Apollo Diversified Credit Securitize Fund (ACRED)

ACRED is a token for a share in a British Virgin Islands company that owns one thing: Class I shares of Apollo Diversified Credit Fund, a registered interval fund that lends to companies and against assets. The company, Securitize Tokenized Apollo Diversified Credit Fund, Ltd., was formed in 2024 and sells under Rule 506(c) to accredited investors only. It relies on the section 3(c)(1) exclusion, so it may never have more than 100 beneficial owners; its February 2026 Form D reported 26 investors and $110.9 million sold. Securitize is placement agent, transfer agent, and fund administrator, and its page sets a $50,000 minimum. The token cannot be more liquid than the fund beneath it. Apollo’s fund offers to buy back at least 5% of its shares once a quarter. ACRED takes redemption requests monthly inside that quarterly notice period and pays only after the underlying fund pays, with no promise of a full redemption. Money goes in at once, through a USDC swap; it comes out on Apollo’s quarterly schedule, prorated if too many holders ask at the same time. The wrapper adds costs the fund itself does not carry. Securitize estimates the feeder’s own expenses at 0.72% a year on top of the underlying Class I expenses of 3.34%, and it reports a further 0.50% lost to US withholding tax on the fund’s distributions, because the holder of the fund shares is a foreign company. On Ethereum one ordinary Securitize key owns the ACRED contract, the same key that owns the STAC and VBILL contracts; the contract can be upgraded, paused, and made to lock an investor or take back tokens. On Solana one address holds mint, freeze, and permanent-delegate power. The assessment is adverse because ACRED loses the comparison with the fund it holds. An advisor can buy Apollo Diversified Credit Fund directly: it has a public prospectus, sits under the Investment Company Act, takes $2,500 in Class A, and offers the same quarterly repurchases. ACRED wraps those shares in an unregistered offshore company, limits it to accredited investors and 100 owners, and adds a fee layer, a tax drag, and a single key. It reopens if a tokenized share class is issued by the registered fund itself, or if the feeder’s costs and liquidity match holding the fund directly.

Review triggers: events that reopen the verdict
• Apollo Diversified Credit Fund issues a tokenized share class itself, under its registered prospectus
• The feeder’s expenses and withholding drag fall to the cost of holding Class I directly, or the feeder moves onshore
• The private placement memorandum becomes available and changes the investor class, minimum, gates, or redemption terms read here
• Apollo Diversified Credit Fund cuts a quarterly repurchase offer below 5%, prorates a tender, or delays payment past the posted date
• The ACRED owner key, proxy implementation, compliance service, or lock manager on Ethereum changes, or the Solana mint, freeze, delegate, or hook authority changes
• The feeder nears 100 beneficial owners or leaves the section 3(c)(1) exclusion
• Any loss of principal, NAV markdown above 2% in a month, or token incident

Watched nightly: a warning on its venues or files, or a cited document that changes, reopens the memo. The first confirmation is due 2026-12-23.

The research file

What the holder owns

The holder owns participating shares of a BVI business company (SEC CIK 2056038). Securitize’s own August 2026 prospectus calls these tokens “non-voting, non-redeemable participating shares issued as part of the funds’ respective share capital”: the holder has no vote and no right to demand cash, and exits only through the repurchases the company offers. The company’s one asset is Class I shares (CRDIX) of Apollo Diversified Credit Fund, a Delaware statutory trust registered as a closed-end fund and run as an interval fund. Apollo Capital Credit Adviser is its adviser and Apollo Credit Management its sub-adviser.

The fund puts at least 80% of managed assets into debt: corporate direct loans, asset-backed loans, performing and dislocated credit, and CLO tranches of any seniority. It borrows, and may borrow up to a third of managed assets; the fee table assumes borrowing of about 15% of net assets. Most of the private loans have no market price and are valued by the fund’s valuation designee with outside valuation firms, as Level 3 assets. The fund warns that distributions may include a return of capital. The token changes who keeps the register; it does not change any of this.

Who may buy, and how many

The Form D/A filed 2026-02-12 claims Rule 506(c) and section 3(c)(1) and reports no non-accredited investors. Rule 506(c) lets the fund advertise, but every buyer must be an accredited investor whose status the issuer has taken reasonable steps to verify; Securitize’s onboarding asks for an accreditation application. Section 3(c)(1) spares the company from registering as an investment company only while it has 100 or fewer beneficial owners. For an advisory practice this is a hard ceiling: one firm’s households could take much of the 100 places. The Form D states a $0 minimum; Securitize’s page shows $50,000. The private placement memorandum, which the page names as the controlling document, was not available to this review, so the account types it admits and its gates are unread.

How money gets out

Apollo Diversified Credit Fund offers once a quarter to buy back no less than 5% of its shares at NAV; that promise is a fundamental policy only a shareholder vote can change. Holders get 21 to 42 days’ notice before the request deadline, the price is set within 14 days after it, and payment follows within seven days of pricing. If requests exceed the offer, the board may take up to 2% more, and past that it buys pro rata and the rest waits a quarter. Apollo’s prospectus names feeder vehicles as one cause of this: when a feeder’s own investors ask out, the feeder tenders in bulk and can push an offer into proration.

ACRED sits on top of that schedule. Securitize says monthly redemptions are available during a quarterly notice period and that full redemptions are not guaranteed; proceeds come in USDC or USDG once the underlying fund has paid the feeder. Entry is faster than exit: new money can buy ACRED at once through a smart-contract swap with USDC, or by wire into a monthly close. Securitize’s page adds that secondary trading “is not guaranteed and may be limited by regulatory transfer restrictions.” Securitize itself holds ACRED and sACRED, a receipt token, as collateral for loans to its users, so some supply sits in lending positions that would unwind in the same queue.

What the wrapper costs

Apollo’s prospectus puts Class I total annual expenses at 3.50% before and 3.34% after the adviser’s waiver: a 1.50% management fee, 0.66% of other costs, and 1.33% of interest on borrowing. Securitize’s page repeats the 3.34% as underlying expenses and adds the feeder’s own estimated expense ratio of 0.72%, covering its management fee and operating costs, and a withholding tax impact of 0.50% as of August 31, 2026. The withholding arises because the fund pays its distributions to a BVI company, a foreign shareholder, and US tax is withheld at the source before the money reaches the token holder. A US taxable client who owned CRDIX directly would not bear that drag. Owning a foreign company whose only income is fund distributions may also bring the US passive foreign investment company rules into play for such a client; that is a question for the client’s tax adviser before any purchase. Securitize reports a one-year net return of 5.46% to August 31, 2026 and assets of $95.58 million.

Who controls the token

On Ethereum, ACRED is a Securitize DS Protocol token at 0x17418038ecf73ba4026c4f428547bf099706f27b, an upgradeable proxy. Its owner, 0x59c1eacec450c57dcb9b8725d0f96635c2b676ee, is an ordinary single-signature address, and the same address owns the STAC and VBILL contracts, so one Securitize key controls the upgrade path of three funds. The owner issues tokens. The verified implementation lets Securitize pause transfers, issue tokens without compliance checks, burn, and upgrade; every transfer passes a compliance check against Securitize’s registry, and the linked lock manager can lock an investor’s tokens in place.

On Solana, ACRED is a Token-2022 mint at FubtUcvhSCr3VPXEcxouoQjKQ7NWTCzXyECe76B7L3f8, whose metadata points at metadata.securitize.io. One address, Fr3R4632…YbH, is the mint authority, the freeze authority, and the permanent delegate, and a transfer-hook program gates every transfer. The launch named Aptos, Avalanche, Ethereum, Ink, Polygon, and Solana, and Securitize later added Sei with Wormhole bridging; Securitize has not published contract addresses for the other chains, so they are unread. These powers let Securitize, as transfer agent, correct the register; they also mean the register is only as safe as that key.

Record

Apollo and Securitize announced ACRED on 2025-01-30. No loss of principal, suspended repurchase, prorated tender at the feeder, or token incident was found in the Securitize and Apollo documents reviewed. That is a limited finding: the fund has not been through a credit cycle in token form, and a marketing page is not an incident log. The January 2025 launch release said redemptions ran at daily NAV; the current page says quarterly, and the current page governs this memo.

Comparison and decision

Against BUIDL and VBILL, the other Securitize funds in this registry, ACRED holds private credit, not Treasury bills, and its exit is quarterly, not daily; it cannot sit in a cash sleeve. Against STAC, it trades senior CLO tranches for a mix that includes direct loans and leverage. The decisive comparison is with its own underlying fund. Bought directly, Apollo Diversified Credit Fund is registered, open to non-accredited clients ($2,500 in Class A, which carries a sales load of up to 5.75%; Class I has no load and lists a $1,000,000 minimum that the fund may waive), publishes a prospectus, and has the same quarterly liquidity. ACRED keeps the fund’s risks and liquidity and adds an offshore company outside the Investment Company Act, an accreditation test, a 100-owner cap, 0.72% of feeder expenses, 0.50% of withholding, and a single key over the register. That is a lost comparative review, recorded as an adverse assessment with a reopen condition. An accredited client may legally buy it, which is why model-client eligibility is recorded separately as eligible with conditions.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Securitize: ACRED primary-market page · primary · accessed 2026-09-23
  Supports: $50,000 minimum, BVI domicile, quarterly redemptions, USDC and USDG ramps
• Securitize: ACRED primary-market page content (Builder.io content API behind the page) · primary · accessed 2026-09-23
  Supports: 0.72% feeder expense ratio, 0.50% withholding tax impact, 3.34% underlying expenses, monthly redemptions inside a quarterly notice period, instant USDC subscription, accreditation application, secondary trading not guaranteed
• SEC EDGAR: Securitize Tokenized Apollo Diversified Credit Fund, Ltd., Form D/A filed February 12, 2026 · primary · accessed 2026-09-23
  Supports: BVI business company formed 2024, Rule 506(c), section 3(c)(1), no non-accredited investors, $0 minimum on the form, 26 investors, $110.9M sold
• SEC EDGAR: Securitize Holdings prospectus, Form 424B3, filed August 7, 2026 · primary · accessed 2026-09-23
  Supports: non-voting, non-redeemable participating shares, sACRED receipt tokens, ACRED held as loan collateral
• Apollo Diversified Credit Fund prospectus (April 29, 2025) · primary · accessed 2026-09-23
  Supports: interval fund, quarterly repurchase of at least 5%, repurchase notice, pricing and payment periods, proration and feeder vehicles, Class I expenses, leverage, Level 3 valuation, Class A $2,500 minimum
• Apollo and Securitize: launch release (PR Newswire, 2025-01-30) · primary · accessed 2026-09-23
  Supports: launch chains, Securitize as transfer agent and fund administrator, daily-NAV redemptions at launch
• Verified ACRED implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
  Supports: compliance check on transfer, pause, burn, issueTokens, upgradeToAndCall
• ACRED Solana mint metadata · primary · accessed 2026-09-23
  Supports: issuer-anchored Solana mint
• Securitize: ACRED on Sei, instant subscription with fund bridging (Builder.io content API behind the blog) · primary · accessed 2026-09-23
  Supports: Sei deployment, Wormhole bridging

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The layer with the most administrative power sets the position’s effective control; that describes control, not quality or suitability.