I kept coming back to one line from a conference hallway interview this week, the kind that sounds casual until you sit with the math. A trading desk can grow fast enough to bump into a rule that was written to keep growth in a box. That is roughly where stock token volume sits right now for one of the louder retail names in the market. Not a ban. Not a green light either. A ceiling that moves with last month’s share volume, and a pause button that only arms itself after a repeat breach. If you trade tokenized equities, or you are simply trying to figure out whether “stocks on a chain” is a product or a press release, that ceiling is the story.
The company’s crypto lead said, in plain language, that current activity is already high enough to brush some of those limits. He also said the firm is still reading the fine print. Both things can be true. Regulators opened a five-year lane. Operators are discovering the lane has width markings.
Why Stock Token Volume Is Already Testing the New Caps
The exemption landed in mid-September. It gives qualifying venues a route to trade tokenized versions of National Market System stocks through permissioned automated market makers and liquidity pools, without registering as an exchange, if a stack of conditions is met. Five years is a long pilot by Washington standards. It is a short one if your order book is already busy.
Johann Kerbrat, senior vice president and general manager of crypto and international at the brokerage, put it this way during Korea Blockchain Week: the firm is still mapping the parameters. Volume limits exist. Asset-type limits exist. And if you look at the stock token book the company already runs, the numbers are not small. In his words, that book is already pretty high and will hit some of its limits.
There are limitations on the volume, and what type of assets we can tokenize. If you look at our volume on our stock tokens, it is already pretty high and will hit some of its limits.
Johann Kerbrat, speaking at Korea Blockchain Week
I’ve found that executives rarely volunteer a ceiling unless legal has already circled it. So the comment reads less like a boast and more like a scheduling problem. Product wants broader coverage of U.S. stocks and exchange-traded funds. Compliance wants a spreadsheet that stays inside the monthly share-volume bands. Those two desires do not always share a calendar.
What the Exemption Actually Opens
Strip away the slogan and the order does something specific. It lets qualifying venues match tokenized NMS stocks in a controlled onchain setting. Permissioned, not a free-for-all pool. Automated market makers and liquidity pools are allowed as the matching style, which is a real shift from the central-limit-order-book reflex most equity traders still carry in their heads.
The catch, and there is always a catch, is that the token has to behave like the share. Economic rights. Voting and other shareholder privileges. Synthetic price exposure alone does not qualify. That single sentence knocks out a lot of the products that circulated offshore over the last two years, including, awkwardly, some of the structures already live in wallets outside the United States.
Perhaps the most interesting aspect is the time box. Five years is long enough to gather data and short enough that nobody can treat the exemption as a permanent charter. Venues that want to stay in the lane will have to keep proving the product still looks like a share, not a derivative costume.
Two Tiers, Two Very Different Ceilings
The volume rules are not one number. They split along the same logic as the existing Limit Up Limit Down plan, which already sorts stocks by how wild their prints can get.
Tier 1 covers names in the S&P 500 and the Russell 1000, plus certain exchange-traded products. A venue may list up to 75 of these symbols. Trading in each tokenized line is capped at 0.25 percent of that stock’s average daily share volume from the prior month.
Tier 2 is the rest of the eligible NMS universe. The symbol cap rises to 250. The volume cap rises to 2.5 percent of prior-month average daily volume. Wider on paper. Often thinner in real life, because many of those names do not trade like mega-caps.
| Bucket | What sits inside | Symbol cap | Volume cap |
| Tier 1 | S&P 500, Russell 1000, certain ETPs | 75 | 0.25% of prior-month average daily share volume |
| Tier 2 | Other eligible NMS stocks | 250 | 2.5% of prior-month average daily share volume |
Read that table twice. The tight cap sits on the liquid names, which is exactly where retail token demand tends to cluster. People do not line up to tokenize a micro-cap with a sleepy tape. They line up for the household stocks. Those are the ones living under the quarter-percent rule.
A Worked Example, Without the Fantasy Numbers
Say a large-cap stock trades 40 million shares a day on average last month. Tier 1 would allow a venue’s tokenized version to turn over about 100,000 shares of equivalent volume in a day before the threshold is in view. That is not nothing. It is also not a second Nasdaq.
Now flip to a quieter name with 800,000 shares of average daily volume in Tier 2. Two and a half percent is 20,000 shares. Smaller absolute number, looser percentage. A burst of social-media attention can eat that budget before lunch.
I am not claiming those share counts match any specific ticker the firm lists. They are illustrations so the percentages stop feeling abstract. The design choice is clear either way: tokenized flow is meant to be a side channel, not a rival primary market. Anyone selling the exemption as “stocks, but unlimited and onchain” is selling a different document than the one regulators signed.
The Pause Is a Second Strike, Not a First
Here is the mechanic that will matter in practice. A venue that repeatedly exceeds the volume threshold for a given tokenized stock must pause trading in that product for three months. The first breach does not trigger the pause. After that first miss, the venue has to stay inside the line.
So the rule is closer to a warning shot than a trapdoor. Useful, if you are building. Dangerous, if your growth plan assumes you can overshoot, apologize, and keep printing. Three months off a popular token is a long time in retail. Users do not wait around for a symbol to come back. They route elsewhere, or they forget the product existed.
- First breach: no automatic three-month halt, but the venue is now on notice.
- Repeat breach on that same tokenized stock: trading in the product pauses for three months.
- Caps reset against the prior month’s average daily share volume, so a quiet tape shrinks the allowance.
- Symbol counts are separate from volume counts. You can be under the share cap and still be out of ticker slots.
A quiet month in the underlying stock is the sneaky version of this rule. Average daily volume falls, the token allowance falls with it, and a book that felt comfortable in August can look oversized in October. Anyone running these products will need a rolling forecast, not a static limit taped to the wall.
The Volume That Already Exists Offshore
Context matters, because the firm did not walk into September with an empty book. In August, tokenized stock trading volume routed through a major decentralized exchange on the company’s own chain reportedly reached about $1 billion. That figure came from the exchange’s founder, not from a regulator’s filing. Treat it as a signal of activity, not as an audited market-share number.
Those tokens were not offered to U.S. investors. They still are not. The live product sits in a wallet available in more than 120 countries, structured as debt securities issued by a Jersey entity and backed by shares that correspond to the tracked assets. Economic exposure, yes. Direct ownership of the underlying shares, no. Voting rights attached to those shares, no.
That gap is the whole tension. The offshore book proved demand. The U.S. exemption demands a different legal animal. You cannot simply point at last summer’s volume and say the exemption is already full. Different wrapper, different user base, different rights. You can say the demand pattern is real, and that a tight Tier 1 cap will feel tight quickly if U.S. access ever looks like the offshore one.
Why Kerbrat Called the Signal More Important Than the Cap
He did not sound panicked. The line he wanted remembered was that the regulator is willing to work toward tokenization and to study what it is actually good for. From there, the firm intends to keep pushing adoption and a wider set of U.S. stocks and ETFs.
I buy the directional read and I would not buy the comfort. A regulator can want the experiment and still write a cap that bites. Both messages fit in the same order. The industry spent years asking for a lane. It got a lane with a speed limit and a symbol quota. Celebrating the lane while ignoring the speed limit is how products get paused in month four.
Same Rights, or It Does Not Count
Under the framework, a qualifying tokenized NMS stock has to deliver the same rights and privileges as the conventional share. Economic rights are the easy half. Dividends, splits, the price. Voting and the rest of the shareholder bundle are the hard half, because blockchains are good at transferring a token and clumsy at proxy season.
Synthetic products that only hand you price exposure do not qualify. That is not a footnote. It is the line that separates a tracker from a share. Venues that want to list a stock tokenized by an unaffiliated third party also have to notify the company whose shares are being tokenized and give that issuer a chance to object.
Issuer notice is a political clause as much as a legal one. Public companies have spent the last year watching tokens with their ticker appear in wallets they do not control. Some shrugged. At least one did not.
The AMC Argument, and What It Actually Proved
Earlier in the fall, AMC Entertainment’s chief executive, Adam Aron, criticized the brokerage’s AMC-linked token and said his company had not consented. The firm’s reply was that consent is not required under the structure it currently uses. Holders get economic exposure. They do not directly own AMC shares, and they do not receive the votes attached to those shares.
Kerbrat later called much of that criticism a marketing stunt, and said the firm stands behind the legal structure. He also said work on voting rights and in-kind redemption was already underway before the public spat. In-kind redemption, he noted, was on the table at the company’s July 1 event in London.
You can hold both thoughts. A CEO using a token launch as a megaphone is not a new genre. A product that tracks a company without offering the company’s shareholders’ rights is also a real design choice, and it is exactly the design the new exemption refuses to bless. The dispute did not invent the gap. It advertised it.
Some of the criticism from the AMC chief executive, if you look at it, is mostly a marketing stunt. We stand behind the legal structure of our systems.
Johann Kerbrat, on the issuer dispute
In my experience, “we stand behind the structure” is what you say when the structure is lawful and still about to be rebuilt. Kerbrat and chief executive Vlad Tenev had already said, earlier in September, that voting rights and in-kind redemption are coming to the stock tokens. That is the rebuild. Whether it arrives in time to fit the exemption, and whether it arrives for U.S. users at all, is the open question.
What Voting Rights Would Change for a Holder
Today, a holder of the offshore token is closer to a creditor of a Jersey issuer than to a shareholder of the tracked company. The token is backed by shares. Backed is not the same word as owned. If the issuer failed, or if the custody chain snagged, the token’s promise would be tested in a place most retail users have never heard of.
Voting rights pull the product toward the share. In-kind redemption pulls it further. If you can hand the token back and receive the actual stock, the peg stops being a marketing sentence and becomes an arbitrage. That is how serious tokenized funds keep their price honest. It is also operationally annoying: transfer agents, broker-dealers, settlement windows, corporate actions that do not care about your chain’s block time.
- Price exposure only: easy to ship, does not qualify for the exemption.
- Economic rights plus voting: closer to a share, harder to operate at proxy time.
- In-kind redemption: the peg becomes enforceable, and the back office gets real.
- U.S. eligibility: still a separate gate, even if the wrapper is finally right.
None of those steps is a tweet. Each one is a project. The firm’s July rollout, when it launched its own chain next to products meant to move traditional assets onchain, was the starting gun. September’s exemption is the rulebook. The volume comment is the first sign the rulebook might already be tight.
Who the Caps Are Really For
It is tempting to read every limit as a gift to incumbents. Sometimes that reading is fair. Here, the design also protects the underlying auction. If a tokenized side market could freely print a large fraction of a stock’s daily volume, you would get two prices, two closes, and a mess at the open. Quarter of a percent on Tier 1 is small enough that the primary tape should still be the tape.
The cost of that caution lands on the venue. A popular token can hit the ceiling while the stock itself is having a normal day. Users will experience that as “why can’t I buy more,” not as “market-structure hygiene.” Support teams should start writing that answer now.
Rough mental model for a venue: Symbol slots are scarce on Tier 1 (75). Volume room is scarcer on liquid names (0.25%). First miss is a warning. Second miss is a three-month dark period. Prior-month ADV is the moving target.
If I were sizing a launch list, I would not fill all 75 Tier 1 slots on day one. I would keep a reserve for names that suddenly matter, and I would watch the five or six tokens that will eat the allowance. Concentration is the risk. A book can be “fine” in aggregate and illegal on a single line.
Permissioned Pools Are Not the Casino Version
The matching model in the exemption is worth a pause. Permissioned automated market makers and liquidity pools are a long way from the anonymous pool most crypto traders picture. Access is gated. Participants are known to the venue. That is how you get surveillance, how you keep the token from leaking into a wallet the exemption does not cover, and how you argue to a regulator that this is not an unregistered exchange wearing a new hat.
It is also how you disappoint a slice of the audience that wanted stocks in the same interface as a meme coin at 2 a.m. Permissioned does not mean joyless. It means the experiment is being run with a sign-in sheet. Anyone who wanted the other version already has it, offshore, and without the shareholder rights.
What “Broader Coverage” Can Honestly Mean
Kerbrat said the firm will keep pushing broader coverage of U.S. stocks and ETFs. Under the caps, broader does not mean the whole market. Seventy-five Tier 1 symbols is a curated list, not the S&P. Two hundred fifty Tier 2 symbols is a large menu and still a slice of the NMS universe.
ETFs complicate the menu in a useful way. A single tokenized fund can deliver a basket, so a venue that is short on symbol slots can still offer sector exposure. The volume cap still applies to that product’s own average daily volume, which for a giant fund is enormous and for a niche fund is not. Slot strategy and volume strategy are different jobs. Most launch plans treat them as one.
Would I expect the first U.S. list, if it comes, to look like the offshore list? Probably not. The offshore list was built for demand. A U.S. list under this order has to be built for the cap, the rights test, and the issuer-notice step. Demand still matters. It just does not get the last word.
Meanwhile, Crypto Perps Are Walking in the Other Door
While the stock-token paperwork is still being read, the same firm is lining up a different onchain product for U.S. customers. On September 29 it said eligible U.S. users will get crypto perpetual futures across eight assets: Bitcoin, Ether, Solana, XRP, Dogecoin, Cardano, Chainlink, and Hyperliquid.
Leverage is not uniform. Bitcoin and Ether contracts are slated for up to 10x. The other six sit at up to 3x. Kerbrat said the firm picked those levels itself. Raising them later is undecided, and will depend on how people actually trade and how much liquidity shows up after launch.
That is a grown-up answer, and a rare one. Leverage is the easiest dial to turn for a headline and the hardest dial to turn back after a bad weekend. Waiting on real liquidity before touching it is the correct sequence. Whether the desk sticks to that sequence once competitors advertise a higher number is the test.
Clearing, Funding, and a Very Small Fee
The perps plan uses a global waterfall clearing system. Kerbrat contrasted that with some competing U.S. offerings, and he flagged funding math as another difference. Funding rates on this venue will be recalculated continuously, rather than on the 15-minute clock several platforms still use.
Continuous funding sounds technical. For a holder it is simple. The carry you pay or receive does not sit still for a quarter of an hour while the spot-perp basis moves. In a calm market the difference is noise. In a squeeze it is the difference between a funding print you can see coming and one that updates under your feet.
Fees start at 0.01 percent through the end of 2026, with the contracts offered by the firm’s derivatives unit through Bitstamp infrastructure. A fee that low is a customer-acquisition price, not a steady-state price. Anyone modeling the business should assume it does not last forever. Anyone trading it should enjoy it while it does, and should not build a strategy that only works at one basis point.
| Piece of the perps plan | What was described |
| Assets | Bitcoin, Ether, Solana, XRP, Dogecoin, Cardano, Chainlink, Hyperliquid |
| Leverage | Up to 10x on Bitcoin and Ether, up to 3x on the other six |
| Funding | Recalculated continuously, not on a 15-minute cycle |
| Clearing | Global waterfall structure |
| Fee | 0.01 percent through the end of 2026 |
| Wrapper | Derivatives unit, Bitstamp infrastructure |
What Is Not Coming, at Least Not Yet
Kerbrat did not hand out a 2027 derivatives menu. Europe has shown interest in commodity and ETF perpetual futures. He said there are no plans to announce single-stock perpetual futures for U.S. customers. The firm already lets people build multi-leg options strategies, and he pointed at that toolkit when asked how traders can take complex equity views without a single-stock perp.
That answer is doing quiet work. A single-stock perp is the product equity-token fans eventually ask for, because it skips ownership, skips votes, and skips the exemption’s rights test. Declining to announce it for the U.S. keeps the stock conversation on the token-and-rights track, where the new order actually lives. It also avoids inventing a second equity derivative while the first equity token is still being rebuilt.
Any later increase in crypto leverage, he said, comes only after the firm sees how customers use the contracts and how liquidity develops. File that next to the stock-token comment. One business is worried about having too much volume. The other is waiting to see whether volume shows up. Same company, two clocks.
Two Products, One Retail Brand
It is easy to treat stock tokens and crypto perps as separate press cycles. For the user they will sit in the same app, next to options, next to the cash account, next to whatever yield product is in fashion that quarter. That proximity is the strategic point. A retail brand that already owns the Monday-morning stock trade wants the weekend crypto trade, and it wants a version of the stock trade that can move when the primary market is shut.
After-hours desire is the honest use case for tokenized equities. Not “replacing the exchange.” A wallet that can transfer a claim on a share at 11 p.m. on a Sunday, with redemption back into the real share when the market opens, is a product people will pay for. A wallet that offers a price feed and a logo is a product people will try once.
The exemption is built for the first version, with training wheels. The live offshore token is closer to the second, and the firm has said the wheels are coming. Until redemption and votes are real, I would describe the current token as a tracker with a custody story, not as a share.
Risks the Caps Do Not Solve
A volume ceiling does not fix issuer credit risk on a debt-wrapped token. It does not fix smart-contract risk on the chain. It does not fix the gap between a token price and the underlying print when liquidity on the pool is thin. It does not fix what happens to a holder if the Jersey issuer, the custodian, or the transfer path has a bad day.
Nor does it fix behavior. Retail flow clusters. A handful of meme-adjacent stocks can absorb a venue’s entire Tier 2 budget while the serious names sit quiet. The three-month pause then hits the exact product the timeline is shouting about. That is a communications crisis wearing a compliance badge.
- Wrapper risk: debt security versus direct share ownership.
- Peg risk: price exposure without reliable in-kind redemption.
- Cap risk: a popular line goes dark for a quarter after a repeat breach.
- Calendar risk: prior-month volume shrinks the allowance without warning the group chat.
- Rights risk: votes that exist on paper and fail in a proxy rush.
None of this makes the experiment pointless. It makes the experiment a market-structure project, which is less fun to post about and more important to get right. The firms that treat the exemption as a marketing window will be the ones explaining a pause. The firms that treat it as an engineering spec might still be listing in year five.
How a Careful User Should Read the Next Headlines
When the next update lands, a few questions sort the signal from the slogan. Are U.S. users actually eligible, or is this still an offshore wallet story? Does the token carry votes, or a promise of votes? Can you redeem in kind, and on what timetable? Which tier is the symbol in, and what was last month’s average daily volume? Has the line already logged a first breach?
If a headline says “unlimited tokenized stocks,” it is wrong. If it says “the regulator banned stock tokens,” it is also wrong. The order is a conditional lane. The company’s own crypto lead just said the car is already near the guardrail on volume. That is the sentence to keep.
A Note on Leverage, Because It Will Get Mixed In
Stock tokens and 10x Bitcoin perps will be discussed in the same breath, because they share a brand and a week on the calendar. They do not share a risk. A token meant to track a share, even a flawed one, is a directional claim on a company. A perpetual with continuous funding is a derivatives position that can liquidate you while you sleep. The 3x sleeve on the smaller assets is still enough to end an account if the move is violent and the funding flips.
The fee holiday through 2026 will pull people in. Fine. Just do not let a one-basis-point headline do your position sizing. Liquidity after launch is the variable Kerbrat himself flagged. Thin books and high leverage are an old couple. They do not get kinder because the app is familiar.
Where This Leaves the Onchain Equity Pitch
The pitch, for years, was simple. Put the share on a chain, trade it anytime, move it like any other token, keep the economic deal. The September order accepts a narrow version of that pitch and rejects the loose one. Same rights. Limited symbols. Limited volume. Permissioned matching. Issuer notice if someone else tokenizes your stock. A five-year clock.
The brokerage’s offshore book already showed that people will trade the loose version at size. A billion dollars in a month on one route is not a science project. It is also not, by itself, eligible for the U.S. lane. Closing that gap means voting, redemption, and a willingness to throttle the very activity the firm is proud of. Kerbrat’s comment is the throttle warning.
I keep thinking the useful outcome is boring. A short list of tokens that really do redeem into shares, that really do pass votes through, that stay under a quarter of a percent on the big names, and that do not pretend to be the market. If that is what year one looks like, the exemption did its job. If year one looks like the offshore book with a new disclaimer, the pause rule will do the job instead.
What to Watch Between Now and the First Real Test
Watch the rights upgrade, not the symbol count. Voting and in-kind redemption are the bridge from the current debt wrapper to something the exemption can recognize. Watch whether U.S. users are included, because a global wallet and a U.S. lane are still different products. Watch single-name volume against prior-month average daily volume, especially on the household stocks that will live in Tier 1.
Watch the perps launch as a separate scorecard. Eight assets, two leverage bands, continuous funding, a waterfall clear, a promotional fee. If liquidity is deep and liquidations stay orderly, the leverage conversation can reopen. If it is not, the 10x cap will look wise in hindsight. Europe’s interest in commodity and ETF perps can stay a European story until someone is ready to say otherwise.
And watch the tone from issuers. The AMC episode will not be the last time a chief executive discovers a token with the company’s ticker. Notice-and-object, under the exemption, gives issuers a formal seat. Some will use it to block. Some will use it to negotiate how votes and redemption actually work. That negotiation, more than any conference quote, will decide which names ever make the list.
Practical filter: rights + redemption + tier cap + user eligibility. Miss one, and the headline is ahead of the product.There is a version of this story where the caps prove too tight and the industry spends the five years lobbying for a wider lane. There is a version where a few venues live comfortably inside the bands and the data convinces regulators to extend the idea. The company’s own description, right now, sounds closer to the first version on volume and the second version on intent. Both can be on the table until the first repeat breach, or the first clean quarter, tells us which one is real.
For anyone holding these tokens today, outside the United States, the near-term change to care about is not the cap. It is whether voting and in-kind redemption show up in the product you already own, and on what terms. For anyone waiting on a U.S. version, the cap is the plot. Seventy-five names. A quarter of a percent. A warning, then a three-month silence. That is the shape of the experiment, whether the marketing prefers a rounder story or not.
