USDC, Coinbase, Goldman Sachs & Building a Non-Custodial Exchange

Exchanges that hold nothing

Vishal Gupta says his general thesis is that exchanges probably should not be holding assets. True Markets settles to qualified custodians, with assets such as Bitcoin held in bankruptcy-remote accounts in the customer's name, so that if either the custodian or the exchange blows up, customers are fine. Behind the scenes it uses Turnkey for technical wallets.

Settlement is meant to be stablecoin agnostic: True Markets can speak any GENIUS Act-compliant stablecoin, including PYUSD, Gupta says. It currently supports Solana, Base and Hyper EVM, and aims to be chain agnostic and eventually custodian agnostic.

Built for APIs, not apps

Vishal Gupta argues buyers should not have to pay 300 basis points for Bitcoin, and that the industry assumes 5,000 people are needed to run an exchange. About 10 of True Markets's 13 staff are engineers, and he says one and a half people, helped by AI, are building the matching engine, work that once took dozens.

The first customers are systematic traders. True Markets is giving away $1 million of equity through a liquidity program and offers an API, True Markets Gateway, for building front ends on 150 assets plus Bitcoin. Gupta says agents will pick venues on fees and liquidity: "I don't think we'll have the best app, but we'll have the best APIs."

From Goldman to USDC

Vishal Gupta joined Goldman Sachs's electronic trading desk in 2002 and stayed about 10 years, at one point routing about 10% of options volume through his team's technology. He met co-founder Patrick there.

At Circle, as head of USDC, he grew the stablecoin from zero to half a billion in market cap, though it sat at 200 million for a long time. He says DeFi did not work well until USDC showed up, and that it was the first stablecoin FTX integrated as collateral for perps.

Lessons from Coinbase

As head of exchange at Coinbase, Vishal Gupta ran three exchanges and took spot listings from 20 assets to 235. Merging the USD and USDC order books took about two years, he says. He describes Coinbase and Circle as splitting leftover interest revenue effectively 50-50.