We submitted a no-action request to the SEC related to Ondo Global Markets. The request is narrow. It does not ask the SEC to rewrite securities law or approve every form of tokenized security. It asks for confirmation that SEC staff would not recommend enforcement action if we proceed with a specific model for recording and administering certain securities entitlements in tokenized form on Ethereum Mainnet in support of OGM products.
The reason for the filing is practical. We think this structure can make OGM products more useful without changing the basic legal framework that supports them. Under the model described in the request, OGM products would remain what they are today: tokenized notes that provide non-U.S. investors with exposure to U.S.-listed stocks and ETFs. The underlying securities would remain inside the existing legal, custody, and recordkeeping framework, and the official books and records would remain there as well. What changes is that, in a limited set of circumstances, the relevant securities entitlements would also be represented in tokenized form on Ethereum Mainnet and held by our custodian BitGo to support recordkeeping and operational processes.
We believe the addition of that tokenized feature can help Ondo and ultimately investors in OGM products in straightforward ways: cleaner collateral monitoring, more efficient creation-and-redemption workflows, and simpler reconciliation for the OGM product stack. In other words, the goal is to improve the operational side of an existing product, not to replace the existing system with something entirely new.
That may sound technical, but the purpose is substantive. We believe the changes we describe can meaningfully improve the operational foundations of an existing market-leading product without changing its core features. That is why we have defined our approach in a demonstrably careful way. In a structure like this, where numerous established market participants are involved, getting clarity up front matters. Even when the legal case is clear and strong, as is true here, a submission like ours can be the right step before moving ahead with a new operating model inside the existing system.
That is why we consider the request to represent continuity as much as change. The filing is based on the view that a targeted onchain layer can work alongside the current framework if the underlying protections remain in place and the official record does not move. The request is meant to function as a recordkeeping innovation, not a rewrite of market structure.
Ethereum Mainnet is part of that story, but it is not the whole story. We are using it because OGM already operates in Ethereum and Ethereum-compatible environments, so using the same rail reduces friction and keeps the broader system coherent. More broadly, we think public blockchain infrastructure can be useful in regulated markets when paired with the right controls.
An SEC staff no-action position does not create a new rule. What it can do is create room for a specific, bounded model to move forward without waiting for a longer rulemaking process. That is what we are asking for here: room to make a practical product improvement in a narrow and supervised way. The full no-action letter request and a related explainer are linked below.
Source: Ondo
