Tokenized stocks: 15.6% of $3.06B fits the SEC order

Of the $3,060M in tokenized stocks counted by rwa.xyz on Sep 19, 2026, only $477.8M (Securitize, Figure, and Superstate, or 15.6%) fit the definition of SEC Order 34-106402 (Sep 17, 2026), when read against each issuer's legal documentation; Ondo, bStocks, xStocks, Robinhood, and Reality fall outside the scope at 82.6%. The order opens a lane for trading tokenized stocks on AMMs (automated market makers: the smart contract that sets the price based on the ratio of deposited assets), but only covers "Tokenized NMS Stock" (a U.S. listed stock tokenized by its issuer or a third party) that grants the holder "the same rights and privileges" as the stock: the same equity interest, same dividend, same vote, and same share in liquidation. It expressly excludes tokens that are "a third party's own security providing synthetic exposure." None of the tokens that fit the criteria have a single pool on an AMM, and the four venues with markets for tokenized NVDA (Robinhood Chain, Aerodrome on Base, PancakeSwap on BNB Chain, and Raydium on Solana) trade debt and certificates. This article classifies each issuer by their legal documentation and maps liquidity pool by pool.

Which tokenized stock issuers fit the SEC order: Securitize, Ondo, Backed, Robinhood?

As of Sep 19, 2026, rwa.xyz counted $3,060M in tokenized stocks spread across 6,353 assets and ten named platforms. Binance, which launched ten tokens on Base with prospectuses approved in Abu Dhabi, does not appear on that dashboard; it is measured separately by totalSupply ($17.91M). The classification of each platform is derived from its own legal documents, cross-referenced with the four categories from the SEC staff statement of Jan 28, 2026 (issuer; custodial; linked security; security-based swap). A "transfer agent" is the SEC-registered registrar that maintains the issuer's shareholder ledger.

This is a reading of the order text against each issuer's documents; the SEC has not ruled on any of them. The breakdown: $477.8M fits (Securitize 357.5 + Figure 83.7 + Superstate 36.6), representing 15.6% of the total; $2,528.1M does not fit due to legal structure (Ondo 852.8 + bStocks 795.7 + xStocks 560.3 + Reality 153.9 + Robinhood 152.9 + Dinari 12.5), representing 82.6%; WisdomTree ($28.0M, 0.9%) falls outside the perimeter as funds, and "others" ($26.1M, another 0.9%) are unclassified. The 15.6% is a ceiling due to Figure: its "Series A Blockchain Common Stock" has rights in parity with the Nasdaq-listed Class A, but it is a distinct class traded only on its own network; if the SEC does not consider it "NMS stock" (Rule 242.600 requires trade reporting under an effective reporting plan), the block drops to $394.1M and 12.9%. The only candidate to add to the total is Dinari, should it pass voting rights to the holder (16.0%).

What does SEC Order 34-106402 require of a Tokenized Securities Venue?

The order creates a new entity, the Tokenized Securities Venue (TSV): "an organization, association, or group of persons that brings together buyers and sellers of Tokenized NMS Stock by (1) providing one or more AMM liquidity pools for permissioned participants to interact and agree upon the terms of a trade and (2) setting the standards for access to those pools." The TSV is exempted from the definition of "exchange" under Section 3(a)(1) of the Exchange Act; those providing liquidity with their own capital in these pools ("Covered Firms") are exempted from the definition of "dealer" under Section 3(a)(5). TSV smart contracts "must be auditable, public, and deployed on a public, permissionless distributed ledger."

The eligible asset is the piece that determines everything else. NMS (National Market System) refers to the set of stocks and ETFs listed on U.S. exchanges with consolidated trade reporting; "Tokenized NMS Stock" is "an NMS stock that is (1) a security tokenized by or on behalf of the issuer of the underlying stock; or (2) a security tokenized by a third party not affiliated with the issuer." It continues: "does not include securities where a third party issues a crypto asset that represents its own security and that provides synthetic exposure to an underlying security, such as a tokenized linked security or a tokenized security-based swap." Note 4 also excludes rights and warrants; Note 22 clarifies that the order does not exempt anything under the Investment Company Act (funds).

Condition E is the operational test. Literally: "A TSV must verify that the Tokenized NMS Stock made available for trading on the TSV provides holders the same rights and privileges as does traditional NMS stock of an equivalent class." The order enumerates what this means: "the same interest in the company as holders of the underlying stock, the right to receive the same dividends the company pays to holders of the underlying stock, the right to exercise the same voting rights as may be exercised by holders of the underlying stock, and the right to receive the same share of residual assets in liquidation." If the token is issued by a third party, the TSV can only list it if that third party "distributes or makes available to holders proxy materials and other issuer communications at no cost to the issuer or the shareholders."

The other conditions (TSV must be a "U.S. person," public Notice 30 days before operating, Issuer Notice another 30 days if the token is from a third party, pairs limited to another Tokenized NMS Stock, a payment stablecoin, or a tokenized money market fund, and validity "from September 17, 2026, to September 17, 2031") are detailed in the timeline below.

Why are Ondo, Backed, Robinhood, and Coinbase excluded even if they custody the stock?

A certificate is a security issued by a special purpose vehicle that promises the stock's price; the stock, if it exists, is on that vehicle's balance sheet and not the holder's. What the order verifies is who issues the security the holder has in their wallet and what rights it carries, not whether a share is deposited with a custodian. In Ondo Global Markets, the issuer is a BVI entity, the tokens "are not themselves stocks, ETFs or ADRs," and the offering is closed to U.S. persons under Regulation S (the rule allowing a security to be offered without SEC registration provided it is sold only outside the U.S.). The fact that Broadridge (a proxy service provider for listed issuers) distributes proxy voting materials to these tokens does not change the issuer: it is staff category 3, "linked security," the case the order explicitly excludes by name.

Ondo has a second line, the U.S. custodial line (Oasis Pro TA, LLC as transfer agent, voting via Broadridge; details on the Ondo/Broadridge model vs Securitize), which is category 2 (security entitlement: the right to a share that an intermediary holds on behalf of the client, as in any broker) and which rwa.xyz includes in the same $852.8M row without specifying its size. Custodial tokens exist as their own contracts on Ethereum under the name "(Ondo Custodial Tokenized Security)," distinct from the "(Ondo Tokenized)" BVI line. On Sep 19, 2026 (14:39-14:41 UTC, eth_call to a public RPC), the totalSupply was 3.0 units of IVV (0xB600…a348, a single holder on Etherscan), 3.0 units of MU (0x5eB7…85a8), and 0.0 of CRCL (0x22D7…b285). A re-reading on Sep 20, 2026, at 22:03 UTC returns exactly the same: $5,342 at the Sep 18 close compared to the $852.8 million in the row. With this split, the block that fits does not increase due to Ondo, and 15.6% remains the ceiling.

The "NVIDIA CB Certificates" issued by Coinbase Onchain SPV Ltd (an ADGM entity; prospectus approved by FSRA on Aug 4, 2026) represent "beneficial interests" in NVIDIA shares deposited at Alpaca Securities (U.S. broker-dealer and custodian). The prospectus states that "holders do not have direct voting rights over the underlying," that "only Vested Holders may exercise any rights (including redemption and voting)," that "holders will not directly receive cash dividends," and that the securities "may not be offered, sold or delivered in the U.S. or to U.S. Persons." It is a certificate with conditional voting and no direct distribution: it fails Condition E on three of its four rights.

Backed (xStocks), BTech (bStocks), Robinhood, and Reality are excluded for the same reason: certificate, debt, or the issuer's own security, without rights to the stock (citations in the table; what you are buying in xStocks, Ondo, and Robinhood).

Where was tokenized NVDA trading on Sep 20, 2026: Robinhood Chain, Base, Solana, or BNB Chain?

NVDA is the only stock with a token from all major issuers, which is why it is used as a benchmark. The snapshot is a single one, DexScreener (DEX pool aggregator) on Sep 20, 2026, at 22:04 UTC, with all pools for each token summed (liquidity and 24h volume in dollars).

The four geographies with active markets total $18.57M in liquidity and $32.53M in 24h volume for NVDA, and all four trade tokens that the order does not permit. On Robinhood Chain, the largest pool is NVDA/USDG on Uniswap with $6.16M in liquidity and $17.13M in volume. On Solana, the index token carries more weight: SPYx (15 pools) moved $15.37M with $5.53M in liquidity, six times the volume of NVDAx.

The Ondo row forces a separation between the issuer's contract and the homonymous contracts. Ondo Global Markets publishes a CSV at docs.ondo.finance/addresses with the official addresses for its 451 tokens: for NVDAon on Ethereum, only 0x2D1F…bDEE is listed, and for TSLAon only 0xf6b1…103f, both being BeaconProxy with thousands of holders. Searching for "NVDAon" on DexScreener on Sep-20-2026 at 22:04 UTC returned 18 pools and $274.38 M in liquidity, but 99.9% of that figure belonged to two Ethereum contracts declaring the same name, "NVIDIA (Ondo Tokenized)", which do not appear in that CSV and whose verified contract on Etherscan is a MintBurnTeamToken with two and three holders, a single transaction in 24 h, and round emissions of 1,831,533 and 119,097 units. The same pattern reappears on another chain: on Sep-21-2026 at 06:10 UTC, those four pools had disappeared from DexScreener and the search showed a $17.75 M pool on Robinhood Chain with $0.03 in volume, two transactions, and an address that is also not on the Ondo list. The market for official contracts at that same time: NVDAon, five pools with $144,583 in liquidity and $18,722 in 24 h volume across 116 transactions; TSLAon, three pools with $68,984 and $2,205. That is the Ondo spot market, 0.02% of the $852.8 M attributed to it by rwa.xyz. And the Ondo custodial line, which would indeed fit the order, does not have a single pair listed on DexScreener.

What is the weight of Coinbase's ten tokens on Base and how much volume goes through Aerodrome?

Coinbase publishes the official list of contracts at base.org/stocks (all starting with 0xb2) with the warning "if a token is not on this list, Coinbase did not issue it." On-chain value is derived from totalSupply (Base RPC, Sep 20, 2026, at 22:04 UTC) multiplied by the price of the highest liquidity Aerodrome/USDC pool in the same snapshot; tokens have eight decimals and each unit represents one share.

The ten tokens are worth $17.91M, or 0.59% of rwa.xyz's $3,060M (which does not count them). Volume, however, doubles the deposits: $30.41M in 24h against $14.62M in liquidity, and 97.8% of that volume ($29.75M) and 92.9% of the liquidity ($13.58M) go through Aerodrome; Uniswap, Equalizer, Hydrex, and PancakeSwap share the rest. As of Sep 20, 2026, none of the four AMMs with real activity (Uniswap on Robinhood Chain, Aerodrome, PancakeSwap, and Raydium) is a TSV, nor could they list these tokens if they were.

What liquidity do Securitize, Superstate, Figure, and Ondo's custodial line have on AMMs?

Zero pools with liquidity. DexScreener (Sep 20, 2026, 22:04 UTC) returns only unrelated namesakes for SECZ, EXOD, FGRD, and STKE: two SECZ/XRP pairs on XRP Ledger totaling $128, "AlgoStake" for STKE, and no pairs for EXOD or FGRD. For GLXY, the only real pairs are the eight for "Galaxy Digital Inc. • Robinhood Token" on Robinhood Chain ($392,781 in liquidity)—Robinhood's debt on Galaxy, not the share Superstate records in its registry. The FWDI and MU pools appearing on Solana with volume belong to Backpack Securities, another third party unrelated to Superstate or Ondo's custodial line.

This absence has a technical cause, the same one that makes these tokens fit the definition: tokenized stock issued by its issuer carries transfer restrictions. Securitize offers tokenized SECZ "to eligible U.S. investors" via its platform, Superstate requires "an allowlisted address," and Ondo's custodials circulate under controls from the broker-dealer, transfer agent, and custodian. A permissionless AMM, where any address can deposit and trade, is incompatible with such a list; the order resolves this conflict with a permissioned-access AMM on a public chain, operated by a U.S. entity. Such a venue does not exist as of Sep 20, 2026: no Notice (Condition C) appears on the websites of Securitize, Superstate, Oasis Pro, Coinbase, Robinhood, or Kraken (xStocks distributor).

The "dealer" exemption allows a market maker to seed these pools with their own capital without registering. Backed and BTech are not U.S. persons; Coinbase and Robinhood could establish a TSV, but not with the tokens they currently trade on Base and Robinhood Chain.

How much NVDA volume does the 0.25% cap allow for a Tier 1 Tokenized Securities Venue?

Condition F limits each TSV to 75 Tier 1 symbols (those in the S&P 500, Russell 1000, and ETPs—exchange-traded products—with more than $2M average daily volume, per the LULD price band plan) and to "0.25% of the average daily share volume from the previous month" for each, and 250 Tier 2 symbols at 2.5%. Exceeding this requires "pausing trading in that Tokenized NMS Stock for three months" (the first instance requires no action, only that it not be repeated); affiliated TSVs aggregate their volumes for the calculation.

Applied to NVDA using the 20-session average published by stockanalysis.com after the Sep 18 close (134,684,686 shares, identical in the Sep 20 re-reading; the order uses the previous month's average per the consolidated reporting plan, which is not open data, so this is an approximation), the Tier 1 cap is 336,712 shares per day, roughly $74.8M at the Sep 18 close ($222.27). Based on the snapshot, this cap more than doubles the on-chain spot volume for NVDA over a weekend across the four geographies with markets ($32.53M), and a Tier 2 TSV would have ten times more margin ($748.4M per day on the same basis).

What timeline does Order 34-106402 set between Sep 17, 2026, and Sep 17, 2031?

Two gaps in the timeline matter. The order requests comments on whether the exemption should be permanent but sets no deadline in its text. And the publication in the Federal Register, announced in the fact sheet, had still not occurred as of Sep 20, 2026, at 22:03 UTC according to the register's own API, which returns zero documents for both "Tokenized NMS Stock" and "34-106402": this does not affect validity, but it is the reference that typically starts the comment clock in other orders.

What would have to happen for the 15.6% ceiling to break?

The figure falls if any of the following occurs, each verifiable by a document:

1. Before Nov 30, 2026 (roughly 75 days from the order: the 30 + 30 days of notices plus a one-month buffer), a TSV publishes its Notice listing a token from Backed (xStocks or bStocks), Robinhood Europe, Coinbase Onchain SPV, or Ondo Global Markets as a Tokenized NMS Stock; this would mean the SEC accepts certificates or debt as "same rights."
2. Dinari transfers voting rights to holders and documents it; this would add $12.5M, moving the block to 16.0%.
3. An AMM pool appears with more than $1M for SECZ, EXOD, GLXY, FGRD, or Ondo's custodial line; as of Sep 20, 2026, there are zero. Conversely: if the SEC does not count Figure's class as NMS stock, the block drops to $394.1M and 12.9%.

Sources and links: SEC, Rel. 34-106402 (PDF) · SEC, fact sheet · SEC, release 2026-90 · SEC, file 4-927 · SEC, Statement on Tokenized Securities (28-jan-2026) · rwa.xyz, Tokenized Stocks · base.org/stocks (contracts and prospectuses) · Coinbase Onchain SPV, NVDA prospectus (FSRA, 4-aug-2026) · Etherscan, IVV (Ondo Custodial) · Etherscan, NVDAon (Ondo Global Markets) · Ondo, Important notes · Ondo Global Markets · Ondo, official token addresses (CSV) · Ondo, custodial tokenized securities (2-jul-2026) · Binance, bStocks (12-jun-2026) · Backed, legal documentation · Robinhood, mainnet and Stock Tokens · Bitget Wallet, rTokens · Dinari, dShares whitepaper · Securitize, tokenized SECZ (2-jul-2026) · Superstate, Opening Bell · Figure, 8-K (12-feb-2026) · Figure, release from 18-feb-2026 · DexScreener API · stockanalysis.com, NVDA