b'The Long View of the Short-TermGuggenheim Tokenizationof Commercial Paper We advised Guggenheim Partners who led a consortia of financial entities in developing a tokenized asset-backed commercial paper (ABCP) issuance platform in the United States. Commercial paper is short-term, unsecured investment grade debt, usually issued by corporates and financial insti-tutions. ABCP is commercial paper (CP) collateralized by financial assets,usually issued by a conduit or special purpose funding vehicle established by a financial institution to own the collateral assets received from asset sellers. CP and ABCP play important roles in financing businesses. There has been a significant increase in ABCP in recent years, with ABCP now accounting for about 30% of total CP outstanding. There is nearly $400 billion out-standing in the United States as of year-end 2025.Tokenization brings greater efficiency to this important market, reducing settlement risk, issuance costs, and also regulatory charges for the financial institution issuers that are sponsors. As a leading firm advising on short-term debt issuance, we were able to bring to bear our understanding of the market, the relevant documentation, and the set-tlement and clearance requirements. We advised on, among other things, structuring, securities, tax matters and the tokenization infrastructure. Ownership of the CP is recorded in the issuers books and records and in a public, blockchain-based distributed ledger using Ethereum, an open-ended, decentralized, public software platform with smart contract func-tionality. Since the initial work, Guggenheim has expanded to working with Ripple and, as a result of market interest, focusing on the use of the XRP Ledger. This work is noteworthy because this product is the first offering of tokenized commercial paper instruments in the United States. 1'