Historical record. Archived 2026-09-23: Superseded by an individually researched memo written with the eligibility file theo-thbill. The class record let size decide under the retired TVL screen and never read the contracts. It listed Solana, where no thBILL was found, and left out Base and HyperEVM. It did not say that Theo’s terms bar US citizens and residents, that Theo names no legal issuer, or that the tULTRA vault on Ethereum held no ULTRA units and booked all 35.7 million of its assets as pending. It did not record that a single key holds thBILL’s emergency pause role, or that the chain shows 36.3 million thBILL against CoinGecko’s 120 million and Theo’s own $175M+ and $200M figures.. This keeps the last issued verdict and does not count toward current coverage.

Tokenized real-world assets

Theo Network thBill

Not approved Too small to exit at size

Issued

2026-08-14

Last confirmed

2026-08-14

Next check due

2026-11-15

Research basis

Capacity evidence not established

Chains

Arbitrum One · Mixed control, Solana · Governed, no freeze, Ethereum · No freeze key

Eligibility file

What the holder owns and who may hold it

thBILL is an appreciating token whose current basket is tULTRA, Theo’s wrapper for a Singapore unit trust invested in ultra-short U.S. Treasuries, repos and cash. DefiLlama recorded about $63.5M on 2026-08-14, chiefly on Arbitrum and Solana, below the published retired TVL screen. Government debt merits individual review at scale; today size alone decides, without treating the token as private credit or claiming an impairment.

Review triggers: events that reopen the verdict

TVL sustained above the retired TVL threshold for 30 days

Watched nightly: a warning on its venues or files, or a cited document that changes, reopens the memo. The first confirmation is due 2026-11-15.

The research file

Mechanism

thBILL uses Theo’s index-token design and currently contains tULTRA. Theo describes tULTRA as one-for-one backed by ULTRA fund shares or USDC awaiting the purchase of those shares. The fund exposure is ultra-short U.S. Treasuries, repos and cash, managed by Wellington with FundBridge as fund manager and Standard Chartered as custodian.

Control and legal claim

Theo documents upgradeable vault contracts, role-based minting, whitelisting and emergency pause authorities. The underlying fund has regulated service providers, but Theo also states thBILL participants have no claim over underlying assets. That distinction, the wrapper entities, pending-settlement accounting and cross-chain deployments require legal and operational underwriting before any approval.

Exit consequences

Direct mint and redemption require KYC. Theo says the token-side action is processed immediately while underlying collateral can settle within four business days, and redemption pays equivalent value in USDC rather than delivering fund shares. Non-qualified holders depend on third-party trading venues; Theo’s terms warn that liquidity can be insufficient or delayed.

Why the class rule decides

At about $63.5M the product remains below the standing retired TVL screen, so the class rule decides before legal-claim, settlement and bridge diligence. Sustained TVL above the retired TVL threshold for 30 days reopens an individual review of fund documents, asset verification, pending assets, role controls, audits, cross-chain supply and stressed redemptions.

Sources

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

Theo Docs — thBILL composition and redemption · primary · accessed 2026-08-14
Supports: basket composition, KYC mint and redemption, four-day settlement, no claim over underlying assets
Theo Docs — tULTRA fund and service providers · primary · accessed 2026-08-14
Supports: fund assets, fund manager, investment manager, custodian, regulator
Theo Docs — tToken controls and pending assets · primary · accessed 2026-08-14
Supports: upgradeability, roles, emergency pause, optimistic minting, pending assets
DefiLlama — Theo Network thBILL survey record · secondary · accessed 2026-08-14
Supports: survey TVL, chain distribution, RWA category

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.

Chain	Verdict	Control	Control constraint
Arbitrum One	Approved with limits	Mixed control	a single sequencer orders >99% of transactions and admin keys can upgrade bridge contracts on a ~7-day timelock.
Solana	Approved with limits	Governed, no freeze	no admin key can seize funds, but stake concentration and a sub-25 Nakamoto coefficient are the standing watch items.
Ethereum	Approved	No freeze key	No sequencer, no upgrade key, no operator who can be compelled. Rule changes require social consensus.

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