure.
We are confident of transitioning out of the sandbox to serve a larger number of users. We expect to graduate from the MAS Fintech Regulatory Sandbox into full operational status soon this year.
Singapore has many existing gaps in the private capital markets that results in accredited investors being underserved by the current financial market. Could you share with us what these gaps are and how iSTOX solves this problem?
Investors today face a challenge. Low rates of return within the public markets continue to drive strong global demand for high-growth pre-IPO start-ups, exclusive hedge funds and other private market opportunities. In 2018, for example USD $778 billion worth of new capital flowed into private markets. In the case of private equity alone, net asset value grew more than sevenfold since 2002, doubling market cap growth of equities in the public market.*
Despite all this, the private capital market system itself has remained highly fragmented, inefficient, complicated and costly. For investors, this has resulted in limited access to a closed group of well- connected and privileged investors. And even for those that do have access to private capital markets, the antiquated and fragmented nature of the current system means they must go through multiple intermediaries to gain the investments they seek.
Fortunately, there is hope on the horizon. The rise of distributed ledger technology (DLT) and smart contracts, combined innovative business models and forward-looking regulation now make it possible to bring new kinds of capital markets platforms to investors.
In the case of iSTOX, this has resulted in the first regulated capital markets platform in any major financial centre to support the one-stop issuance, custody and trading of digitized securities. iSTOX seeks to redefine private capital markets by allowing investors and issuers to connect and transact directly under a safe, MAS-regulated environment. By coupling this with an innovative and accessible business model, iSTOX opens private markets opportunity to a broad range of accredited investors.
iSTOX enables investors to access previously inaccessible investments which includes exclusive funds. What are some of these funds and why should investors take note?
Most of us are familiar with the mutual fund offerings from banks. Many are products with fairly high upfront and ongoing fees. There are some funds which have a track record of positive returns across different market conditions. For instance, the top global macro and private equity funds.
Such funds are generally only open to large institutional investors like the biggest asset managers or sovereign wealth funds. They do not market even to high net worth individuals and have relatively small fund sizes (compared to many mutual funds) which makes their offering even more scarce.
Also, they tend to have long lock-up periods like 3 years or more. If investors want the returns offered by these funds, or the return streams to add to their portfolios for return enhancement or diversification, there is currently no way. But with iSTOX, it will be possible.
Alternative investment products will also be available to investors. What are some of these products?
We have also shortlisted some very exciting opportunities for the new year. These include a discretionary fund that builds returns through mezzanine deals and private debt financing, as well as a range of debt, fund and equity-linked issuances across a range of sectors (including real estate, entertainment, and lifestyle).
Where are user funds held?
Funds which you transfer into your iSTOX account reside in a customer segregated account held with DBS, Southeast Asia’s biggest bank. Your funds are interest-bearing, and you will have access to your funds through your online iSTOX Wallet. Digitized securities are minted if you make an investment and after funds have been debited from your iSTOX Wallet. These securities are custodized with
ICHX Tech Pte. Ltd., the operator of the iSTOX platform.
Investors who open an account with iSTOX before February 1st, 2020, receive certain exclusive benefits. Could you share with us what those perks are?
Select investors enjoy a certain number of guaranteed allocations in primary market issuances and waiver of fees associated with primary market subscription and secondary market purchases for a limited period of time.
Is there anything else that you would like to share about iSTOX?
I would like to share a bit about the iSTOX philosophy as well. Where we are now, what we do, it comes down to the belief to provide investors with greater accessibility, freedom and flexibility, with a desire to bring about improvements to the world.
We believe that all investors can and should have the capacity to build and manage their portfolios with the same freedom and flexibility now available to the very wealthy. In addition to generating good returns, investors should be able to freely engage with industries, technologies and causes that fire their passions, provide them exposure to potentially transformative developments in technology and society, and allow them to improve the world around them.
We believe that access to opportunities like high-growth pre-IPO start-ups, exclusive hedge funds and Asian unicorns can and should be open to far, far more investors. While technological limitations and other barriers previously locked out all but the very wealthy and well-connected, the new advances that are starting to make themselves felt in financial markets will fundamentally change this equation. We believe the financial industry should embrace these changes.
We believe that DLT and smart contract technology will open new worlds of possibilities when it comes to how investing works. These possibilities will include but will certainly not be limited to assets that can be traded and owned in fractions for greater liquidity and access, including real assets like buildings, aircraft, wind farms and more. Investors deserve access to these innovations as well as others.
Smartlands Hires London Strategic Consulting to Assess UK Market
This week, Smartlands, an institutional-grade tokenization platform announced the hiring of London Strategic Consulting. The firm seeks to utilize London Strategic Consulting’s market analysis to better position the company for the mainstream adoption of security tokens. The news demonstrates an increased pace of adoption for these regulatory compliant tokens within the UK market.
London Strategic Consulting (LSC)
London Strategic Consulting (LSC) is a non-profit consulting firm. Importantly, the organization is student-run. The choice to work with the LSC comes as part of London’s corporate social responsibility program expands. The LSC provides tracking and forecasting services to companies seeking deeper insight into their industries. As such, the LSC determined that tokenized securities are to be the next major trend in the blockchain sector.
Smartlands cooperated with the LSC to assess the digital securities space in the UK. The group is to provide Smartlands with a fresh perspective on how, and how soon, security tokens are to disrupt the UK financial sector. In turn, Smartlands will utilize this data to best determine its role in the digitization of the UK economy.
Security token adoption in the UK has been on the rise. The use of blockchain technology provides investors with more efficiencies, scalability, and transparency in the space. Most importantly, tokenization provides much-needed liquidity to the market.
Smartlands – Progress in Motion
Speaking on the partnership, Yaroslava Tkalich, Smartlands CMO called the work of the student body “marvelous.” She explained that it was necessary to focus the study on the UK markets first. This strategy allows Smartlands to tailor their plans to fit the nuances of the UK market directly. Tkalich also stated that after the UK, the firm would begin to expand its research to include global trends in the space. Specifically, Smartlands is interested in collective investment funds and other structured products currently under development.
For its part, the LSC is to identify any issues of mass adoption. These concerns are to focus on both issuers and investors in the blockchain sector. The LSC is to report any innovative new financing and capital raising models discovered and their impact on the current market trends. This data will help to build a bridge between legacy finance and the new digital economy.
The LSC report should provide Smartlands with the critical data needed to lay out a comprehensive approach towards the UK market moving forward. The firm intends to focus its development efforts on these key aspects. To date, the LSC pointed out that distribution, structuring, issuance, primary listing, secondary trading, custody, portfolio management, advisory, and market-making are the key areas requiring additional attention in the UK blockchain sector.
There is no doubt that Smartlands took the proper approach towards discovering the latest asset tokenization trends. In this manner, the firm can develop new marketing practices and business models to further its overall goal to be the dominant tokenization platform in the UK. Importantly, these plans fall in line with the company’s international expansion strategy. For now, Smartlands appears to be ready to make some major adjustments in an effort to remain the industry leader.