Article
A New Regulatory Framework For Transfer Agents: An Analysis Of The SEC’s Modernization Proposal And Industry Implications
The SEC has proposed the most comprehensive modernization of transfer agent rules since their original adoption in the 1970s, replacing paper-era requirements with technology-neutral standards covering cybersecurity, operational resilience, faster processing, and blockchain integration. The proposal would eliminate longstanding exemptions for mutual funds and small transfer agents while establishing new compliance governance requirements and restrictive legend controls that would reshape how transfer agents
Greenberg Traurig, LLP
