Goldman Sachs Report: SEC Approves Trading of Tokenized Stocks, COIN to Benefit Most

Written by: Rita

The SEC has opened the door to tokenized stock trading in the U.S. for the first time. In a report issued on September 18, 2026, Goldman Sachs noted that on September 17, the SEC issued an order granting a five-year conditional registration exemption to specific exchanges and liquidity providers, permitting them to offer tokenized stock trading in the U.S. These entities are referred to as Tokenized Securities Venues (TSVs). Goldman Sachs believes that this order, for the first time, broadly permits tokenized stock trading in the U.S. and could drive gradual growth in the tokenized U.S. stock market.

Goldman Sachs analyst James Yaro outlined three conditions in his report. Only venues using an automated market maker (AMM) order book are eligible for exemption; traditional exchanges and most centralized crypto exchanges, which use centralized limit order books (CLOB), do not qualify. Only stocks with native tokenization characteristics are exempt; non-native, derivative-style tokenized stocks are not covered. Issuers have the right to object and refuse tokenization of their stocks prior to trading. These three conditions limit the short-term impact of the exemption.

Goldman Sachs noted that AMMs are primarily used by decentralized exchanges, while CLOBs are used by traditional exchanges and most centralized crypto exchanges. AMMs provide liquidity for long-tail contracts through token inventories, making them suitable for new markets. As trade sizes increase, the scarcity-based pricing of AMM smart contracts leads to higher price slippage risk, whereas CLOBs are more effective in deeper, more liquid markets. This technical difference means that the exemption order has limited impact on large markets.

The exemption order also requires TSV to be limited in the number of trading symbols and trading volume, must provide tokenized stockholders with shareholder rights and dividends equivalent to those of underlying stockholders, the AMM smart contract must be auditable, public, and deployed on a public blockchain, and TSV must publicly disclose its operations and trading information.

Goldman Sachs believes that Coinbase (COIN) and Robinhood (HOOD), within its coverage, may help establish a tokenized stock market in the U.S. COIN stands to benefit the most, as its tokenized stock brokerage product already meets most of the requirements under the exemption order, including offering shareholders rights and dividends equivalent to those of the underlying shares. COIN can offer tokenized stocks in the U.S. under the exemption order with minimal technological upgrades. Additionally, COIN provides a tokenization platform and custody services, allowing it to benefit as other companies build tokenized stock offerings using the exemption order.

If COIN wishes to use the exemption order to establish a tokenized stock exchange, it must develop new exchange technology, as COIN’s existing exchange uses a CLOB. Goldman Sachs notes that COIN routes brokerage trades to decentralized exchanges, many of which use AMMs and are therefore eligible for the exemption order.

HOOD’s current tokenized stock offering is available only in Europe and is non-native tokenization, which does not meet the exemption requirements. HOOD must develop a new tokenized stock product to comply. Goldman Sachs also noted that tokenized stocks traded on-chain could drive adoption of tokenized cash as a settlement currency, thereby increasing stablecoin usage—potentially benefiting Circle (CRCL), the issuer of USDC, and COIN, which also derives significant economic benefits from USDC.

Goldman Sachs believes that the exemption poses limited direct competitive risk to traditional exchanges. Nasdaq (NDAQ) and the New York Stock Exchange (ICE) already operate registered national securities exchanges and do not require an exemption from the definition of “exchange” to trade tokenized stocks. Both exchanges are advancing tokenization within their existing market infrastructure frameworks, rather than through TSV. They do not need to build AMM infrastructure to support their current tokenization initiatives.

Nasdaq received SEC approval in March 2026 to allow tokenized versions of DTC-eligible securities to trade on the same order book, with DTC handling tokenization and settlement. This pilot covers Russell 1000 constituents and index ETFs for a three-year period. The New York Stock Exchange is advancing along a similar path, developing a standalone platform supporting 24/7 trading, instant settlement, and stablecoin financing, though the platform still requires regulatory approval.

Goldman Sachs noted that traditional exchanges maintain a structural advantage on the most liquid stocks because tokenized orders on Nasdaq and the New York Stock Exchange interact with traditional stocks on the same order book, whereas tokenized stocks on TSV are subject to symbol and volume restrictions and are limited to permitted participants. The eligible universe under the DTC pilot consists of Russell 1000 components and major index ETFs—precisely the deep markets where CLOBs outperform AMMs.

Goldman Sachs views this exemption as another step toward greater regulatory clarity for digital assets by the SEC and CFTC. Previously, the SEC proposed a regulatory framework in August 2026 that would exempt smaller projects from token offering requirements. On September 17, the CFTC issued a no-action stance, exempting developers of self-custody wallets from registering as introducing brokers. Both agencies have indicated their intent to establish comprehensive regulations for digital assets.

Goldman Sachs also noted that these regulatory efforts are insufficient to fully unlock widespread adoption of digital assets. Regulatory actions lack permanent legislative backing, and future regulators could reverse or modify them through rulemaking. Goldman Sachs believes that fully unlocking digital assets requires comprehensive legislative reform, such as the CLARITY Act, which failed a procedural vote in the Senate on September 15.

Goldman Sachs believes that the exemption order’s competitive outcome is more favorable than the passage of broader tokenization legislation. If the CLARITY Act were to pass and lead to wider adoption, traditional exchanges would face greater competitive pressure. The exemption order limits the short-term proliferation of tokenized stocks through AMM requirements and issuer veto powers, resulting in only limited impact on the trading volume of traditional exchanges.

The exemption opens the door to tokenized stocks, but AMM requirements and issuer veto power keep the door only slightly ajar. If issuers commonly choose to reject tokenization, or if the CLARITY Act gains renewed momentum, how will the long-term value of this exemption framework change?

Disclaimer

This article is a compilation and interpretation by Chaoxiang Research of a third-party brokerage research report (Goldman Sachs, September 18, 2026), combined with publicly available market information. The ratings, price targets, earnings forecasts, and related judgments cited herein reflect the views of the brokerage's analysts and represent the position of their respective institution only; they do not reflect the views of Chaoxiang Research nor constitute any investment advice.

The market carries risks; make decisions independently. This article should not be used as a basis for buying or selling any securities.