Blockchain Association Rebuts Citadel’s Tokenized Market Claims in SEC Submission

- The Blockchain Association told the SEC Citadel misapplies rules to tokenized markets.
- The filing says blockchain rails are not brokers, dealers, or exchanges by default.
- The group urged the SEC to use existing tools to support compliant tokenized finance.
The Blockchain Association has escalated its policy fight over tokenized finance with a new filing to the U.S. Securities and Exchange Commission. On April 6, 2026, the group said it submitted a response rebutting Citadel’s arguments against tokenized U.S. equity securities and decentralized finance trading protocols. The filing framed the dispute as a market structure question, not a rejection of securities law.
In its statement, the Blockchain Association said tokenized securities remain securities, but blockchain-based infrastructure should not be treated as a traditional intermediary by default. The group also tied the submission to its broader tokenization push, following CEO Summer Mersinger’s testimony last month and the launch of a tokenization workstream.
Filing Targets How Blockchain Rails Should Be Classified
According to the association, Citadel wants the SEC to regulate blockchain rails behind tokenized finance as if they were the same as conventional financial intermediaries. The group said that approach applies the wrong legal framework to technology designed to modernize asset ownership, transfer, and settlement.
The submission described tokenization as the representation of traditional financial assets on blockchain networks. It said that process allows ownership and transfer functions to operate on programmable rails rather than older financial plumbing. The comparison placed tokenization alongside the electronic trading shift of the 1990s.
In that framing, the filing argued that faster settlement, stronger transparency, and more resilient infrastructure are direct features of blockchain-based capital markets. It also said tokenization can improve the movement of assets and collateral across the financial system. The association added that the model could broaden access to investment opportunities for ordinary Americans.
Neutral Infrastructure at the Center of the Dispute
A central claim in the submission is that securities laws regulate intermediaries, not neutral infrastructure. The Blockchain Association said validators, autonomous smart contracts, non-custodial software, and related blockchain tools do not automatically become exchanges, brokers, or dealers because they support a transaction.
That argument directly challenges the idea that open blockchain systems should be regulated like centralized financial institutions. The filing said the legal question is not whether tokenized assets fall under securities law.
Instead, it focuses on whether the technical rails behind a Tokenized Market should inherit the same regulatory treatment as legacy market actors. Summer Mersinger, the group’s chief executive, said the filing reflects a wider Washington push around tokenization policy.
In her statement, she said the goal is to support a market evolution that makes U.S. finance more efficient, resilient, and globally competitive. The association presented that view as a policy case for updating market structure around technology.
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SEC Tools and the Broader DeFi Fight
The filing said the SEC already has tools available to support responsible progress in tokenized finance. It specifically pointed to exemptive relief and iterative regulatory pathways, which the Commission has historically used when new market structure technologies emerge.
The group said those tools could help regulators manage change without forcing existing categories onto new systems. The new submission also revives a parallel debate around DeFi regulation. The text said that the fight intensified after Uniswap founder Hayden Adams accused Citadel of pushing the SEC toward classifying DeFi developers as broker-dealers.
That accusation sharpened concerns that decentralized systems could be regulated as though they were centralized firms. The filing closes with a broader competitiveness argument. It says the United States now faces a policy choice over where the next generation of market infrastructure will be built. In that account, the Tokenized Market debate is no longer only about compliance but also about whether modern capital market development remains onshore.



