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Eligibility file · Credit fund

Securitize Tokenized AAA CLO Fund (STAC)

What the client owns
Share of a British Virgin Islands private fund holding U.S. dollar AAA-rated CLO tranches. Issuer direct: The on-chain record is the securityholder file; the holder is the registered owner.
Who may hold it
US accredited investors. First purchase $100,000. The current pages say “highly sophisticated investors” who pass “investor qualification and accreditation” checks. The file reads that as accredited investors at least, the stricter reading of a private placement. Securitize’s page shows a $100,000 minimum; the fund’s November 2025 Form D states $0 and claims section 3(c)(1), which admits accredited investors. The file keeps the page’s figure, the stricter.
Who can freeze or claw back
Ethereum: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. Owner key: a single key.
How it exits
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. Settles in USDC, USD.

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 Superseded to reconcile the minimum with the fund’s Form D. The November 2025 Form D states a $0 minimum and claims Rule 506(c) and section 3(c)(1); the file kept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 Superseded records.

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The verdict is on the memo: Securitize Tokenised AAA CLO Fund Rejected

Issuer
Securitize Tokenized AAA CLO Fund (British Virgin Islands); BNY Investments as portfolio selector; BNY as custodian and NAV administrator
Registration
Private placement, Rule 506(c)
Official record
Securitize (transfer agent and fund administrator), SEC-registered transfer agent
Instruments
STAC
Chains
Ethereum
Reviewed
2026-09-24 · v1
Next review
2027-03-24

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).

FactWhat the file records
Who onboards the holderbroker dealer
Voting rightsNone
Distributionsreinvested
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
2025-11-05DRule 506(c); Investment Company Act section 3(c)(1)$0$5,000,0001

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 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

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.

ChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
EthereumYesYesYesYesYesOwner 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.

ChainKeyWhat it can doHeld byAddress
EthereumOwnergrant and revoke these powersa single key0x59c1…76ee
EthereumWallet registrar ownerdecide who may hold, grant and revoke these powersa single key0x3ee6…1a3e
Ethereum: 12 contract reads at block 26037157, 6 functions in verified source, 2026-09-23
Read from the chain
  • 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
Read from verified source

Where it trades

VenueKind
Securitize primary marketissuer primary

How it exits

PathCutoffSettlementSettles in
Redeem with the issuer in its window2:30 p.m. Eastern for subscriptionsDaily 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 issuanceUSDC, 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 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.

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, 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 add the issuer’s own words for each term; the accredited floor now says which words it rests on.
2026-09-24Revised. 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

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