ARK Investment Management has asked the U.S. Securities and Exchange Commission to approve a tokenized share class for its 562 million USD venture fund, one of the most concrete attempts yet by a major asset manager to put registered fund shares on a distributed ledger.
According to an application filed with the SEC, ARK Venture Fund wants to add a Tokenized Class alongside a new Exchange Class by amending an exemptive order the regulator granted in November 2025. The SEC published notice of the request on August 24 and set September 18 as the deadline for requests for a hearing before it can act on the application.
The filing in detail
ARK filed the original application on May 20 before submitting amendments on June 11 and August 7 under file number 812-16031. The filing seeks relief under sections 6(c), 18 and 17(d) of the Investment Company Act, along with Rules 23c-3 and 17d-1.
The proposal would give the two new classes different routes for secondary trading. Exchange Class shares could list on a national securities exchange, while ownership of Tokenized Class shares would be recorded through distributed ledger technology. Tokenized shares could trade through alternative trading systems registered under Regulation ATS, other quotation mediums, or peer-to-peer transfers between approved wallets. Notably, ARK is not asking the SEC for permission to list or quote the shares on decentralized finance platforms.
The firm is seeking approval through the SEC’s existing exemptive application process while the agency continues working on separate rules that could govern tokenized securities more broadly. ARK made clear its application does not seek regulatory relief for the technology used to maintain shareholder records. In a footnote, the applicants said they “are not seeking exemptive relief with respect to whether or how distributed ledger technology is used by a Fund to maintain a record of its shareholders.”
An existing structure, a new ledger
ARK Venture Fund operates as a continuously offered closed-end interval fund and reported 562 million USD in total assets as of January 31. Its existing Class D, Class S and Class U shares were priced at 49.83, 49.69 and 49.70 USD respectively as of May 15, with an aggregate non-affiliate market value of approximately 912.6 million USD.
The venture fund is separate from ARK’s better-known ARK Innovation ETF, which had 6.55 billion USD in assets and operates through ARK ETF Trust. Under the proposed structure, investors would receive Tokenized Class shares through the fund’s normal subscription process at net asset value. The shares would carry no sales load and could be distributed by registered broker-dealers or directly through the fund’s transfer agent, with costs associated specifically with the class remaining with its shareholders.
The application would amend ARK’s November 2025 exemptive order, which allowed the fund to maintain multiple share classes. That earlier application contained a representation that fund shares would neither be listed on a securities exchange nor quoted on a quotation medium — requiring ARK to return to the SEC before introducing the proposed trading arrangements.
No blockchain named — yet
No blockchain, tokenization provider or new transfer agent has been identified in the application. The filing refers generally to “tokenization agents” and the fund’s transfer agent when discussing expenses associated with the proposed class. The Bank of New York Mellon currently serves as ARK Venture Fund’s transfer agent, administrator and custodian, according to the fund’s semi-annual report.
ARK already has a financial connection to tokenization company Securitize through the venture fund itself. The portfolio holds Securitize equity and a 10 million USD convertible note carrying a 5% interest rate and maturing in September 2028, acquired on September 30, 2025. Securitize has expanded its institutional tokenization business aggressively this year: in August it launched a tokenized high-yield fund with Neuberger that invests mainly in high-yield bonds while offering interests across Avalanche, Ethereum, Solana and Sui. The company also serves as the transfer agent and tokenization platform for BlackRock’s BUIDL fund, and Hanwha Group became its largest shareholder in July after combined holdings reached 9.6%. ARK’s application does not state whether Securitize would have any role in the proposed Tokenized Class.
Regulatory timing matters
The filing arrives before the SEC has completed a separate regulatory framework for tokenized securities trading. An “innovation exemption” discussed by SEC Chair Paul Atkins has yet to take effect, but the proposed approach is expected to let selected firms test blockchain-based securities products under defined conditions while permanent rules are developed. In August, reports indicated the SEC was preparing a regulatory route that could permit qualified platforms to trade tokenized U.S. stocks around the clock.
By using the exemptive application path rather than waiting for the new framework, ARK is effectively asking the SEC to bless tokenized fund shares under rules written in 1940. That strategy has precedents: the tokenized fund structure that BlackRock’s BUIDL uses today was secured through similar relief. If granted, ARK’s order would extend the model to an interval fund whose shares already trade secondarily — a subtle but meaningful expansion of what tokenized fund shares can do.
Why it matters for blockchain adoption
For the blockchain industry, the application is significant less for its scale — 562 million USD is a rounding error in traditional fund plumbing — than for what it normalizes. A tokenized share class approved through the standard exemptive process would make distributed-ledger ownership records an ordinary feature of regulated funds rather than an exotic experiment. It would also create a template other asset managers can copy wholesale, much as the spot ETF filings of prior years became a standardized queue.
The September 18 hearing deadline gives the SEC a window to act, request more information, or let outside parties weigh in. If no hearing is requested, the application can proceed toward a decision. Market context for the filing: Bitcoin trades around 78,500 USD, Ethereum near 2,487 USD and Solana at about 103 USD.
Disclaimer: This article is for informational purposes only and does not constitute financial advice.
sept 18 hearing deadline and this got filed quietly as an amendment to an existing exemptive order. smart move, amend instead of filing fresh so you inherit all the precedent
the quietly huge part: peer to peer transfers between approved wallets for a registered fund share. ARK is basically asking for fund shares that move like crypto
footnote saying they dont want relief on the DLT shareholder records part is the tell. they know the tech question is where the SEC would stall, so they carved it out
tokenized share class on a 562m venture fund, hearing deadline sept 18. if this passes the tradfi rails finally touch the chain directly
ARK kept the ask deliberately modest. Tokenized Class trades on ATS or peer to peer between approved wallets, they skipped exchange listings entirely. smart way to make it easy for the SEC to say yes
approved wallets is doing a lot of heavy lifting here. peer to peer sounds great until you see the whitelist requirements, its closer to a permissioned registry than crypto rails
this. every p2p transfer needs both wallets pre-approved by the transfer agent, so its a permissioned registry with crypto branding. still net bullish on the filing tho
pre-approved wallets means the transfer agent runs that whitelist forever. one sanctioned address slipping through a p2p transfer and the sec has its test case, amendment route closed for everyone
permissioned registry with crypto branding is harsh but accurate. still beats quarterly gates, even a fenced pool is more liquidity than venture shares have ever had
562 million is pocket change for ARK. the venture fund is just the test tube here, if the Tokenized Class gets through you watch them try it on the ETF side next
they will absolutely try the ETF side next. wood has been telegraphing tokenized everything since spring, the venture fund is just the low stakes rehearsal
rehearsal is right. 562m venture fund is pocket change next to arkb, if the share class works the etf tokenization filing writes itself
Sept 18 hearing deadline, file number 812-16031. at least this one skips the usual 19b-4 grind, could actually move fast
@Ingrid Sorheim amending the November 2025 exemptive order instead of filing fresh is the whole ballgame here. If the SEC greenlights the Tokenized Class by October, every manager holding a similar order will queue up the exact same amendment
Agreed, and the amendment route works for every manager holding a pre-2026 order. Count maybe a dozen funds that could clone this exact filing by Q1 if it passes.
amending the existing order also means objectors get less runway. quiet process, fast process, and a dozen copycat filings before Q2 if it clears
Rule 23c-3 relief for an interval fund with a tokenized class, thats the quietly clever bit. closed-end structure means no daily redemption pressure while the token trades P2P
interval structure plus p2p transfers is doing quiet heavy lifting. quarterly gates cap the run risk while the token side feels modern, clever hybrid
562 million fund getting a tokenized class before we even have a functioning tokenized treasury market. the order of operations here is fascinating
order of operations feels wrong until you remember venture shares are already illiquid. the interval fund structure hides the settlement gaps, this is the least demanding pilot they could have picked
sept 18 deadline on an amendment to an existing order is the speedrun version of fund innovation. if it clears, Q1 is copycat season
the copycat season take ignores that ark is amending an order from nov 2025. copycats with no prior order wait a year plus for their own, this lane is barely open
copycats need the same november 2025 order though. how many managers actually hold one they can amend like this
copycat season still needs the sec to bless the approved wallet registry part. thats the piece every clone inherits and nobody has litigated yet
sept 18 is just the hearing request deadline, not a decision date. still, an 812 file number moving in months instead of years is fast for this sec