The RWA tokenization sector is approaching $40 billion in on-chain value. The DTCC is running live institutional trades. BlackRock's BUIDL fund has $2.56 billion in assets on nine blockchains. Robinhood has tokenized 190+ US stocks available in 120+ countries. The sector's infrastructure is real, operational, and growing.
Americans are largely watching it happen from the sidelines.
97% of tokenized real-world asset value is currently inaccessible to US retail investors. Not because the technology does not exist. Not because the products are not built. Because the regulatory framework that would allow compliant distribution to American retail has not been written.
The Specific Products Americans Cannot Access
Robinhood Stock Tokens. Robinhood has tokenized Apple, Nvidia, Microsoft, Amazon, Tesla, SpaceX, and 185+ additional US stocks. It made them available in 120+ countries. Its 35 million US users cannot access them. The SEC has not approved the debt-security structure for US retail distribution. The product exists. The regulatory pathway does not.
Ondo USDY and OUSG. Ondo Finance's yield-bearing stablecoin backed by US Treasuries — earning approximately 4.5% annually in US dollar terms — is available to eligible investors globally. It is explicitly unavailable to US persons. The same Treasury yield that a Fidelity money market fund provides to any American with a brokerage account is structured differently enough on-chain to require regulatory treatment that has not yet been established for retail distribution.
Franklin Templeton BENJI. Available on Stellar, Polygon, Avalanche, Aptos, Base, and other chains. Minimum investment exists; US retail access is restricted to qualified purchasers in some structures.
Most tokenized private credit. Goldfinch, Centrifuge, and Maple Finance offer tokenized private credit yielding 8–15% annually. US retail investors are excluded from most structures through Regulation S (which restricts US person participation in offshore offerings) or Regulation D (which limits participation to accredited investors — roughly 12% of US households).
Why This Happened — The Regulatory Architecture
The US securities regulatory framework was built for a world where financial instruments are either publicly registered securities (with full SEC disclosure requirements, prospectus obligations, and ongoing reporting) or private offerings limited to sophisticated investors. Tokenized RWA products do not fit cleanly into either category — they are novel structures that combine elements of both, often with additional complexity from the on-chain layer.
Rather than creating new categories, US regulators have applied existing frameworks that were not designed for tokenized assets. The result is a compliance environment where issuers face a choice: register fully with the SEC (expensive, time-consuming, uncertain outcome for novel structures), use Regulation D to limit to accredited investors only (blocking 88% of US households), or structure the offering to exclude US persons entirely under Regulation S.
Most chose the third option. The result is a market where American investors are explicitly excluded from the most innovative financial products being built on American infrastructure by American companies using American financial assets as the underlying collateral.
The Accreditation Gap
The accredited investor threshold — $200,000 in annual income ($300,000 jointly) or $1 million in net worth excluding primary residence — was designed in 1982 to identify investors sophisticated enough to evaluate risk without full SEC-mandated disclosure. It has not been meaningfully adjusted for inflation since. In 2026 dollars, the 1982 income threshold would be roughly $640,000.
The practical effect: approximately 12% of US households qualify as accredited investors. The other 88% — including many financially sophisticated, college-educated, employed Americans who simply do not earn above the threshold or have not accumulated the required net worth — are treated as requiring protection from products their wealthier neighbors can freely access.
This is not a theoretical critique. A 35-year-old software engineer earning $150,000 in San Francisco — above median household income, with advanced financial literacy — cannot access Robinhood Stock Tokens or Ondo USDY. A retired dentist in Alabama with a $1.2 million investment portfolio can. The accreditation framework protects by asset level, not by sophistication. And it excludes most of the people tokenization's proponents say the technology is designed to reach.
What the CLARITY Act Would and Wouldn't Fix
The CLARITY Act, awaiting a September 15 procedural vote in the Senate, would create a comprehensive digital asset market structure framework. Its passage would be significant for institutional participants and for the broader legal clarity of the sector. But it would not automatically solve the retail access problem.
The CLARITY Act addresses market structure — which digital assets are securities, which are commodities, what disclosure requirements apply, how exchanges must be registered. It does not create a new investor access framework. The accredited investor threshold is in the Investment Company Act and the Securities Act, not in market structure law. Changing it requires separate legislation or SEC rulemaking.
What CLARITY Act passage would enable: clearer rules for compliant tokenized product distribution, removal of the regulatory ambiguity that pushes issuers toward Regulation S exclusion of US persons, and a framework within which the SEC could more readily issue guidance on retail-accessible tokenized securities. The CLARITY Act is a prerequisite for fixing the 97% problem. It is not itself the fix.
The Inequality Dimension
Larry Fink, in his 2026 Annual Chairman's Letter, named the access problem explicitly: stock market wealth has grown 15 times faster than median wages since 1989. A third of Americans do not have $500 for an emergency. He positioned tokenization — through fractional ownership and wallet-based access — as a mechanism for broader economic participation.
The irony is acute. The technology that Fink and others say will democratize finance is currently most accessible to the same institutional investors and wealthy individuals who have always had access to sophisticated financial products. The democratization thesis requires retail access. Retail access requires regulatory clarity. Regulatory clarity requires political will. And political will requires the September 15 vote to go a certain way, followed by years of additional rulemaking.
The bridge Fink described — being built from both sides of the river — has the traditional finance side well underway. The retail access side has not yet broken ground.
→ CLARITY Act September 15 — what the vote actually decides
→ Robinhood CEO calls on the SEC to fix this
→ The global RWA race — why 120 countries have access Americans don't