Midas mTBILL

This file replaced an earlier record on 2026-09-23. Superseded the same day: permissionless transfer had been filed as a venue. It is a fact about the contract, already recorded as no allowlist in the control table, and is now stated as a term rather than a place to trade. Superseded records.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: Midas (mTBILL / mBASIS / mBTC) Not approved

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.

Who may hold it

No citizens or residents of the US, Canada, China, Australia, or Iran, and no entities formed under their laws.

“the investor is neither a citizen of nor does possess a permanent residence or working permit for the United States of America (USA), Canada, China, Australia or Iran and has no residence or registered office within the territory of one of these states;”

Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · General Terms and Conditions, 2.2 a) · words found 2026-09-23

First purchase minimum

USD 1.00.

“Minimum Investment Amount USD 1.00”

Midas Software GmbH, Final Terms for mTBILL Tokens dated 7 October 2024 (MFSA filing copy) · Part A, Contractual Terms table · words found 2026-09-23

Account types

People, companies, and partnerships with legal personality, if they pass the eligibility tests.

“Eligible to purchase and/or redeem Tokens are all natural and legal persons as well as partnerships with a legal personality if they fulfil the following requirements:”

Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · General Terms and Conditions, 2.2 · words found 2026-09-23

Who it may be transferred to

Holders may sell tokens person to person, over the counter.

“Subject to contrary provisions in the Final Terms, Blockchain-based Certificates are transferable and may be traded by Tokenholders in markets they chose via OTC-Contracts, i.e. on a bilateral basis.”

Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · Program description, B.1 Trading through OTC Contracts · words found 2026-09-23

How a holder redeems

A KYC-cleared holder is paid within ten business days of a redemption request.

“If the Tokenholder is Greenlisted, the Issuer shall transfer the relevant Redemption Amount to the Tokenholder’s wallet or account within ten Business Days after notice of the exercise of the Issuer Call Option by the Issuer or notice of receipt of the Tokenholder Order Request Form by the Issuer.”

Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · General Terms and Conditions, 5.3 · words found 2026-09-23

Who keeps the official record

No register named; the issuer counts as holders only KYC-cleared wallets that hold tokens.

“The Issuer will recognize and acknowledge as Tokenholders only those persons who both hold Tokens, and who have successfully completed the KYC/AML Requirements.”

Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · General Terms and Conditions, 4.1 · words found 2026-09-23

What the issuer says it can freeze or take back

Midas may move or delete tokens against the holder’s will to obey the law or a court order.

“In order to comply with legal obligations and official or court orders, Tokens may also be transferred or deleted without or against the will of the Tokenholders.”

Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · General Terms and Conditions, 4.3 · words found 2026-09-23

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.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-24. 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.

Where it trades

How it exits

Reopen conditions: events that change an answer above
• Midas offers mTBILL to U.S. persons or changes the USD 1.00 minimum
• The proxy admin or implementation on Ethereum or Base changes, or a transfer allowlist is added
• A blacklist, pause, or burn is used against a holder, or the instant-redemption vault is drained
• Any collateral, custodian, or oracle change that is not disclosed for mTBILL specifically
• Midas publishes final terms under its July 2025 prospectus; the file is then re-read against them

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 yesterday’s quote, since a fund of this kind accrues a few basis points a day. Every document quoted above is re-read too, and a quote that leaves its document 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 2 times since it was filed. Each superseded copy is kept as published, with the reason it was replaced.

Sources

• Midas — mTBILL product page and U.S. disclaimer · primary · accessed 2026-08-14
  Supports: not offered to U.S. persons, geo-blocked in the United States
• Midas docs — prospectus and final terms · primary · accessed 2026-08-14
  Supports: Liechtenstein FMA-approved prospectus, secured note
• Midas docs — mTBILL · primary · accessed 2026-08-14
  Supports: tracks sub-three-month Treasury bills, daily third-party verification
• Midas docs — issuance and redemption · primary · accessed 2026-08-14
  Supports: eligibility screening at issuance and redemption, instant and standard redemption
• Midas docs — deployed contracts · primary · accessed 2026-08-14
  Supports: mTBILL contract identity on Ethereum and Base, redemption vaults
• Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
  Supports: BLACKLISTED_ROLE and blacklist operator, pause operator, burn from a holder address, mint operator role
• Midas Software GmbH, Base Prospectus dated 17 July 2024 (FMA Liechtenstein approved; MFSA filing copy) · primary · accessed 2026-09-23
  Supports: who may-hold, account types, transfer, redemption, record, freeze
• Midas Software GmbH, Final Terms for mTBILL Tokens dated 7 October 2024 (MFSA filing copy) · primary · accessed 2026-09-23
  Supports: minimum