The SEC's September 17 order creating a path for Tokenized Securities Venues (TSVs) answers a long-standing question: can exchange operators trade tokenized NMS stocks without registering as a national securities exchange? The order says yes, but only within a tightly conditioned framework. For teams evaluating whether to build a TSV, the design questions start where the legal ones end.

‍

For teams investigating and building against this opportunity, Stork Research has assembled a two-page brief that calls out the points where data design decisions can do the most to reduce compliance risk. You can read it here.

‍

How do TSV transaction data feed requirements actually work? The order requires machine-readable, dollar-denominated trade data covering a rolling 30-day window, refreshed within 10 minutes of each transaction. It also requires reporting on each AMM liquidity pool's daily share volume and end-of-day size. What counts as machine-readable? What happens when a pool spans multiple chains? These are engineering questions as much as compliance ones.

‍

What do TSV public notice disclosure requirements demand, and where do they overlap with recordkeeping? Every notice a TSV publishes, from the initial public Notice through any later revision, also has to show up in its books and records, retrievable in machine-readable form.

‍

Volume cap may be the most sensitive data dependency in the SEC's TSV Innovation Exemption requirements. Tier 1 stocks are capped at 0.25 percent of the underlying security's average daily volume, Tier 2 at 2.5 percent, with penalties escalating to a three-month trading suspension. Calculating that threshold accurately has implications not only for compliance risk, but for operations, user experience, and growth.

‍

The order also requires TSVs to halt trading whenever the underlying NMS stock halts on its primary exchange, whether from a circuit breaker, pending news, or an SEC suspension. Market status endpoints needs vary by exchange and must be designed with these requirements in mind.

‍

Finally, what does TSV books-and-records compliance look like in practice? The order lists eight categories of records a TSV must keep and produce for inspection, in both human-readable and machine-readable form. The right design can include onchain records, offchain systems, or some blend of the two.

‍

Our TSV data infrastructure risk points brief walks through where these requirements create the highest operational stakes. Click to read, or get in touch with the team at stork.network/contact.