Franklin Sets a Regulatory Precedent for Tokenized Funds
A no-action letter lets Franklin's mutual funds and ETFs park cash in its $726 million tokenized money market fund, and sets the first template for blockchain-based fund ownership under the 1940 Act.
Louis Tellier
August 20, 2026
Opening BENJI to fund cash: On August 12, the SEC issued a no-action letter covering Franklin Templeton’s own registered funds. Its mutual funds and ETFs can now place excess cash and securities-lending collateral in Franklin Templeton’s tokenized money market fund FOBXX. Represented by the BENJI token, the fund currently holds roughly $726 million, placing it among the ten largest in its category.
Why it matters: Tokenized money market funds have so far grown mainly on crypto-native balance sheets, serving traders, crypto corporations, and stablecoin issuers for collateral and treasury management use cases. The letter opens a different pool: cash sitting inside traditional mutual funds and ETFs, which FOBXX’s hourly NAVs and intraday trading could over time make more productive.
Industry’s first: It also sets a precedent beyond Franklin, as the first staff-level template for treating a blockchain-based ownership record as legitimate under the Investment Company Act of 1940.
One of few onshore: That second point matters because of where FOBXX sits. Most large tokenized money market funds are set up offshore or outside the registered-fund regime. FOBXX is one of the few registered in the U.S., which means it must follow 1940 Act rules on custody and shareholder records written decades before blockchain.
Why Franklin needed relief: Those custody rules assume physical securities, with requirements for vault storage, notation, and independent verification that digital records cannot satisfy. The letter exempts Franklin from the provisions built for vaults and, in exchange, accepts that the blockchain forms part of the fund’s official ownership record, with Franklin Templeton Investor Services (FTIS) remaining transfer agent.
How it works: That official record runs across two linked systems.
Franklin’s internal book-entry layer stores investor identities and other sensitive data.
Stellar records subscriptions, redemptions, distributions, NAV data, trade dates, and full transaction history.
Together, and only together, they constitute the master shareholder file.
Control remains centralized: Despite the onchain layer, Franklin keeps full control of that file. FTIS holds the administrative keys to freeze, correct, migrate, or restore positions, and transfer restrictions determine who can receive shares, so the transfer agent's traditional role survives the move onchain.
“The SEC required that we prove that we could control the keys and [...] know where every token was at every moment in time that we issued, and be able to replace any stolen or damaged wallet tokens,” Sandy Kaul, Franklin’s Head of Digital Assets, said in a recent interview.
Outlook: For now, the relief only covers Franklin’s own funds. WisdomTree received separate relief in February for WTGXX, but both approvals remain case-specific, and other managers seeking the same access will each need their own exemption. Until that changes, tokenized funds reach deeper into traditional finance one regulatory exception at a time.
Nick Cherney is Head of Innovation at Janus Henderson Investors. The $480 billion asset manager has launched several tokenized funds in partnership with tokenization specialist Centrifuge.
What does Franklin Templeton’s no-action letter actually unlock for tokenized funds?
I think the easiest way to understand this is to separate what the letter changes today from why it matters longer term.
Today, it gives Franklin greater regulatory certainty around using BENJI within its own ’40 Act fund complex. That could allow more of its internal cash to move into the tokenized fund and increase BENJI’s assets. But economically, much of that is still money moving from one part of Franklin to another.
What it does not do is make the fund fully onchain. Cash still moves through traditional banking rails, the underlying securities still settle through traditional market infrastructure, and the funds remain subject to the same NAV and reporting requirements. You do not get to truly atomic settlement until the underlying assets, even U.S. Treasuries, can themselves move onchain.
So I see the significance as primarily regulatory. Franklin has removed one area of uncertainty around using an onchain register within a ’40 Act fund structure. That is an important building block, but it does not unlock very much by itself. The bigger benefits only emerge as more of the fund infrastructure, including cash, securities and settlement, moves onchain.
Joris Delanoue is the CEO and co-founder of Fairmint, a company specializing in blockchain-integrated transfer agency services. He also serves as General Director of the Canton Foundation.
Nick described Franklin’s relief as one building block toward an end-to-end onchain fund stack. What does the no-action letter signal for you?
Recent developments around tokenized money market funds, and Franklin Templeton’s no-action letter in particular, suggest fund tokenization is entering its next phase. The first challenge was putting the fund interest onchain. Now the industry is working on moving the regulated infrastructure around it onto the same rails.
Transfer agency sits at the center of that shift. Much of today’s market still has liquidity moving onchain while the authoritative ownership record is maintained elsewhere, forcing transactions to be reconciled against traditional systems. The goal is not to remove the transfer agent, but to let the regulated transfer agent maintain that record onchain.
That helps explain the growing focus on digital transfer agency across traditional and crypto firms, from BNY’s Digital Transfer Agency to Bullish’s acquisition of Equiniti and Securitize’s role with the NYSE. But moving each transfer agent onchain independently only solves part of the problem. Without common standards, the industry simply rebuilds today’s silos on new rails. Real efficiency only appears when ownership and transactions share one interoperable source of truth.