
SEC no-action letter lets Franklin Templeton mutual funds and ETFs hold tokenized money-market shares as collateral. First such relief for a traditional fund, Kaul says.
The SEC has sent Franklin Templeton a no-action letter that lets its conventional mutual funds and exchange-traded funds hold shares of tokenized money-market funds as collateral or portfolio holdings. Sandy Kaul, the firm's head of digital assets and innovation, said it is the first time the regulator has granted this type of relief for a traditional fund to invest in a blockchain-based representation of a money-market fund.
"We want our funds to experience the efficiency of having a better money market fund option: manage more precisely, capture more of the yield, better and more tightly manage how much cash liquidity they have to hold," Kaul said.
The vehicle at the center is the Franklin OnChain U.S. Government Money Fund (BENJI), which uses blockchain tokens to represent ownership and invests in U.S. government securities and cash equivalents. BENJI currently holds about $2.6 billion in tokenized money-market products. Franklin Templeton oversees roughly 130 ETFs with about $82 billion in assets worldwide, plus a mutual fund business with approximately $790 billion.
The no-action letter improves capital efficiency, liquidity and collateral management for ETFs, Kaul said. A fund that holds BENJI shares can settle trades faster and manage cash positions more precisely because the tokenized shares trade 24/7 on blockchain rails. Investors in an ETF that holds BENJI indirectly gain access to that blockchain layer without holding the tokens themselves.
Kaul said the distribution channel – not just the $2.6 billion size of the tokenized fund – is the main story. Franklin's large mutual fund and ETF base means the no-action letter could let thousands of existing funds plug into tokenized cash management. Other asset managers are likely to seek similar relief, though the SEC has not signaled a broader policy shift.
The move comes as tokenized money-market funds have grown to roughly $2.6 billion across issuers, with Franklin's BENJI among the largest. The broader crypto ETF market has seen volatile flows: Bitcoin ETFs recorded net inflows of over $500 million in Q3, following outflows of about $4 billion in June and withdrawals of over $380 million last week. Jane Street added roughly $630 million in Bitcoin ETFs in Q2, bringing its reported position to about $1.06 billion.
Franklin Templeton is now the test case for how far the SEC is willing to let tokenized assets penetrate traditional fund structures. Kaul said the no-action letter is the first instance where the regulator has specifically granted this type of comfort, leaving the door open for similar applications.
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