Notes on the DTCC NAL: The Mechanics of Tokenized Entitlements The clean way to think about U.S. stocks "ownership" is that it’s a stack of records, not a single ledger. At the top, the issuer/transfer agent register is the legal register of record; for most DTC-custodied float it shows Cede & Co as the registered owner. Below that, DTC maintains participant positions as book-entry credits in each participant "Account." If a participant is holding for a customer, the customer’s interest is recorded on the participant’s own books. The legal model that makes this work is UCC Article 8: DTC is the securities intermediary, participants are entitlement holders, and what moves economically is a security entitlement in the indirect holding system. DTCC’s tokenization program does not change the issuer register. It tokenizes the participant-level entitlement layer, creating a new on-chain representation of a DTC-held security entitlement, not a newly issued security. Here is the step-by-step flow described in the no-action letter: 1. A participant registers one or more blockchain addresses with DTC as Registered Wallets. 2. The participant submits a Tokenization Instruction for eligible “Subject Securities” already credited to its DTC Account. 3. If accepted, DTC debits the securities from the participant’s Account and credits them to a Digital Omnibus Account on DTC’s centralized ledger. 4. DTC then uses Factory to mint and deliver a token to the participant’s Registered Wallet representing the participant’s security entitlement to those immobilized securities. 5. Tokens can be transferred between Registered Wallets without instructing DTC to process a book-entry delivery; LedgerScan tracks token movements and its record constitutes DTC’s official books and records for tokenized entitlements. To unwind, the participant de-tokenizes: The token is burned, the position is debited from the Digital Omnibus Account, and credited back to the participant’s DTC Account. Two boundary conditions define how this fits into today’s stack. ...