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Tokenized real-world assets

Ethena USDtb

Rejected The evidence weighs against it
Issued
2026-09-24
Last confirmed
2026-09-26
Next check due
2027-09-27
Research basis
Individual research
Chains
Ethereum · No freeze key, Solana · Governed, no freeze
Symbols
USDTB
Eligibility file
What the holder owns and who may hold it

USDtb is a dollar stablecoin. Since 13 October 2025 Anchorage Digital Bank, N.A., an OCC-chartered trust bank, has been its sole issuer and the only party that owes the dollar; Ethena Labs lends the brand. The reserve is almost all BlackRock’s BUIDL fund: $397.7 million of BUIDL and $4.0 million of cash against 401.0 million tokens on 31 July 2026. That is why USDtb is often described as a way to hold BUIDL without being a qualified purchaser. It is not. The holder owns no BUIDL share and gets none of its income, which the bank keeps as its fee. The holder owns a promise from the bank to pay $1, and the bank makes that promise only to its own clients. Anyone may hold and send USDtb. Only the bank’s clients may buy it from the bank or sell it back, and the bank’s terms say a holder who is not a client has no contract rights against it. The bank publishes no minimum and keeps its fee schedule private. On both chains one key can block any wallet, one can pause the token, and one can create USDtb or burn it from any holder; on Ethereum one key can also replace the code and hand out every role. The assessment is adverse. The reserve and its monthly examination are sound, but a client who holds USDtb gets a $1 token with no yield and no right to redeem, whose price outside the bank rests on a $20 million Curve pool. A client who wants cash on chain has larger dollar stablecoins; a client who wants BUIDL’s yield does not get it here.

The research file

What the holder owns

Anchorage’s Covered Stablecoin Terms, effective 13 October 2025, govern every stablecoin the bank issues, USDtb among them. They make the bank “the sole issuer of, and the sole obligor for” each one and say a transfer “transfers all rights associated with those Covered Stablecoins to the recipient.” The terms name no register of holders besides the chain. But the right that matters, redemption at $1, is “conditional”: it passes to the recipient “only if, and when, the recipient becomes a Client.” A holder who is not a client, in the terms’ words, has “no enforceable rights against ADB in respect of Covered Stablecoins, except as may arise under applicable law.” The reserve sits in a South Dakota express trust with the bank as trustee, and the July 2026 reserve report says the assets are “held for the benefit of USDtb token holders.” The trust agreement is not public, so no document read says whether a holder who is not a client can enforce that trust. Income on the reserve above what backs the tokens one to one is “fiduciary compensation to ADB,” so BUIDL’s daily dividends go to the bank. USDtb is not a deposit and is not FDIC or SIPC insured.

The GENIUS Act, and when it applies

Anchorage drafts USDtb’s terms to the GENIUS Act, signed 18 July 2025. Its redemption section cites the Act, and the token’s Solana metadata calls it “structured to be compliant with the GENIUS Act.” The Act matters to a holder in two ways. It says a payment stablecoin issued by a permitted payment stablecoin issuer is not a security under the Securities Act, the Exchange Act, the Investment Company Act, or the Advisers Act. And if a permitted issuer fails, holders’ remaining claims take first priority in its bankruptcy. But the Act takes effect on the earlier of 18 January 2027 or 120 days after the regulators’ final rules. The OCC proposed its rules in March 2026 and had not issued final ones when this memo was written. No document read shows the OCC has approved Anchorage as a permitted issuer. Until then the exclusion and the priority are a date on the calendar, not a right a holder can use. USDtb has no Form D and no registration.

Who may hold, mint, and redeem

USDtb’s own documentation says: “Only customers of Anchorage Digital Bank are able to mint and redeem USDtb.” The bank’s terms say the same twice: it issues “exclusively to Clients” and redeems “exclusively from Clients,” and it “may refuse, suspend, or limit any redemption request in its discretion,” liquidity management among the reasons. Clients sign the bank’s Master Account Agreement. Anchorage’s pages speak to institutions, and its contact form asks for an institution type; no document read offers an account to an individual. Clients redeem at $1 “net of any applicable fees disclosed in the Covered Stablecoin Fee Schedule,” which is not public; no minimum is published. Everyone else may hold USDtb: the terms bar transfers to prohibited jurisdictions, to sanctioned persons, and for unlawful use, and set no investor test. The 2026-08-17 memo could not say which rule governed US persons. The terms answer it: any holder, US or not, may hold, and none but a client may redeem. Before the move, Ethena’s Liquidity Fund let Securitize-approved BUIDL holders swap BUIDL for USDtb; that route was always limited to BUIDL’s own qualified purchasers.

Who controls the token

On Ethereum, USDtb (0xc139…ac1c) is an upgradeable proxy. Its code, AnchorageTokenUSDtb, was installed in October 2025, and its verified source gives four roles. The admin, 0xd938…3956, is a plain address, one key; it also owns the proxy admin contract, so it can replace the code, and it grants and revokes every other role. The minter-burner, 0x3643…e6f3, can create USDtb and burn it from any wallet without the holder’s consent, blocked wallets included. The blocklister, 0x8875…5d23, can stop any wallet from sending or receiving. The pauser, 0xc2a2…0812, can halt all transfers. Each is a plain address; Anchorage may split a key inside its own custody, but the chain sees one signer. Transfers are otherwise open: the old whitelist roles remain in the code as named constants that nothing reads. On 2026-09-24 the contract listed 96 blocked wallets, none holding USDtb. Ethena’s old roles, a minting contract and a 5-of-11 Safe that once managed the blacklist, still hold their grants, but no function checks them. On Solana, USDtb (8yXr…8n3T) is a Token-2022 mint. One wallet is both mint authority and permanent delegate, so it can create tokens and move or burn any holder’s balance; separate wallets hold the freeze and pause authorities; a fourth can set a transfer fee (now zero) or add a transfer hook (none set). Anchorage’s terms claim the same power in words: it “may freeze, block, seize, or otherwise restrict” USDtb held by clients and non-clients alike.

The reserve and the BUIDL look-through

Anchorage publishes a monthly reserve report examined by a Big Four firm to AICPA attestation standards. On 31 July 2026: 352,731,964 USDtb on Ethereum and 48,224,742 on Solana, 400,956,706 in all, against $401,718,132 of reserve, a surplus of $761,426. The reserve was $397,671,702 of BUIDL, 99%, and $4,046,430 of cash in bank demand accounts, $3,796,430 of it above the FDIC limit. The BUIDL sat in Anchorage wallets on Solana ($172.7 million), BNB Chain ($110.8 million), and Avalanche ($114.2 million). No token was access-restricted. By 2026-09-24 supply had grown to about 520.8 million (476.0 million on Ethereum, 44.8 million on Solana). So the reserve is one private fund. BUIDL’s file (blackrock-buidl) records that Securitize, its transfer agent, can freeze and seize BUIDL on Ethereum and Solana and that BUIDL redeems only through Securitize. A BUIDL freeze, a redemption delay, or a fall in its $1 NAV would reach USDtb through the bank’s reserve, not through the holder’s wallet. That file does not read BUIDL on BNB Chain or Avalanche, where more than half of Anchorage’s BUIDL sits.

Comparison and decision

Against the other dollar stablecoins a client might hold, USDtb has a strong issuer, a reserve held in trust, and a monthly examination, and it has the same single-key controls most of them have. What sets it apart is worse for a client: a thin market (the largest pool DefiLlama lists is Curve’s USDC-USDtb pool, about $20 million), a redemption window open only to institutional bank clients, a private fee schedule, and a reserve concentrated in one fund whose own shares another firm can freeze. Against BUIDL, USDtb adds a bank’s promise and removes the yield. The assessment is adverse; the program stays research-only. The client-eligibility question is not assessed, because the research rejects the program first; the file records that anyone may hold it.

Sources

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

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.

ChainVerdictControlControl constraint
EthereumApproved No freeze key No sequencer, no upgrade key, no operator who can be compelled. Rule changes require social consensus.
SolanaApproved 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.
AssetControlWho can freeze it
USDtb Issuer can freeze Ethena controls an upgradeable USDtb token whose administrator can change transfer state, blacklist addresses, and forcibly redistribute balances; BUIDL and USDC supply the backing.
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