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Legal

Nature of the collateral

What a Robinhood stock token legally is, who issues it, what you have a claim on, and what you do not.

This is the most important page in this documentation. Everything Fyber does rests on an instrument that most people will assume is a share. It is not.

What it is

A Robinhood stock token is a collateralised tracker certificate, issued in the form of a ledger-based security (Registerwertrecht) under Swiss law, articles 973d and following of the Swiss Code of Obligations.

Four legal systems are involved:

ElementJurisdiction
Issuer — Robinhood Assets (Jersey) LtdJersey
The security itselfSwitzerland
Security AgentZug, Switzerland
Base prospectus approvalLiechtenstein, by the FMA, under Regulation (EU) 2017/1129

The prospectus is passported into thirty EEA jurisdictions, which is why the European Economic Area is not a restricted market for this instrument.

What you have a claim on

The certificate is secured and limited recourse. Your claim is against the issuer, backed by the collateral arrangement the issuer has put in place with its Security Agent. It is a claim on that structure and on nothing else.

Risk

You have no rights over the underlying shares. No ownership, no voting rights, no direct claim on the company, no dividend entitlement other than what the certificate's own mechanism reflects, and no relationship with the issuer of the equity. The tracker follows a price; it does not convey a share.

Risk

The issuer is not regulated, and states so in its own documentation. It was incorporated on 23 October 2025. It has no financial history and no credit rating. Its ability to honour the certificates depends on it and on its collateral arrangement, neither of which Fyber can observe, verify or influence.

Rule R-15.4.1 (1)

The failure mode that matters most to a Fyber user

Risk

The price feed tracks the share. It does not track the token's backing.

If the issuer or its custodian fails, the Chainlink feed keeps publishing the price of the underlying equity — because that is what it is designed to do — while the value of the certificate you hold goes toward zero. The protocol would continue to value your collateral at the share price and would continue to allow borrowing against it.

There is no on-chain mechanism that can detect this. There is no mitigation. It is disclosed rather than solved.


Rule R-15.4.1 (8)

The only partial defences are procedural and sit outside the protocol: whether the Security Agent's backing attestation is published and readable, and how recent it is. Check that yourself before you deposit anything.

The issuer refuses admission to trading

The issuer's own final terms state that it has not arranged for the products to be admitted to trading on any exchange, organised trading facility or DLT trading facility, and that it has not considered and does not consent to such admission.

Risk

This has a consequence for you. Fyber's liquidation and redemption mechanisms create a secondary market in an instrument whose issuer has explicitly declined to have one. Whether that arrangement requires authorisation as a multilateral trading facility under Article 1(5b) of MiFIR is an unsettled question on which no published analysis exists, and it is the largest legal uncertainty in this project. See Risk summary.

How the token behaves technically

  • Balances are raw. The protocol holds them and accounts for them itself, never by reading balanceOf; donations sent to a contract are ignored.
  • A uiMultiplier reflects corporate actions for display. It is never used in valuation, because the price feed already incorporates it. Applying it twice after a 10:1 split would multiply collateral by a hundred.
  • The token exposes oraclePaused(), newUIMultiplier() and effectiveAt(), which the protocol reads to detect corporate actions. A failed read is treated as "paused" — the conservative direction.
  • The token contract is behind a proxy. The protocol snapshots its implementation slot at deployment and reacts automatically to any change: minting frozen 7 days, liquidations suspended 24 hours, an automatic transferability self-test, and shutdown of the branch after 28 days if the test never passes.

Rules R-2.4.1, R-2.4.2, R-2.4.3, R-4.3.9

Risk

Three things about the token remain to be verified on-chain before any code is written, and two of them could invalidate the design: whether the issuer can freeze, blocklist or upgrade balances; and whether balanceOf returns the raw or the multiplier-scaled balance. If the issuer can freeze a vault's balance, nothing in Fyber covers that — not the Closer key, not shutdown, not the Backstop.


Rules R-2.4.4, R-4.3.9

Which tokens Fyber accepts, and which it never will

Five branches are deployed and the registry is closed forever: SPY, QQQ, a third broad-market ETF (VOO or IVV), GLD and IWM. Adding a sixth is impossible; it would require deploying a different protocol.

Never, by design and by the choice made at deployment: leveraged or inverse ETFs, pre-IPO instruments, tokens listed for less than 90 days, and single-name equities. The reason for the last one is concrete: a single-name token has traded on-chain at 4.6 times its official closing price, and no out-of-session pricing rule survives that.

Rules R-12.3.1, R-0.3

How to say this correctly

If you write about Fyber, "tokenized stocks" is acceptable shorthand only if the exact nature is set out somewhere the reader can reach. Describing the collateral as shares, equities or stock is inaccurate and, in most of the jurisdictions where this product is available, a regulated statement.

Last reviewed: 2026-09-07 · Spec v0.4