Securitize Tokenized AAA CLO Fund (STAC)
This file replaced an earlier record on 2026-09-24. Superseded to reconcile the minimum with the fund’s Form D. The November 2025 Form D states a $0 minimum and claims Rule 506(c) and section 3(c)(1); the file kept Securitize’s $100,000 tile without naming the filing. The file now cites the Form D and says it keeps the stricter figure. Superseded records.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: Securitize Tokenised AAA CLO Fund Rejected
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
Eligible investors who pass Securitize KYC, AML, and investor qualification and accreditation checks.
“Eligible investors can subscribe to the Securitize Tokenized AAA CLO Fund directly through Securitize, with shares issued as digital tokens on Ethereum. These tokenized shares will offer fractional ownership and transparent recordkeeping through Securitize’s integrated Know Your Customer (KYC), Anti-Money Laundering (AML), and investor qualification and accreditation infrastructure.”
Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29) · Release body · words found 2026-09-23
- First purchase minimum
$100,000, shown as a figure in the Minimum Investment tile, not a sentence.
“$100,000”
Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · Key facts tile, Minimum Investment · words found 2026-09-23
- Account types
The documents read do not say.
Not stated in Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund), Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29), Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12).
- Who it may be transferred to
Only to other whitelisted holders, starting one day after issue.
“(6) Tokens can be transferred to other whitelisted holders one day after issuance.”
Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · Fund Profile footnote (6) · words found 2026-09-23
- How a holder redeems
Redemptions depend on selling CLOs, expected T+2 or T+3 but not guaranteed.
“(4) CLOs may take several days to liquidate the Fund’s position, either in whole or in part, which may be necessary for the Fund to be able to provide redemption funds to a redeeming Shareholder. It is expected that CLO liquidations will generally be facilitated on a T+2 or T+3 timing, however, there can be no guarantee of such timing.”
Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · Fund Profile footnote (4) · words found 2026-09-23
- Who keeps the official record
Securitize keeps the records and onchain ownership through its transfer agent.
“Securitize provides integrated KYC, AML and investor accreditation, along with transparent recordkeeping and onchain ownership through its transfer agent infrastructure.”
Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12) · Release body · words found 2026-09-23
- What the issuer says it can freeze or take back
The documents read do not say.
Not stated in Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund), Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29), Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12).
| Fact | What the file records |
|---|---|
| Who onboards the holder | broker dealer |
| Voting rights | None |
| Distributions | reinvested |
| SIPC coverage of the wallet | No |
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.
| Filed | Form | Exemption claimed | Minimum | Sold to date | Investors |
|---|---|---|---|---|---|
| 2025-11-05 | D | Rule 506(c); Investment Company Act section 3(c)(1) | $0 | $5,000,000 | 1 |
Filed by Securitize AAA CLO Tokenized Fund, Ltd. (SEC CIK 2095325). 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 2025-11-05 Form D states a $0 minimum; the file records $100,000. The note under “Who may hold it” says which figure the file follows.
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.
| Agent | SEC file | TA-2 period | Accounts | Issues with master file | Work it hires out |
|---|---|---|---|---|---|
| Securitize Transfer Agent, LLC | 084-06638 | 2025-12-31 | 18,337 | 54 | PACIFIC STOCK TRANSFER CO |
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.
| Chain | Freeze a holder | Pause | Claw back | Gate holders | Change the code | Keys held by |
|---|---|---|---|---|---|---|
| Ethereum | Yes | Yes | Yes | Yes | Yes | Owner key: a single key. |
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.
| Chain | Key | What it can do | Held by | Address |
|---|---|---|---|---|
| Ethereum | Owner | grant and revoke these powers | a single key | 0x59c1…76ee |
| Ethereum | Wallet registrar owner | decide who may hold, grant and revoke these powers | a single key | 0x3ee6…1a3e |
Ethereum: 12 contract reads at block 26037157, 6 functions in verified source, 2026-09-23
- eip1967.implementation=0x77684815f44b28726bc3efa4471b88ef3b93feb0
- owner()=0x59c1eacec450c57dcb9b8725d0f96635c2b676ee
- isPaused()=false
- getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x07952f21df5068bfa900ff317e6aaf4fe376a561
- getDSService(COMPLIANCE_SERVICE)=0xd8edd463579cda2249cf91a36767421b4bbd69bb
- getDSService(DEPRECATED_SECURITIZE_SWAP)=0xc793b33120e5b74b601b00af8fe2d30167ceb923
- getDSService(LOCK_MANAGER)=0x6fce11ccc5c6861f74e5bf02f4d4ac0a7832b870
- getDSService(REGISTRY_SERVICE)=0x71080eb74e2816124327af399ac8cc518bbc7f49
- getDSService(TRANSACTION_RELAYER)=0x705924779443f6b869bffdcc553708498862f4b6
- getDSService(TRUST_SERVICE)=0xec0f580a0fe6ea53654537d34788aebad70a6370
- getDSService(WALLET_MANAGER)=0x412ab53abc69877f0976484a131087008f354897
- getDSService(WALLET_REGISTRAR)=0x10e0b0d4ecfa6921cc52f2edbc594c1ff4e9a62e
- preTransferCheck in verified source 0x7768…feb0
- lockInvestor in verified source 0xe33f…45c6
- isPaused in verified source 0x7768…feb0
- burn in verified source 0x7768…feb0
- issueTokens in verified source 0x7768…feb0
- upgradeToAndCall in verified source 0x7768…feb0
Where it trades
| Venue | Kind |
|---|---|
| Securitize primary market | issuer primary |
How it exits
| Path | Cutoff | Settlement | Settles in |
|---|---|---|---|
| Redeem with the issuer in its window | 2:30 p.m. Eastern for subscriptions | Daily redemption requests; CLO sales to fund them are expected on T+2 or T+3 with no guarantee; on-demand liquidity pool at general-partner discretion; one-day hold after issuance | USDC, USD |
- Securitize publishes the offering memorandum with the eligible-investor class, gates, valuation policy, and complete fees; the file is then re-read against it
- The compliance service, lock manager, proxy implementation, or issuer role on Ethereum changes
- Securitize publishes the Solana mint identity; that chain is then read and added
- A redemption gate, a suspension, or settlement beyond the stated window
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. 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.
| Date | Change |
|---|---|
| 2026-09-23 | Filed. |
| 2026-09-23 | Revised. Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager, so the file said the issuer cannot freeze a holder. It can, through lockInvestor. Same claim model, terms, and exit. |
| 2026-09-23 | Revised. Superseded to add the issuer’s own words for each term; the accredited floor now says which words it rests on. |
| 2026-09-24 | Revised. Superseded to reconcile the minimum with the fund’s Form D. The November 2025 Form D states a $0 minimum and claims Rule 506(c) and section 3(c)(1); the file kept Securitize’s $100,000 tile without naming the filing. The file now cites the Form D and says it keeps the stricter figure. |
Sources
- SEC EDGAR: Securitize AAA CLO Tokenized Fund, Ltd., Form D filed November 5, 2025 · primary · accessed 2026-09-24
Supports: Rule 506(c), section 3(c)(1), minimum accepted from any outside investor, amount sold, investor count - Securitize — STAC primary-market page · primary · accessed 2026-09-23
Supports: $100,000 minimum, accredited investors where applicable, BVI domicile, instant subscription with 2:30 p.m. Eastern deadline, daily redemptions, T+2 or T+3 CLO liquidation, one-day hold, 0.40% expense ratio - Securitize STAC launch with BNY, 2025-10-29 · primary · accessed 2026-08-01
Supports: BNY custody and NAV, AAA CLO mandate - Securitize STAC Solana expansion and fund risk disclosure, 2026-06-12 · primary · accessed 2026-08-01
Supports: Solana share class, structured-credit risk disclosure - Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: preTransferCheck compliance gate, pause, seize, issueTokens, upgradeToAndCall - Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29) · primary · accessed 2026-09-23
Supports: who may-hold - Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · primary · accessed 2026-09-23
Supports: minimum, transfer, redemption - Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12) · primary · accessed 2026-09-23
Supports: record