How to become a TSV.

The launch checklist

1. Stand up the US-person operator entity

   Formation-based test: organized under US law. Foreign ownership is fine. Run statutory-disqualification screens across the group now, not later — and decide the affiliation map (operator, tokenizer, front-ends) with counsel, because caps aggregate across affiliates.

2. Define admission standards and the rulebook

   The venue sets its own participant standards: identification tiers, sanctions screening, attestations. Encode them as configuration — admission tier, symbol scope, per-symbol caps, halt policy, fee schedule — reviewed like code, release-gated, attributable.

3. Deploy the venue stack

   Permissioned AMM pools, the compliance choke point, the operator services (admission authority, cap monitor, halt-sync, notice workflow, records, reporting). Contracts must be public and auditable at published addresses. Build in-house or license — the checklist is the same either way.

4. Connect the feeds

   Two inputs matter: a halt feed from the primary exchange (real-time, with resumption) and prior-month consolidated volume per symbol for the ADV caps. Both are available from official sources. Design for feed loss: fail closed, alert, resume.

5. Select instruments and supply

   Prefer low parity burden first: no-dividend single-class commons, broad index ETPs, spot-commodity ETPs. For each symbol, decide issuer-tokenized (no notice) vs. third-party tokenization (notice required) — and verify rights parity per the order's criteria as part of listing admission.

6. Draft and publish the notices

   Public website notice at least 30 days before operating — including the fee schedule — and written notice to the SEC within one business day. The notice site is a legal instrument: version it, timestamp it, keep it live.

7. Fire issuer notices and run the clocks

   Written notice to each issuer whose stock a third party tokenizes; trading waits until 30 days after receipt; honor objections. Each symbol carries a workflow object — sent, received, clock running, clear or objected.

8. Turn on records and reporting from day one

   Hash-chained books and records (onchain records qualify) and USD-denominated 24-hour volume reporting. If every action emits a versioned event from one place, reporting is a downstream consumer — not a month-end scramble.

9. Go live — and operate inside the lines

   Monitor per-symbol volume against caps continuously (a breach is an immediate multi-month pause in that symbol, affiliates included). Synchronize halts with the primary market in real time. Log screening evidence. The exemption is conditional forever, not just at filing.

Engineering requirements, condition by condition

The timeline reality

The regulatory floor is the notice clock: 30 days of public notice, SEC written notice within one business day. But the practical path is set by engineering readiness and issuer-notice clocks. A team with entity, counsel, rulebook and licensed software can file and be live just past the notice window. A team building venue software from scratch is looking at a multi-year specialist program — protocol engineering, cap math with regulatory consequences, halt infrastructure, records — before the notice even matters.

Build vs. buy

What's genuinely bespoke: your authorization strategy, your issuer relationships, your participants, your markets. What's not: pool math, admission gates, cap monitors, halt oracles, notice workflows, event schemas. That second list is where teams spend years rediscovering edge cases that are already encoded — in requirements, in tests, and in configuration — in venue software that exists today. The rational move for most entrants is to buy the second list and pour their scarce specialists into the first.

Frequently asked questions