If there’s a common theme I’m hearing out here at the Northwestern Pritzker School of Law Securities Regulation Institute, it’s to “think big” about modernizing the public company experience. That includes the infrastructure for trading and voting. If you’ve been ignoring the digital revolution, now’s a good time to start paying attention.

There’s strong sentiment that blockchain will completely change the game – for example, we could see instantaneous trade settlement and peer-to-peer trading. It could also resolve longstanding “proxy plumbing” issues that make it hard to know who owns and votes stock – and make it much easier for retail investors to vote.

I’ll concede that we’ve been talking about this since at least 2016 – including Nasdaq’s practice run for blockchain voting in Estonia! But at this point it seems much closer to becoming reality.

As one sign that things are moving along, the SEC posted notice yesterday for a revised version of a proposal that Nasdaq initially submitted back in September. Here’s an excerpt:

The Exchange proposes to amend the Exchange’s rules to enable the trading of securities on the Exchange in tokenized form during the pendency of a pilot program to be operated by the Depository Trust Company (“DTC”) pursuant to the terms of a December 11, 2025 Commission No-Action Letter. Specifically, proposed rules Equity 1, Section 1 and Equity 4, Rules 4756, 4757, and 4758 will clarify how Nasdaq trades tokenized securities under this pilot program. This Amendment No. 2 supersedes the original filing, as amended by Amendment No. 1, in its entirety.

And:

The purpose of the proposed rule change is to establish clearly that Nasdaq’s member firms and investors that are eligible to participate in the DTC tokenization pilot program (“DTC Eligible Participants”) may trade tokenized versions of those equity securities and exchange traded products (“ETPs”) on the Exchange that are eligible for tokenization as part of the DTC tokenization pilot program (“DTC Eligible Securities”), pursuant to the terms of the No Action Letter. The filing describes and applies to one method by which DTC Eligible Securities can trade on Nasdaq within the current national market system, using DTC to clear and settle trades in token form, per order handing instructions that DTC Eligible Participants may select upon entering their orders for DTC Eligible Securities on Nasdaq.

Meredith recently blogged about how the DTC pilot works. And it’s not just Nasdaq and DTC that are investing in tokenization – several other recent developments suggest it’s a priority for a number of big market players, and that companies are starting to jump in too:

– Remarks from Larry Fink and SEC Chair Paul Atkins

– NYSE’s proposal to enable tokenized trading

– Authorized blockchain common stock in a corporate charter

– Registration statement to offer blockchain common stock

– Commentary on issues to work through

At this point, tokenization isn’t just “for the kids” – securities lawyers will need to understand it too. Whether that’s the death knell for it being edgy and cool, I can’t say – but blogging about “the blockchain”* does make me feel a lot like Colin Jost learning Gen Z slang. No cap.

– Liz Dunshee

*It’s just “blockchain” now. “The blockchain” is very 2019.