SEC Transfer Agent Registration

Vertalo, Inc. is registered with the U.S. Securities and Exchange Commission as a Transfer Agent under Section 17A of the Securities Exchange Act of 1934. This registration is not incidental — it is the foundation on which our entire platform is built.

As a registered Transfer Agent, Vertalo operates under the SEC's comprehensive regulatory oversight framework, including:

• Annual reporting and recordkeeping requirements under SEC Rules 17Ad-6 and 17Ad-7
• Operational standards for accuracy, turnaround times, and safeguarding of investor records
• Ongoing compliance with the SEC's Transfer Agent rules governing turnaround times, lost securityholder searches, and investor communications
• Subject to examination by SEC staff

This framework provides our clients — issuers of tokenized securities — with the regulatory certainty that their investor records are maintained by a supervised, accountable fiduciary.

Regulatory Examinations

As an SEC-registered Transfer Agent, Vertalo is subject to periodic regulatory examinations conducted by the SEC's Office of Compliance Inspections and Examinations (now the Division of Examinations). These examinations review our operational controls, recordkeeping systems, compliance programs, and investor protection practices.

Vertalo maintains a robust compliance program, including written supervisory procedures, audit trails, and documented policies aligned with SEC examination expectations. We view regulatory engagement as a mark of credibility — not a burden.

The 5 SEC Tokenization Models

On January 28, 2026, the SEC staff issued a significant statement outlining five recognized models for the tokenization of securities. Vertalo's platform is designed to support all five models, giving issuers maximum flexibility in how they structure and operate tokenized securities offerings.

Vertalo's multi-model support positions our clients to structure transactions under the framework most appropriate for their offering — while maintaining full regulatory compliance throughout.

Leadership Signals from the SEC

The regulatory environment for tokenized securities has evolved significantly. Key signals from SEC leadership reinforce the direction Vertalo has been building toward for years:

Commissioner Mark Uyeda

Chairman Paul Atkins — ETHDenver 2026

These signals validate what Vertalo has built: a Transfer Agent infrastructure designed specifically for the tokenized securities era, operating within — not around — the existing regulatory framework.

Global Data Compliance: GDPR & CCPA

Vertalo's platform and data practices are designed to comply with major global privacy frameworks:

• GDPR (EU/UK): We process personal data of EU and UK individuals in accordance with the General Data Protection Regulation, including lawful bases for processing, data subject rights, and data processing agreements with sub-processors.
• CCPA (California): California residents have the right to know, access, and request deletion of personal information Vertalo holds about them, subject to regulatory retention obligations.

Our Privacy Policy provides a full description of our data practices and your rights under applicable law.

Multi-Jurisdiction Operations

Vertalo supports issuers and investors operating across multiple jurisdictions. Our platform is designed to accommodate the regulatory nuances of each market:

Whether navigating SEC requirements in the US, FCA guidelines in the UK, MiFID II considerations in the EU, or JFSA frameworks in Japan, Vertalo's infrastructure provides the flexibility to manage cross-border investor records while maintaining jurisdiction-specific compliance controls.