The SEC Approved All-or-Nothing Contracts on Coinbase's Trading Volume and MARA's Bitcoin Output — Payouts Are $1 or Nothing

On October 13, 2026, the Securities and Exchange Commission approved a Cboe Exchange rule change on an accelerated basis, opening the door to a product American investors have never had before: standardized contracts that pay out based on a number a company reports in its SEC filings, rather than on the price of its stock.

The approval order is Release No. 34-106659, File No. SR-CBOE-2026-061. The product is called a binary KPI option. And buried in the issuer list — 23 companies named in the order — are three names crypto investors know well: Coinbase Global, Marathon Digital Holdings (MARA) and Robinhood Markets.

That means a regulated way to take a position on how much Coinbase traded, how many bitcoin MARA actually mined, or how many funded accounts Robinhood reported — without buying a single share of COIN, MARA or HOOD, and without touching the price of bitcoin itself.

What a binary KPI option actually is

The mechanics in the order are specific. Binary KPI options are European-style (exercisable only at expiration), cash-settled, and carry a fixed exercise settlement amount of $1 with a multiplier of one. Payout is all-or-nothing:

• A call pays $1 if the reported KPI equals or exceeds the pre-set strike level.
• A put pays $1 if the reported figure comes in below it.
• In every other case, the contract expires worthless.

Settlement is not driven by where a stock trades. It is driven by whether a specific financial or operating metric the issuer discloses in an earnings-related filing with the SEC — a Form 8-K, 10-Q or 10-K — meets the threshold written into the contract. Before this approval, Cboe could list binary options only on broad-based indexes and its Magnificent 10 index.

Each issuer gets its own menu of measurable numbers. The order sets out the crypto-relevant ones:

The rest of the list is a roster of large US issuers: Apple, Advanced Micro Devices, Alphabet, Amazon, Bank of America, Citigroup, Ford, Intel, JPMorgan Chase, Meta Platforms, Microsoft, Netflix, NVIDIA, Palantir, SoFi Technologies, Space Exploration Technologies Corp, Super Micro Computer, Target, Tesla and The Walt Disney Company.

Why this matters if you trade crypto

These contracts are not bitcoin-price products, and that distinction is the entire point.

A Coinbase trading-volume contract resolves on how much activity the exchange reported in a given quarter. Coinbase’s Form 10-Q for the quarter ended June 30, 2026 reports revenue of about $1.22 billion, down from the prior year, in a quarter when trading activity stayed heavy across the market. Volume and price correlate, but they are not the same variable — a quarter can deliver falling token prices with heavy two-way volume, or a quiet rally that never shows up in the volume line.

A MARA production contract tracks the operational side of mining: bitcoin produced, energized hashrate, blocks won, total holdings. MARA reported producing 2,422 BTC in the second quarter of 2026 while running an energized hashrate of 70.3 EH/s and holding 35,577 BTC at the end of June, after selling a portion of its stack. Hashrate can expand while bitcoin’s price falls, which is exactly the kind of divergence a stock-price contract cannot express.

A Robinhood contract on funded customers, ARPU or Gold subscribers is a read on US retail participation — the demand side of the market, not the asset side.

None of these pay out on the price of bitcoin. If your view is purely about BTC, this is not that instrument.

The jurisdictional line the SEC just drew

The most consequential part of the order is not the payout schedule — it is the classification argument.

The order reasons that an all-or-nothing payout does not turn an instrument into an event contract or a swap. In its words, the distinguishing feature is “not the shape of the payout curve but rather the nature of the underlying interest.” Where the underlying is a security, or an interest in one, or based on a security’s value, the instrument is a securities option — binary payout or not. The order also notes that absent the swap exclusion these contracts would likely meet the definition of a security-based swap, which is itself a security under the Exchange Act. Either way, the SEC says it has jurisdiction.

Chairman Paul Atkins then went further in his October 13 statement. He described the approved contracts as cash-settled, European-style, standardized options that are NMS securities, subject to exchange rules governing customer accounts, margin requirements, trading halts, auctions, market-maker appointments and quoting obligations, order types and times-in-force.

Then came the sentence that matters for every US crypto venue: the order “does not address — and does not foreclose — CFTC jurisdiction over KPI contracts based on the same underlying KPIs as those contemplated in the approval order structured to fall under the CFTC’s jurisdiction.”

Read that literally. The same corporate metric — say, an exchange’s trading volume — could be packaged two different ways, with the SEC regulating the securities-option version and the CFTC potentially regulating a differently structured version of the same idea. Atkins framed the result as a new spirit of “harmonization, innovation, and investor choice” after what he called decades of jurisdictional turf wars between the two agencies. The boundary is the same one being fought over in the prediction-market litigation that has already reached federal court, where state gaming law, CFTC registration and event contracts collide.

The guardrails built into the approval

US investors get real protections here, and they are specific:

1. Halt procedures. Binary KPI options halt in lockstep with trading halts in the issuer’s stock and its standard options, so nobody is forced to trade against a stale or distorted price. The order also lays out alternative settlement procedures for cases where the reported value is unavailable at settlement time.
2. Position limits. Positions are capped at 25,000 standard option contracts per expiration, and the conversion is 100 binary KPI option contracts to one standard option contract. A hedge exemption is available only to registered market-makers.
3. Disclosure. The Commission designated the contracts as standardized options under Exchange Act Rule 9b-1, and an options disclosure document describing their characteristics and risks has been submitted to the Commission. Customers must receive that ODD and hold an account approved for the options class.

You cannot trade them yet

Approval is not launch. The contracts are to clear through Cboe Clear US (CCUS), and that depends on CCUS receiving approval of its application for temporary registration as a registered clearing agency under Section 17A of the Exchange Act, along with approval or effectiveness of its rule updates to handle binary KPI option clearing. Cboe represented that it will not list the contracts for trading until all applicable CCUS filings and documents are approved or effective.

Cboe also agreed to submit a separate rule filing once CCUS registration lands, because Cboe options normally clear at the Options Clearing Corporation. FINRA may file clarifying changes of its own. As of this writing there is no launch date.

For context on how slow the alternative path is: the CFTC’s own push to build a federal framework for leveraged and margined crypto trading remains at the proposal stage, with TD Cowen analyst Jaret Seiberg warning that the agency’s advance notice of proposed rulemaking may not be finished until early 2028.

What US investors should verify before trading these

1. Broker and approval level. Not every US broker will offer the product, and options trading requires an approved account level. Confirm both before assuming you can trade a given KPI contract.
2. Read the ODD. The payout is binary. A contract that misses the strike by one cent settles at zero — the full premium is the maximum loss, and it is a real possibility, not a formality.
3. Do not assume crypto tax rules. Listed options are not reported like spot digital assets. Do not assume that crypto-specific information reporting such as Form 1099-DA governs these contracts; the reporting of option gains and losses follows the rules for securities options, and you should confirm the treatment that applies to your account with a tax professional.
4. Watch the earnings calendar. Settlement keys off a reported figure from a specific filing. Position size with the reporting date in mind, not with the token chart in mind.
5. Be precise about what you own. A MARA hashrate contract and a MARA share are different instruments with different risk drivers. Treating one as a proxy for the other is how traders get surprised.

For live context on why operating-metric exposure is a distinct animal: on October 15, 2026, bitcoin traded near $80,900, down roughly 3% over 24 hours, after September CPI came in at 3.7% year over year, and roughly $948 million of leveraged positions were liquidated across the market. A company’s quarterly numbers and the token’s price can move in the same direction — or not.

Where international readers can trade spot and derivatives

Notice for international readers: Binance.com does not accept US residents or persons located in the United States. The link below is an affiliate promotion and this publication may receive referral compensation.

Notice for international readers: Bybit restricts access for US persons and residents. Review the platform’s terms of service and confirm your jurisdiction is eligible before trading leveraged products. The link below is an affiliate promotion and this publication may receive referral compensation.

What to watch next

Three developments will determine whether this becomes a live market or a footnote.

First, CCUS clearing registration under Section 17A. Nothing lists until it clears. Second, Cboe’s follow-up rule filing reflecting CCUS clearing, plus any FINRA companion filing — those are the operational milestones between approval and the first ticker. Third, and most interesting for crypto, whether a differently structured version of the same KPI exposure shows up in CFTC-shaped form. Atkins’ statement deliberately left that door open, which means the same trading-volume view could eventually exist on two regulatory shelves — one built on securities law, one built on the Commodity Exchange Act.

For now, the practical takeaway for US investors is narrow and concrete: the SEC has approved the structure, the payout rules are fixed at $1 or nothing, the issuers include three of the largest crypto-facing public companies in America, and the contracts cannot trade until the clearing plumbing is approved. Watch the clearing registration, not the press release.