Examination #1
These public documents are responses from BlockTransfer's first examination, conducted in 2025 by the U.S. Securities and Exchange Commission's New York Regional Office.
The series documents BlockTransfer's responses to successive staff requests concerning its transfer-agent operations and blockchain-based recordkeeping system. The final response addresses findings from the examination. Certain third-party details in the public copies have been redacted.
Scope of the collection
These pages summarize the public responses rather than the nonpublic exhibits and supplements referenced within them. The summaries are navigational aids; the embedded PDFs remain the primary records.
Responses
Response #1
Public: Initial document request, organization, regulatory records, policies, and controls.
Response #2
Redacted: Lost-securityholder searches, issuer records, onboarding, identity verification, and AML controls.
Response #3
Public: Control books, master securityholder files, issuances, revocations, and distributed-ledger records.
Response #4
Redacted: Transaction evidence, account records, combined transactions, and public-ledger privacy.
Response #5
Public: Asset-holder records, distribution accounts, payment history, and restricted balances.
Response #6
Public: Authorized-share controls, issue dates, investor records, and revocation or reissuance documentation.
Response #7
Redacted: Principal-office records, issuance-date maintenance, and public-information practices.
Response #8
Public: Response to examination findings and proposed operational remediation.