Examination Response #3
This June 16, 2025 letter answers detailed staff questions about control books and master securityholder files in Block Transfer's blockchain-based recordkeeping system. It explains how issuer instructions, outstanding balances, revocations, and investor records are represented across public-ledger and internal records.
Topics covered
- Authorized, issued, and outstanding share totals
- The public blockchain as a control-book record and the supporting issuer authorizations
- Revoked and newly issued holdings and reconciliation of capitalization records
- Construction and use of master securityholder files
- The proprietary book-entry system and its relationship to distributed-ledger data
- Claimable balances, pending holdings, certificate detail, and historical file comparisons