What Digital Asset told the SEC

The request

Nine things the letter puts on the record

Each quotation below is verbatim from the 14-page request of 30 October 2026. Figures in it are stated as of 30 September 2026. The comment under each one says what it settles or moves in the September report.

• The two counts, stated by the issuer

  At launch, there were 13 Super Validators. As of September 30, 2026, there were approximately 60 Super Validators. [...] As of September 30, 2026, there were 13 Super Validator Node Operators.

  The September report derived this split from the Canton Foundation’s MainNet configuration file, because no published document stated it. Digital Asset has now stated it to a federal regulator. Holding a super validator position and operating a node are separate things, and the two counts measure different populations.

• Who sells Canton Coin

  The natural sellers of Canton Coin in the secondary market are Super Validators, Validators and application providers monetizing Canton Coin minted for the services they provide.

  Selling by the parties who receive new coins is described as the ordinary working of the market, not as an event. The buyers named in the same paragraph are validators, application providers and users who need coins to pay network fees.

• Digital Asset sells too

  DA has also, from time to time since launch, purchased and sold Canton Coin on the secondary market for ordinary operational and treasury purposes, including converting Canton Coin it earns into fiat currency, obtaining Canton Coin needed to pay network fees and managing its working capital, on the same terms available to any other market participant.

  The same section states that Digital Asset “has not undertaken, and does not undertake, to support, stabilize or otherwise influence the price of Canton Coin.”

• Nobody collects the fees

  No portion of the Canton Coin used to pay network fees is received by DA, the Canton Foundation or any other person; such Canton Coin is destroyed by the protocol.

  Fees are burned rather than paid to an operator, so the network has no fee revenue in the ordinary sense. Traffic fees are denominated in US dollars, so the quantity of coin destroyed by a given transaction rises as the coin price falls.

• The issuer’s own description of the price model

  absent useful activity on the network, the total supply of Canton Coin will continue to increase such that downward pressure would be expected on the price of the coin.

  Supply grew between the two readings below, which places the network in the first half of that sentence on the only measure available from outside.

• The repo figure, now in a filing

  processed a monthly average of over $7.1 trillion in U.S. Treasury repo trades that were settled atomically.

  The September report graded the $6T and $300B figures announced, because canton.network published no measurement basis beside them. This number is close to Broadridge’s $7.5 trillion for June 2026 and is now a representation to the Commission’s staff. The letter does not say whether the volume settles on the Global Synchronizer or on a private synchronizer.

• The development fund

  beginning in February 2026, five percent of the Canton Coin available for minting was allocated to parties that support protocol development and other ecosystem public goods.

  Sourced pro rata from the super validator, validator and application provider allocations. The September report recorded cctools showing a 5% development fund against a null field in the live issuance configuration, and treated the community dashboard as the one that disagreed with the chain.

• No pre-mine

  there was no “initial coin offering,” pre-mine or any other pre-launch sale or allocation of the token.

  Consistent with the whitepaper, which describes no genesis allocation, and with both aggregators tracking no locked or unvested tranche.

• The foundation board

  As of September 30, 2026, the Canton Foundation is co-chaired by DTCC and Euroclear and governed by a board of 22 directors, of which DA holds only one seat.

  The named directors include representatives from 5North, 7RIDGE, Broadridge, BNY, Bitwave, CNTN, DA, Cumberland, DTCC, Euroclear, Fairmint, HSBC, IntellectEU, Liberty City Ventures, Obsidian Systems, LTP, MPCH, T-RIZE and Tradeweb. BNY and HSBC do not appear on the September roster in this capacity.

One arithmetic to check

Thirteen voting identities, eleven companies, a threshold of nine

Read again

Fifty days later, the network is the same shape and the market is larger

Every live figure the September report measured, read a second time on 4 November 2026. The September column is the 15 September 2026 snapshot and is not changed by this reading. Rows that did not move are the structure of the network. Rows that moved are the market around it.

The thirteen node identities are the same thirteen names. Bybit still takes the largest share of reported volume at about 36% across two pairs, and Temple Digital Group has moved to second at about 18% on a Canton-native pair. Coinbase, Binance, Gemini and Bitstamp still list no Canton Coin pair.

The measurement

Three coins in ten reached supply, and the rest cannot be seen

The open items

One of the ten closes, three move

Page 7 lists ten questions the September report could not settle. The letter and the second reading change four of them. The other six are unchanged, and most of those wait on the same allowlisted endpoint.

• 02Five super validator counts, five definitionsClosed

  Digital Asset states both counts in the same paragraph and explains the relationship: a super validator may run its own node or be hosted by a node operator, and only node operators vote. That reconciles the 13 read from the governance contract with the roughly 60 in the configuration file and on the Canton Foundation dashboard. Visa’s figure of 40 is still unexplained by any document.

• 03Where Broadridge’s repo settlesNarrowed

  The monthly average of over $7.1 trillion in atomically settled Treasury repo is now a representation to the staff rather than a marketing figure. The letter still does not say whether that volume crosses the Global Synchronizer or a private synchronizer, and a private synchronizer publishes nothing by construction. The question the September report asked is unchanged; the evidence behind the number is stronger.

• 06Community dashboards and the chain disagreeSharpened

  On the development fund, cctools was right and the live configuration is the outlier. Digital Asset states that five percent of minting has gone to a development fund since February 2026, sourced pro rata from all three allocations. The issuance configuration read on 4 November 2026 still returns a null development fund percentage, alongside fields named optDevelopmentFundManager, developmentFundManagerBlacklist and minDevelopmentFundMintingDelay. The machinery is in the configuration and the percentage is not.

• 01Coins minted and coins burned cannot be separatedNarrowed

  The Scan API is still allowlisted and the two totals are still unavailable. A second reading of supply against the schedule now bounds the pair over a window rather than since genesis: 399,916,547 coins reached supply against roughly 1.339 billion authorised over 48.91 days, so about 19.2 million coins a day were burned or never claimed. At the 4 November price that is about $1.9 million a day, against the $1.5 million of daily fees the Canton Foundation dashboard credits to The Tie.

Harder to read than it was

Two public sources now ask for an account

Both were read without credentials in September and both refuse an anonymous request now. Neither figure they served has been re-measured, so the September values stand with their September date and should not be carried forward.