KETJU Research

← Eligibility files

Eligibility file · Treasury fund

BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I)

What the client owns
Share of a British Virgin Islands private fund holding cash, U.S. Treasury bills, and repurchase agreements; I Class share of the same British Virgin Islands fund; one token is one share at a stable $1.00. Issuer direct: The on-chain record is the securityholder file; the holder is the registered owner.
Who may hold it
US qualified purchasers. First purchase $5,000,000. BlackRock’s 2024 launch release states a $5 million minimum; every Form D on EDGAR, through July 2026, states $100,000 for any outside investor. The file takes the higher figure until BlackRock or Securitize says which applies. The I Class (BUIDL-I) is a class of the same fund, sold under the same Form D, so the same qualified-purchaser test applies; no BlackRock or Securitize document read states the I Class minimum, fee, or intended investors.
Who can freeze or claw back
Ethereum BUIDL: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. Owner key: a single key.
Ethereum BUIDL-I: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. Owner key: a single key.
Solana BUIDL: can freeze a holder, claw back, gate who may hold, mint, change the code. An account only a program can sign for can freeze a holder and claw back tokens. A single key can change the code with no delay.
How it exits
Redeem with the issuer in its window. Daily redemption through Securitize in U.S. dollars at the stable $1.00 token value. Settles in USD.

In plain words on RIADeFi: BlackRock BUIDL.

This file replaced an earlier record on 2026-09-23. Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager the token consults on every transfer, so the file said the issuer cannot freeze a holder. It can, through lockInvestor. Same claim model, terms, and exit. Superseded records.

Subscribers see which of their clients hold this program, each household’s answer against these terms, and an alert when the file changes. $49 per advisor per month, first 14 days free.

The verdict is on the memo: BlackRock BUIDL Not approved

Issuer
BlackRock USD Institutional Digital Liquidity Fund Ltd. (BVI); BlackRock Financial Management as manager; Securitize as transfer agent and placement agent
Registration
Private placement, Rule 506(c)
Official record
Securitize, LLC, SEC-registered transfer agent
Instruments
BUIDL BUIDL-I
Chains
Ethereum, Solana
Reviewed
2026-09-23 · v1
Next review
2027-03-23

Who may buy, hold, transfer, and redeem

Each answer rests on the issuer’s own words, quoted from the document named under it. Ketju re-reads each document and records whether the words are still there. Where the documents say nothing, the row says so.

What the holder owns

Each token is a share of the fund, per Securitize, its transfer agent.

“The Company notes that each tokenized share of BUIDL and VBILL represents an ownership interest in the BlackRock USD Institutional Digital Liquidity Fund and VanEck Treasury Fund, Ltd., respectively”

SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Notes to the consolidated financial statements, ”Cash and Cash Equivalents” · words found 2026-09-25

Who may hold it

Investors eligible for a Rule 506(c) private offering in a Section 3(c)(7) fund, which means qualified purchasers.

“The Fund will issue shares pursuant to Rule 506(c) under the Securities Act of 1933 and Section3(c)(7) of the Investment Company Act.”

BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026) · Press release, fifth paragraph from the end of the body · words found 2026-09-23

First purchase minimum

$100,000 per outside investor, per the July 2026 Form D. The 2024 launch release said $5 million.

“Minimum investment accepted from any outside investor $ 100,000 USD”

SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026 · Item 11, Minimum Investment · words found 2026-09-23

First purchase minimum

The I Class minimum is not stated in any document read.

Not stated in BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026), SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026, SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026, SEC EDGAR: Securitize Corp. Form 8-K/A, exhibit 99.2, management’s discussion of results for the quarter ended June 30, 2026 (filed August 13, 2026).

Account types

The documents read do not say.

Not stated in BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026), SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026, SEC EDGAR: BUIDL Form D filing, SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026, SEC EDGAR: Securitize Corp. Form 8-K/A, exhibit 99.2, management’s discussion of results for the quarter ended June 30, 2026 (filed August 13, 2026), Circle: BUIDL-to-USDC transfer contract, BUIDL Solana mint metadata (points at metadata.securitize.io).

Who it may be transferred to

Any time, but only to other pre-approved investors.

“Investors can transfer their tokens 24/7/365 to other pre-approved investors.”

BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026) · Press release body · words found 2026-09-23

How a holder redeems

At NAV, $1 per share, for cash. The transfer agent names no cutoff or settlement time.

“BUIDL and VBILL tokens can be redeemed at their net asset value which is $1 per share and are readily convertible to cash.”

SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Notes to the consolidated financial statements, ”Cash and Cash Equivalents” · words found 2026-09-25

Who keeps the official record

Securitize, the SEC-registered transfer agent, uses a public blockchain as the master securityholder file for most clients. It does not name BUIDL here.

“As part of our Asset Servicing offering, we act as the official SEC-registered transfer agent for the majority of our customers. We use distributed ledger technology in the form of a public blockchain as the master securityholder file to provide recordkeeping, accounting, reporting, examination and other services.”

SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Business, ”Securitize’s Role” · words found 2026-09-25

What the issuer says it can freeze or take back

Securitize says its smart contracts can seize or burn tokens to fix minting or allocation errors.

“While Securitize’s smart contracts provide mechanisms to seize or burn tokens to remediate these situations, such incidents could lead to temporary imbalances, customer disputes, or reputational harm.”

SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Risk Factors, token minting and allocation errors · words found 2026-09-25

FactWhat the file records
Who onboards the holderbroker dealer
Voting rightsNone
Distributionsnew tokens
SIPC coverage of the walletNo

What the issuer filed with the SEC

A private offering files Form D with the SEC within 15 days of its first sale and amends it each year while it sells. The issuer signs it. It states the exemption relied on, the fund’s exclusion from the Investment Company Act (which decides who may buy), the smallest investment accepted, the amount sold, and how many investors hold.

FiledFormExemption claimedMinimumSold to dateInvestors
2026-07-27D/ARule 506(c); Investment Company Act section 3(c)(7)$100,000$5,135,523,41228
2025-07-18D/ARule 506(c); Investment Company Act section 3(c)(7)$100,000$3,251,152,22842
2024-03-18DRule 506(c); Investment Company Act section 3(c)(7)$100,000$00

Filed by BlackRock USD Institutional Digital Liquidity Fund Ltd. (SEC CIK 2013810). Sold to date counts every sale since the first, not the fund’s size today. Ketju reads EDGAR daily; a new filing reopens this file.

The transfer agent’s SEC record

A transfer agent registers with the SEC on Form TA-1 and reports each year on Form TA-2: how many securityholder accounts it keeps and for how many issues it keeps the master securityholder file, the list that says who owns each share.

AgentSEC fileOn EDGAR sinceTA-2 periodAccountsIssues with master fileWork it hires out
Securitize Transfer Agent, LLC084-066382019-07-222025-12-3118,33754PACIFIC STOCK TRANSFER CO

EDGAR records Securitize LLC as the former name of Securitize Transfer Agent, LLC, changed 2025-04-14.

Who can change the record

Powers read from the deployed contracts and their verified source: the token and every contract it consults on transfer. A power recorded here is the issuer’s ability, not evidence it has been used.

TokenChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
BUIDLEthereumYesYesYesYesYesOwner key: a single key.
BUIDL-IEthereumYesYesYesYesYesOwner key: a single key.
BUIDLSolanaYesNoYesYesYesAn account only a program can sign for can freeze a holder and claw back tokens. A single key can change the code with no delay.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-23. A single key is one private key: whoever holds it acts alone. A multisig needs the stated number of signers. A timelock makes every action wait, so holders can see it coming.

TokenChainKeyWhat it can doHeld byAddress
BUIDLEthereumOwnergrant and revoke these powersa single key0xe016…b09e
BUIDLEthereumWallet registrar ownerdecide who may hold, grant and revoke these powersa single key0xf3aa…27d9
BUIDL-IEthereumOwnergrant and revoke these powersa single key0xe016…b09e
BUIDL-IEthereumWallet registrar ownerdecide who may hold, grant and revoke these powersa contract run by a single key0xc537…9765
BUIDLSolanaMint authoritymint new tokensan account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaFreeze authorityfreeze a holderan account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaPermanent delegateclaw back tokensan account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaTransfer-hook authoritydecide who may hold, change the codean account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaHook program upgrade authoritychange the codea single key8d36iv…zbB6
Ethereum BUIDL: 14 contract reads at block 26037152, 6 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.implementation=0x603bb6909be14f83282e03632280d91be7fb83b2
  • owner()=0xe01605f6b6dc593b7d2917f4a0940db2a625b09e
  • isPaused()=false
  • target()=0x603bb6909be14f83282e03632280d91be7fb83b2
  • getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x1dc378568cefd4596c5f9f9a14256d8250b56369
  • getDSService(COMPLIANCE_SERVICE)=0x07a1ebfb9a9a421249ddc71bddb8860cc077e3a9
  • getDSService(LOCK_MANAGER)=0x0a65a40a4b2f64d3445a628abcfc8128625483a4
  • getDSService(OMNIBUS_TBE_CONTROLLER)=0x59a100bcc70649485422670dc697b64bd1c6e6c1
  • getDSService(REGISTRY_SERVICE)=0x0dac900f26de70336f2320f7ccedee70ff6a1a5b
  • getDSService(TOKEN_REALLOCATOR)=0xf33675685c8ee774c7f5655c93afedc7b9818ecd
  • getDSService(TRANSACTION_RELAYER)=0xd75c86c3e3761e2b2a7960afb670850923899473
  • getDSService(TRUST_SERVICE)=0x3a68756d0335e75c909ba1e8fefc1d4832c36c60
  • getDSService(WALLET_MANAGER)=0x13cdc85f7bcd5c1f9cbbff0e2d11532eb9abef74
  • getDSService(WALLET_REGISTRAR)=0x008075b22bec05c7d0fb789e3420b76056d76cab
Read from verified source
Ethereum BUIDL-I: 13 contract reads at block 26042814, 6 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.implementation=0x9e2693f54831f6f52b0bb952c2935d26919a3626
  • owner()=0xe01605f6b6dc593b7d2917f4a0940db2a625b09e
  • isPaused()=false
  • getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x41a5f31c45fa12913e125914bd79ef49befa1a1f
  • getDSService(COMPLIANCE_SERVICE)=0xc7ca0ce7626940838a87656656c6af92b95abd00
  • getDSService(LOCK_MANAGER)=0x32708a900a740846445fd49c0c00df15701720a2
  • getDSService(OMNIBUS_TBE_CONTROLLER)=0xddf7b95d79872766b4c0f32284fac86155c81b3a
  • getDSService(REGISTRY_SERVICE)=0xf8e91fa34311876302d36d14b4f246044fd4332a
  • getDSService(TOKEN_REALLOCATOR)=0x95e07b0682da8627decbb068cb57ae7ebe650e9e
  • getDSService(TRANSACTION_RELAYER)=0xfd45dd1f78f9501b4e37b7a02e24ec29da64917f
  • getDSService(TRUST_SERVICE)=0x712244c054244432d0f9ea16a56121598eba7a2c
  • getDSService(WALLET_MANAGER)=0x1df0616fd703643411d62c34dfbfa3a261df7dab
  • getDSService(WALLET_REGISTRAR)=0x51d016b8cc89f56fd5a7970892586fb512e202a0
Read from verified source
Solana BUIDL: 4 contract reads at block 449565316, 0 functions in verified source, 2026-09-23
Read from the chain
  • mintAuthority=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
  • freezeAuthority=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
  • permanentDelegate=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
  • transferHook=FsE8mCJyvgMzqJbfHbJQm3iuf3cRZC6n2vZi1Q8rQCy2

Where it trades

VenueKind
Securitize primary marketissuer primary

How it exits

PathSettlementSettles in
Redeem with the issuer in its windowDaily redemption through Securitize in U.S. dollars at the stable $1.00 token valueUSD
Redeem with the issuer in its windowCircle smart contract exchanges BUIDL for USDC on demand for approved holdersUSDC
Redeem with the issuer in its windowI Class: on chain, holders send BUIDL-I to one address (0x8780…4200) and Securitize burns it there; 24,999,000 tokens sent on 21 September 2026 were burned on 22 September, and 250 million were burned on 17 September. No document read states the I Class cutoff or how the dollars are paid.USD

What the monitor reads daily

Every control function in the table above and the contracts the token consults on transfer; the token’s on-chain supply against yesterday’s; and its market quote against its one-dollar value. Every document quoted above is re-read too, and a quote that leaves its document reopens the file. EDGAR is read for the issuer’s Form D filings and the transfer agent’s registration; a new filing reopens the file. A key that appears, disappears, or changes shape counts as a change only when the chain’s own log shows the grant, revocation, or signer change between yesterday’s block and today’s; a difference the log does not show updates this file’s key list and nothing more. A change opens a review item in the governance queue and reopens the file before any client action. Subscribers get an email naming each of their clients who hold it, with the household result.

File history

Revised 3 times since it was filed. Each superseded copy is kept as published, with the reason it was replaced.

DateChange
2026-09-23Filed.
2026-09-23Revised. Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager the token consults on every transfer, so the file said the issuer cannot freeze a holder. It can, through lockInvestor. Same claim model, terms, and exit.
2026-09-23Revised. Superseded to quote the issuer’s terms: every Form D states a $100,000 minimum while the launch release states $5 million; the file keeps the higher figure and says so.
2026-09-23Revised. Superseded to add the I Class (BUIDL-I), a second class of the same fund that the file did not list: an Ethereum Securitize DS token holding 239.7 million shares across six wallets on 23 September 2026, run by the same owner key as BUIDL. The file moves to file-records/blackrock-buidl.ts; the BUIDL class terms, contracts, and readings are unchanged.

Sources

The file is public. The subscription checks it against each of your households and watches it daily. $49 per advisor per month, first 14 days free. Start the trial.