- Goldman Sachs sees Coinbase and Robinhood gaining new opportunities from the SEC’s tokenized-stock framework.
- Citizens sees Circle benefiting if onchain equities increase USDC use for settlement and collateral.
- The opportunity remains constrained by issuer opt-outs, volume caps and shareholder-rights requirements.
Coinbase, Robinhood and Circle could emerge as early beneficiaries of the Securities and Exchange Commission’s new framework for tokenized U.S. stocks, according to analyst notes from Goldman Sachs and Citizens cited by CoinDesk on September 20.
The assessment follows the SEC’s September 17 Innovation Exemption, which permits limited secondary trading of qualifying tokenized U.S. stocks through permissioned automated market makers on public blockchains. The framework creates potential business across trading, custody, tokenization infrastructure and stablecoin settlement, but the opportunity differs considerably across the three companies.
SEC Creates a Controlled Market for Onchain Stocks
The SEC order introduces Tokenized Securities Venues, or TSVs, which can operate permissioned AMM liquidity pools without falling under the Exchange Act’s normal definition of an exchange. Certain liquidity providers also receive conditional relief from the definition of a dealer.
The exemption applies only under specific conditions. Tokenized shares must carry the same rights and privileges as the corresponding traditional stock, including dividend and voting rights. Issuers can object to unaffiliated third parties tokenizing their shares, while TSVs face limits on both eligible symbols and trading volume. Smart contracts must also be public and auditable and operate on public, permissionless distributed ledgers.
Those restrictions are central to the economics of the framework. The SEC is opening a route for onchain equities without immediately creating an unrestricted parallel market to conventional exchanges.
Coinbase Has the Broadest Infrastructure Exposure
Goldman Sachs analysts pointed to several parts of Coinbase’s existing business that could participate in a tokenized-stock market, including custody, tokenization infrastructure, stablecoins and Base, its Ethereum Layer 2.
That gives Coinbase multiple potential sources of economic exposure. A tokenized equity could require custody for underlying assets, blockchain infrastructure for issuance and transfers, a venue for trading and an onchain asset for settlement.
Goldman also highlighted Coinbase’s existing tokenized-equity offering, saying it already possesses many characteristics contemplated by the SEC framework. CEO Brian Armstrong said voting rights are expected to be added to the product, according to CoinDesk.
The significance for Coinbase is therefore not limited to stock-trading commissions. If tokenized equities gain traction, activity could spread across several businesses already inside its ecosystem.
Robinhood Has Distribution but Must Adapt Its Model
Robinhood starts from a different position. The company already offers tokenized U.S. equities to eligible customers outside the United States and has built dedicated blockchain infrastructure around tokenized financial assets.
Goldman Sachs identified that existing distribution as an advantage, but the SEC framework introduces a material structural requirement: qualifying tokens must provide the same shareholder rights as the underlying shares.
That means Robinhood cannot simply transplant its existing offshore model into the U.S. exemption. Its products would need to satisfy the SEC’s requirements for rights attached to the underlying equity.
Robinhood’s opportunity therefore depends on whether it can adapt its existing tokenization infrastructure to a model that more closely mirrors conventional share ownership.
Circle’s Opportunity Sits Underneath the Trading Venue
Circle’s potential benefit is less dependent on operating a stock platform.
Citizens analysts pointed instead to USDC’s possible role as settlement liquidity and collateral for onchain equity markets. If tokenized stocks trade through blockchain-based AMMs, those markets will require liquid onchain assets for payments and collateral.
Circle could therefore gain even if Coinbase, Robinhood or another company operates the venue itself.
That gives Circle a different exposure to the market. Coinbase and Robinhood would need to capture trading or infrastructure activity directly, while Circle’s opportunity depends more heavily on whether USDC becomes a preferred settlement asset across multiple venues.
The Three Companies Have Different Paths to the Same Market
| Company | Potential Exposure | Existing Position | Main Constraint |
|---|---|---|---|
| Coinbase | Custody, Base, tokenization, USDC | Broad crypto infrastructure | Adoption by issuers and traders |
| Robinhood | Brokerage, tokenization, Robinhood Chain | Existing offshore stock tokens | Full shareholder rights |
| Circle | USDC settlement and collateral | Onchain dollar infrastructure | USDC adoption by TSVs |
The clearest indicators will be how many issuers permit their stocks to trade on TSVs, how much volume those venues attract, which public blockchains they select and which assets become dominant for settlement.
Those metrics will show whether the exemption develops into a meaningful new distribution channel for Coinbase, Robinhood and Circle or remains a relatively narrow experiment within the much larger U.S. equity market.



