Information system operator

An information system operator is a legal entity that runs a platform for issuing and recording digital financial assets (DFAs) and is responsible for the rules of that platform, for identifying its users and for the accuracy of the records of asset ownership. A record in the information system plays the same role here as an entry in a custody account on the traditional market: it is this record, not a separate paper document, that confirms the holder's rights. Such a system may be run only after inclusion in the register kept by the Bank of Russia — operator status is not granted to just any owner of a suitable technology.

What the operator controls

The operator's main tool is the information system rules it has approved: the procedure for admitting users, the procedure for issuing an asset under the decision of the issuing party, the procedure for settling trades, and the steps to be taken in the event of technical failures and conflicting records. These rules are not an internal policy but a condition that every participant accepts, so an investor's rights on the platform are defined by them to the same extent as by the terms of the asset itself.

The operator's role should be kept apart from two familiar figures. An exchange brings the orders of many participants together in a common order book and keeps the parties anonymous; an information system operator services the issue and transfer of rights within its own platform, and a trade there is often a negotiated one between named counterparties. A depository keeps records of securities that exist outside it, whereas the operator creates the environment in which the asset comes into being at all. The obligations under the asset remain with whoever issued it — the function of the issuer does not pass to the operator, and the operator's solvency does not guarantee payments on the asset.

What the operator checks about the investor

The buyer's status is controlled on the platform side: the operator sees whether a client falls into the category of qualified investor and restricts the purchases available to them. For a non-qualified investor, the annual limit on purchases of DFAs with variable income is — RUB 600,000. Tracking this limit is technically possible only at the operator's level, because only the operator sees all the trades within its system.

Where the term is misleading

The first confusion is mixing it up with a digital financial asset exchange operator: that is a separate status relating to secondary trading, and one and the same platform is not obliged to combine both roles. The second is a literal reading of the phrase: "information system" sounds like a technical service, although what is meant is a legal status with supervision and capital requirements.

The most expensive mistake is to expect a platform to behave like an exchange. The operator has no obligation to maintain two-sided quotes, so liquidity on such a platform is determined by the terms of the particular issue, not by the existence of trading. An asset bought with the intention of selling before redemption may have no buyer at all.