Goldman Sachs and Citizens analysts say Coinbase is the company closest to compliance under the Securities and Exchange Commission’s new five-year tokenized-stock exemption, with Robinhood an
Goldman Sachs and Citizens analysts say Coinbase is the company closest to compliance under the Securities and Exchange Commission’s new five-year tokenized-stock exemption, with Robinhood and Circle also positioned to benefit, in assessments laid out in a September 20 report.
The SEC’s innovation exemption creates a path for qualifying tokenized U.S. stocks to trade through automated market makers on public blockchains. To qualify, tokens must preserve shareholder rights such as dividends and voting, and venues face limits on trading volume and the number of stocks they can offer. Issuers also get the right to object before third-party tokenized versions of their shares can begin trading.
Goldman Sachs analysts said Coinbase could benefit across several parts of its business. Its existing tokenized-equity offering already carries many of the characteristics the SEC requires, including shareholder rights and dividends comparable with the underlying stock. The company also runs an institutional custody business and Coinbase Tokenize, an infrastructure service for other firms putting assets onchain. Analysts at Citizens highlighted the same reach, adding Coinbase’s stablecoins and its Ethereum-based blockchain Base.
One gap remains. Coinbase’s exchanges use central limit order books to match trades, while the SEC framework is built around automated market makers, which price assets through onchain liquidity pools. Goldman Sachs analysts said that is a hurdle if Coinbase wants to operate a trading venue directly under the exemption.
Coinbase CEO Brian Armstrong addressed part of the gap in a post on X, writing that Coinbase Tokenized Stocks are “real fully-backed securities, redeemable for the underlying shares, with dividends integrated, and voting rights coming soon.” Voting rights are not live yet, and no venue decision has been stated.
The exemption frames what Robinhood must do. Its offshore stock tokens give price exposure to U.S. shares through a derivative without conveying the ownership rights the exemption requires, so they do not fit the framework as they stand. Robinhood CEO Vlad Tenev has said share redemptions and voting rights will be added, and analysts at Citizens expect the company to move quickly given its offshore tokenized-equity business and its Arbitrum-based Robinhood Chain. Those changes have not shipped.
Both banks also flagged Circle as an indirect winner, with its USDC stablecoin potentially used for settlement and collateral around onchain markets. Goldman Sachs analysts added that new venues are unlikely to take meaningful volume from incumbent exchanges such as Nasdaq and NYSE owner Intercontinental Exchange, given the trading caps, issuer opt-outs and the limits of automated market makers in deeper markets.
