The SEC clears the way for blockchain-based fund custody
The U.S. Securities and Exchange Commission (SEC) issued a no-objection letter allowing registered funds owned by Franklin Templeton to invest in its Franklin Chain U.S. Government Monetary Fund (commonly known as BENJI).
SEC staff said they would not recommend enforcement action in relation to the Franklin Templeton Fund's proposed custody arrangement involving U.S. government money fund shares on the Franklin Chain.
This decision allows Franklin Templeton Investor Services (FTIS) to act as custodian of participating funds without having to comply with certain requirements for the design of physical or certificate-based securities in Rule 17f-2.
In effect, this removes significant regulatory obstacles previously faced when holding blockchain-based fund shares within traditional fund structures.
The on-chain fund is a registered government money market fund with official shareholder records maintained through a system that combines traditional internal records with blockchain technology.
Some blockchain records include transaction data such as subscriptions, redemptions, dividend distributions, net asset value and transaction information, while FTIS controls official ownership records.
BENJI, Stellar Network and Existing Safeguards
BENJI is an on-chain share token of the Franklin Chain U.S. Government Monetary Fund (FOBXX), a U.S. registered mutual fund managed by Franklin Templeton.
Each BENJI token represents a share of the fund, which invests in U.S. Treasury bonds, repurchase agreements and cash. The fund's goal is to maintain a stable price of $1 per share.
The chain fund currently mainly uses Stellar as its public blockchain, but the SEC letter states that other networks can also be used for specific accounts that qualify.
For each participating fund, FTIS will create a separate blockchain wallet and retain control of the relevant private key.
This exemption comes with important conditions. Each participating fund must have procedures in place to prevent unauthorized orders;FTIS must maintain management controls that allow it to correct unauthorized transactions, freeze or migrate wallet records, and restore official ownership records if necessary. Each fund's board of directors must approve these arrangements and review them at least annually.
Franklin Templeton pointed out in his filing that the reason for adopting this structure is that on-chain funds have the characteristics of calculating net asset value per hour, supporting intra-day trading, and faster transaction processing.
As of the first quarter of 2026, the fund managed approximately US$828 million in assets and ran on eight public blockchains: Stellar Network, Polygon, Arbitrum, Aptos, Avalanche, Base, Solana and Ethereum. The fund is the first registered fund in the United States to use a public blockchain to process transactions and record share ownership.
The SEC letter released Wednesday consolidates that position and may open the door for other asset managers to seek similar structures.

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