The Securities and Exchange Commission published order 34-106402 on 17 September, and the document Robinhood's stock rose on lets a tokenized securities venue trade 75 large-cap symbols at most, each capped at 0.25% of that stock's average daily share volume during the prior month. Counts and volumes aggregate across affiliated venues. Neither tokenized-stock product Robinhood sells today meets the definition the order exempts.
Footnote 72 puts an average Tier 1 name at 7,557 shares a day
Tier 1 follows the Limit Up-Limit Down plan: the S&P 500, the Russell 1000 and eligible ETPs. A venue's volume in a token, added to that of every affiliated venue, is measured against the real stock's consolidated tape, and a repeat breach pauses the venue and its affiliates in that symbol for three months.
Scale comes from the order. Commission staff put 2025 daily weighted-average volume at 3,022,668 shares for Tier 1 stocks. So 0.25% × 3,022,668 = 7,557 shares a day on an average Tier 1 name, and × 75 names = 566,750 shares for the whole venue.
Shares are not dollars, and a venue would list the expensive names. Nvidia traded 121,515,886 shares on 31 August at $220.78: 121,515,886 × $220.78 = $26.83 billion, and 0.25% of it = $67.07 million in one name in one session. That is not the prior-month average the condition uses, but it sizes the gap between share caps and dollar caps.
The whole venue tops out near $750 million a day
No public tape carries prior-month dollar volume for the 75 highest-dollar Tier 1 names, so anyone quoting an official ceiling has assumed it. Assume the 75 average $4 billion a day — above a typical S&P constituent, far below Nvidia's $27 billion — and 0.25% × 75 × $4bn = $750 million a day for the venue and its affiliates together. Robinhood's customers traded $335 billion of equity notional in August, $16.0 billion a day over 21 sessions, so the ceiling is 4.7% of what Robinhood already does daily.
R40 arithmetic on the order's 0.25% Tier 1 condition
| Assumed dollar ADV | Venue ceiling a day | Fair value |
|---|---|---|
| $2bn | $375m | $94.58 (+$0.16) |
| $4bn | $750m | $94.74 (+$0.32) |
| $8bn | $1,500m | $95.06 (+$0.64) |
Ceiling is 0.25% x 75 symbols x the assumed average dollar volume, and belongs to the venue and every affiliated venue together — 2.3%, 4.7% and 9.4% respectively of the $16.0bn a day Robinhood's customers traded in August. Fair value adds the full quarterly notional (ceiling x 63 trading days) to the equities line of our HOOD model at 956 units and $134,937 per billion, against a published base of $94.42. No public tape gives prior-month dollar volume for the 75 highest-dollar Tier 1 names, so the assumed figure is ours and none of this is disclosed.
Capturing all of it moves fair value 32 cents
$750 million × 63 trading days = $47.2 billion of quarterly notional. Our HOOD model drives equities at $134,937 of revenue per billion traded against $956 billion in the June quarter. Hand Robinhood the whole ceiling — every dollar, captured by one broker — and units run 956 to 1,003, fair value $94.42 to $94.74. Thirty-two cents, on $6.4 million of quarterly revenue: 0.49% of the $1,308 million of net revenues reported for the June quarter.
Treating that as additive is already generous: a Robinhood customer buying a tokenized Apple share is most plausibly moving flow that goes through Robinhood today. Our tokenization line carries the bigger number. It opens in 2027 Q3 because US tokenized equities needed a regulatory answer that did not exist, and part of one now does. Pull it forward four quarters and fair value reaches $96.97 — $2.55, eight times the volume ceiling.
A debt security and a derivative are what the definition excludes
"Tokenized NMS Stock" covers a stock tokenized by its own issuer or by an unaffiliated third party. It excludes "securities where a third party issues a crypto asset representing its own security that provides synthetic exposure to an underlying security, such as a tokenized linked security or a tokenized security-based swap."
Robinhood's own descriptions sit inside that sentence. Stock Tokens are "tokenised debt securities issued by Robinhood Assets (Jersey) Limited that provide economic exposure to underlying securities but do not grant investors any legal or beneficial rights in, or against the issuer of, those underlying securities." Classic Stock Tokens are "derivative contracts between you and RHEU." Neither is sold to US persons.
A second condition shuts the same door: a venue must verify the token conveys the same interest, dividends, votes and residual share on liquidation as the stock. Chairman Paul Atkins described tokens carrying "the same rights and privileges as the traditional securities, including rights to receive dividends and exercise voting rights." Robinhood's chain documentation handles dividends through "an onchain multiplier, which adjusts the shares-per-token ratio" — a price adjustment where the condition asks for the company's dividend. The prospectus half sits in our 14 September piece; today turned full rights into a precondition for US trading.
That reading is ours, and one filing overturns it: a venue notice naming Robinhood as tokenizer of record for US shares, dividends and votes passed through, and the exclusion stops applying. The caps would still bind — they are the sixth of ten questions the order puts out for comment, and raising Tier 1 tenfold, to 2.5%, turns 32 cents into $3.23.
Nobody has started the 30-day clock
A venue must post a plain-English notice 30 calendar days before operating and email the Commission within one business day; for a token it did not issue itself it owes the underlying company 30 days' notice, and that company may object and block it. Relief runs to 17 September 2031 and names no firm. Robinhood traded at $107.56 at 2:29pm New York time, up 3.0% on the $104.42 close and below its open, and has not said it will run one.
Every condition here — the exemptions, the symbol and volume limits, the tiers, breach mechanics, the synthetic-exposure exclusion, the same-rights test, the notice and objection requirements, the 2031 expiry and the 3,022,668-share staff average — is SEC order 34-106402 (File 4-927) of 17 September 2026 and its fact sheet; the rights quotation is Chairman Atkins' statement that morning. The order sets no comment deadline. August volumes are Robinhood's operating data of 10 September, the instrument wording and dividend multiplier its newsroom and chain documentation, revenues the June-quarter report. The 31 August figure is one session's most-active print; price and close are stockanalysis.com, timestamped above. Ours: the $4 billion assumption, the venue ceiling and every fair-value output.
