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Tokenized Equities Need an ADR Structure to Protect Investors

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Tokenization has significant potential to transform capital markets, promising real-time settlement, broader investor access and greater programmability across financial infrastructure. But while the rails are evolving, current models for tokenized equities remain fragmented, opaque and misaligned with the safeguards that define the traditional securities markets.

Today, two dominant approaches exist:

The wrapper model involves tokenized IOUs that provide synthetic exposure to existing equities rather than direct ownership. These tokens do not grant holders any governance rights or enforceable claims to the underlying shares. Transferability is typically restricted to closed ecosystems, liquidity is siloed across issuer-controlled platforms and regulation can be murky, with many products not available to U.S. persons.

The on-chain issuance model means creating a native digital share class issued via blockchain. While this approach aligns more closely with the legal definition of security, it introduces operational complexities and scalability challenges. Active issuer participation is mandatory, liquidity remains fragmented between the on-chain tokens and traditional securities and broker-dealer standards are inconsistent, complicating participation for regulated financial institutions and investors.

What’s missing is a tokenization model that combines the speed, accessibility and composability of tokenization with the structure, safeguards and clarity of traditional capital markets. Fortunately, that model already exists elsewhere: depository receipts (DRs).

In many ways, DRs were the original form of tokenization. For over a century, American depository receipts (ADRs) have enabled foreign equities to trade in the U.S. through a regulated, custody-backed structure. Today, this framework can also bridge traditional securities with tokenized infrastructure, offering a scalable and legally sound foundation for modern equities.

The case for tokenized DRs

By combining blockchain rails with the legal and operational framework of DRs, market participants can unlock broader participation and real-time asset servicing without compromising on investor protections or operational standards.

Other benefits include:

  • Preservation of shareholder rights

Unlike synthetic wrappers, the ADR structure perfects shareholder rights, enabling them to be passed along to token holders. This includes economic entities, such as dividends and other corporate actions, as well as governance rights such as voting.

  • Clear segregation of duties

A regulated custodian bank safekeeps the underlying shares in a segregated, bankruptcy-remote structure, held solely for the benefit of ADR holders. An independent, market-neutral depositary facilitates DR issuances and cancellations, maintains accurate records using an SEC-registered transfer agent and performs daily reconciliation with the underlying assets. The depositary has no ownership claim on the underlying shares themselves.

  • Regulatory precedent

ADRs are recognized as securities under U.S. law. For years, they have been used to allow U.S. investors to own and trade foreign shares in the U.S. markets. Furthermore, the receipt structure has been flexible to enable fractionalization of U.S. preferred shares. With regards to tokenized securities, Commissioner Hester Peirce in her latest statement on tokenization mentioned that “a token could be a receipt for a security.”

  • Full fungibility and market access

ADRs are fully fungible and redeemable for their underlying shares, enabling same-day, non-taxable conversions. They can be made available to both retail and institutional market participants who can choose to hold securities in tokenized or traditional form without sacrificing rights or liquidity. The fungibility of ADRs is supported by analysis from MSCI, which indicates that, on average, ADRs trade at parity with their underlying local shares.

Price divergence for ADRs chart

  • Scalability

ADRs can be deployed by both stock issuers and secondary market participants, enhancing scalability and adoption — unlike on-chain issuance models reliant on issuer initiation and active maintenance.

A trusted mechanism for bridging markets

Proven and fully integrated into global finance, applying the ADR structure to tokenized equities is a logical evolution.

As tokenization matures, this kind of innovation is critical to scaling adoption and trust. Just as SEC Rule 12g3-2(b) streamlined access to foreign issuers, a similar regulatory mechanism could unlock broader tokenized equity markets, enabling public companies to offer tokenized shares to U.S. investors in a compliant manner.

The path forward doesn’t require inventing a new wrapper — it requires adapting a proven one. In other words, the bridge between traditional finance and digital infrastructure already exists. It just needs to be thoughtfully crossed.

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Asia Morning Briefing: Native Markets Wins Right to Issue USDH After Validator Vote

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Good Morning, Asia. Here’s what’s making news in the markets:

Welcome to Asia Morning Briefing, a daily summary of top stories during U.S. hours and an overview of market moves and analysis. For a detailed overview of U.S. markets, see CoinDesk’s Crypto Daybook Americas.

Hyperliquid’s validator community has chosen Native Markets to issue USDH, ending a weeklong contest that drew proposals from Paxos, Frax, Sky (ex-MakerDAO), Agora, and others.

Native Markets, co-founded by former Uniswap Labs president MC Lader, researcher Anish Agnihotri, and early Hyperliquid backer Max Fiege, said it will begin rolling out USDH “within days,” according to a post by Fiege on X.

According to onchain trackers, Native Markets’ proposal took approximately 70% of validators’ votes, while Paxos took 20%, and Ethena came in at 3.2%.

The staged launch starts with capped mints and redemptions, followed by a USDH/USDC spot pair before caps are lifted.

USDH is designed to challenge Circle’s USDC, which currently dominates Hyperliquid with nearly $6 billion in deposits, or about 7.5% of its supply. USDC and other stablecoins will remain supported if they meet liquidity and HYPE staking requirements.

Most rival bidders had promised to channel stablecoin yields back to the ecosystem with Paxos via HYPE buybacks, Frax through direct user yield, and Sky with a 4.85% savings rate plus a $25 million “Genesis Star” project.

Native Markets’ pitch instead stressed credibility, trading experience, and validator alignment.

Market Movement

BTC: BTC has recently reclaimed the $115,000 level, helped by inflows into ETFs, easing U.S. inflation data, and growing expectations for interest rate cuts. Also, technical momentum is picking up, though resistance sits around $116,000, according to CoinDesk’s market insights bot.

ETH: ETH is trading above $4600. The price is being buoyed by strong ETF inflows.

Gold: Gold continues to trade near record highs as traders eye dollar weakness on expected Fed rate cuts.

Elsewhere in Crypto:

  • Pakistan’s crypto regulator invites crypto firms to get licensed, serve 40 million local users (The Block)
  • Inside the IRS’s Expanding Surveillance of Crypto Investors (Decrypt)
  • Massachusetts State Attorney General Alleges Kalshi Violating Sports Gambling Laws (CoinDesk)
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BitMEX Co-Founder Arthur Hayes Sees Money Printing Extending Crypto Cycle Well Into 2026

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Arthur Hayes believes the current crypto bull market has further to run, supported by global monetary trends he sees as only in their early stages.

Speaking in a recent interview with Kyle Chassé, a longtime bitcoin and Web3 entrepreneur, the BitMEX co-founder and current Maelstrom CIO argued that governments around the world are far from finished with aggressive monetary expansion.

He pointed to U.S. politics in particular, saying that President Donald Trump’s second term has not yet fully unleashed the spending programs that could arrive from mid-2026 onward. Hayes suggested that if expectations for money printing become extreme, he may consider taking partial profits, but for now he sees investors underestimating the scale of liquidity that could flow into equities and crypto.

Hayes tied his outlook to broader geopolitical shifts, including what he described as the erosion of a unipolar world order. In his view, such periods of instability tend to push policymakers toward fiscal stimulus and central bank easing as tools to keep citizens and markets calm.

He also raised the possibility of strains within Europe — even hinting that a French default could destabilize the euro — as another factor likely to accelerate global printing presses. While he acknowledged these policies eventually risk ending badly, he argued that the blow-off top of the cycle is still ahead.

Turning to bitcoin, Hayes pushed back on concerns that the asset has stalled after reaching a record $124,000 in mid-August.

He contrasted its performance with other asset classes, noting that while U.S. stocks are higher in dollar terms, they have not fully recovered relative to gold since the 2008 financial crisis. Hayes pointed out that real estate also lags when measured against gold, and only a handful of U.S. technology giants have consistently outperformed.

When measured against bitcoin, however, he believes all traditional benchmarks appear weak.

Hayes’ message was that bitcoin’s dominance becomes even clearer once assets are viewed through the lens of currency debasement.

For those frustrated that bitcoin is not posting fresh highs every week, Hayes suggested that expectations are misplaced.

In his telling, investors from the traditional world and those in crypto actually share the same premise: governments and central banks will print money whenever growth falters. Hayes says traditional finance tends to express this view by buying bonds on leverage, while crypto investors hold bitcoin as the “faster horse.”

His conclusion is that patience is essential. Hayes argued that the real edge of holding bitcoin comes from years of compounding outperformance rather than short-term speculation.

Coupled with what he sees as an inevitable wave of money creation through the rest of the decade, he believes the present crypto cycle could stretch well into 2026, far from exhausted.

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Bitcoin Bulls Bet on Fed Rate Cuts To Drive Bond Yields Lower, But There’s a Catch

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On Sept. 17, the U.S. Federal Reserve (Fed) is widely expected to cut interest rates by 25 basis points, lowering the benchmark range to 4.00%-4.25%. This move will likely be followed by more easing in the coming months, taking the rates down to around 3% within the next 12 months. The fed funds futures market is discounting a drop in the fed funds rate to less than 3% by the end of 2026.

Bitcoin (BTC) bulls are optimistic that the anticipated easing will push Treasury yields sharply lower, thereby encouraging increased risk-taking across both the economy and financial markets. However, the dynamics are more complex and could lead to outcomes that differ significantly from what is anticipated.

While the expected Fed rate cuts could weigh on the two-year Treasury yield, those at the long end of the curve may remain elevated due to fiscal concerns and sticky inflation.

Debt supply

The U.S. government is expected to increase the issuance of Treasury bills (short-term instruments) and eventually longer-duration Treasury notes to finance the Trump administration’s recently approved package of extended tax cuts and increased defense spending. According to the Congressional Budget Office, these policies are likely to add over $2.4 trillion to primary deficits over ten years, while Increasing debt by nearly $3 trillion, or roughly $5 trillion if made permanent.

The increased supply of debt will likely weigh on bond prices and lift yields. (bond prices and yields move in the opposite direction).

«The U.S. Treasury’s eventual move to issue more notes and bonds will pressure longer-term yields higher,» analysts at T. Rowe Price, a global investment management firm, said in a recent report.

Fiscal concerns have already permeated the longer-duration Treasury notes, where investors are demanding higher yields to lend money to the government for 10 years or more, known as the term premium.

The ongoing steepening of the yield curve – which is reflected in the widening spread between 10- and 2-year yields, as well as 30- and 5-year yields and driven primarily by the relative resilience of long-term rates – also signals increasing concerns about fiscal policy.

Kathy Jones, managing director and chief income strategist at the Schwab Center for Financial Research, voiced a similar opinion this month, noting that «investors are demanding a higher yield for long-term Treasuries to compensate for the risk of inflation and/or depreciation of the dollar as a consequence of high debt levels.»

These concerns could keep long-term bond yields from falling much, Jones added.

Stubborn inflation

Since the Fed began cutting rates last September, the U.S. labor market has shown signs of significant weakening, bolstering expectations for a quicker pace of Fed rate cuts and a decline in Treasury yields. However, inflation has recently edged higher, complicating that outlook.

When the Fed cut rates in September last year, the year-on-year inflation rate was 2.4%. Last month, it stood at 2.9%, the highest since January’s 3% reading. In other words, inflation has regained momentum, weakening the case for faster Fed rate cuts and a drop in Treasury yields.

Easing priced in?

Yields have already come under pressure, likely reflecting the market’s anticipation of Federal Reserve rate cuts.

The 10-year yield slipped to 4% last week, hitting the lowest since April 8, according to data source TradingView. The benchmark yield has dropped over 60 basis points from its May high of 4.62%.

According to Padhraic Garvey, CFA, regional head of research, Americas at ING, the drop to 4% is likely an overshoot to the downside.

«We can see the 10yr Treasury yield targeting still lower as an attack on 4% is successful. But that’s likely an overshoot to the downside. Higher inflation prints in the coming months will likely cause long-end yields some issues, requiring a significant adjustment,» Garvey said in a note to clients last week.

Perhaps rate cuts have been priced in, and yields could bounce back hard following the Sept. 17 move, in a repeat of the 2024 pattern. The dollar index suggests the same, as noted early this week.

Lesson from 2024

The 10-year yield fell by over 100 basis points to 3.60% in roughly five months leading up to the September 2024 rate cut.

The central bank delivered additional rate cuts in November and December. Yet, the 10-year yield bottomed out with the September move and rose to 4.57% by year-end, eventually reaching a high of 4.80% in January of this year.

According to ING, the upswing in yields following the easing was driven by economic resilience, sticky inflation, and fiscal concerns.

As of today, while the economy has weakened, inflation and fiscal concerns have worsened as discussed earlier, which means the 2024 pattern could repeat itself.

What it means for BTC?

While BTC rallied from $70,000 to over $100,000 between October and December 2024 despite rising long-term yields, this surge was primarily fueled by optimism around pro-crypto regulatory policies under President Trump and growing corporate adoption of BTC and other tokens.

However, these supporting narratives have significantly weakened looking back a year later. Consequently, the possibility of a potential hardening of yields in the coming months weighing over bitcoin cannot be dismissed.

Read: Here Are the 3 Things That Could Spoil Bitcoin’s Rally Towards $120K

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