SEC CRYPTO TASK FORCE OTCM PROTOCOL PUBLICATION JAN. 3, 2026

https://www.sec.gov/files/ctf-written-input-otcm-protocol-010326.pdf

OTCM Protocol ("OTCM") is a financial technology platform focused on tokenizing illiquid over-the-counter securities. We write to endorse the growth of tokenization as an essential innovation for American capital markets, and to respectfully submit our perspective on how the Commission can advance securities tokenization while strengthening investor protection.

OTCM addresses one of American finance's most pressing yet overlooked problems: the systematic abandonment of over 11,000 companies trading on over-the-counter markets, trapping an estimated $50+ billion in shareholder value. Through innovative blockchain technology and the Howey Shield framework—structuring ST22 tokens as community-driven meme tokens consistent with the SEC's February 2025 guidance—OTCM demonstrates how crypto innovation can revitalize failing traditional financial infrastructure while enhancing rather than circumventing investor protections.

The purpose of this submission is to describe the unique market failure OTCM addresses, to explain our regulatory-compliant tokenization model, and to offer our expertise in support of the Commission's efforts to develop clear guidance for tokenized securities. As explained in our attached Roadmap for Tokenized Securities: