Tokenized assets for RIAs: wrapper, exposure, and who may hold it

Start underneath the token

Write down what would remain if the blockchain record disappeared. Is the holder recorded by a transfer agent? Does the token represent a fund share, a beneficial interest, a note, a commodity entitlement, or a contractual redemption right? Which entity owes performance?

If the answer is unclear, the instrument is not ready for client consideration.

Then inspect the wrapper

The wrapper adds its own facts: supported chains, the contract’s administrator, wallet allowlists, transfer restrictions, upgrade authority, pause rights, bridges, and the redemption workflow. These may improve operations while adding new dependencies.

Mechanically, a tokenized-security wrapper is a short list of powers written into the token contract. The transfer agent or issuer mints tokens when a subscription settles and burns them at redemption. The transfer function checks an allowlist and refuses movement to an unapproved wallet. An administrator can pause the contract and upgrade its logic through a proxy, and in several reviewed designs can change a wallet’s status or burn tokens out of it when legally required; Superstate’s USTB documents those powers plainly, and the memo records them. The blockchain entry mirrors the transfer agent’s ledger, and when the two disagree, the legal record controls: the agent can reissue what a lost key stranded. None of this is hidden. It is in the contract and the offering documents.

Redemption anchors the price

A wrapper trades near the value of its underlying claim only while redemption works. The anchor is arbitrage: when the token trades below redemption value, an eligible holder buys it, redeems it, and keeps the difference, and that buying closes the gap. Anything that narrows who may redeem, queues redemptions, or gives the issuer discretion weakens the anchor.

Usual’s USD0++ showed the failure. On 2025-01-09 Usual announced that the unconditional early one-for-one exit would give way to a floor of 0.87 USD0, or a one-for-one route that required a contribution of its USUAL token; five days later it acknowledged that exit liquidity had been heavily impaired.¹² No exploit anywhere. The memo is published. A redeemable token is worth its redemption terms, and the terms are a governance variable unless they are fixed in code.

The anchor also needs the redemption desk to be open. When Circle could not reach $3.3 billion of reserves at Silicon Valley Bank over the weekend of 2023-03-10, USDC traded as low as 86 cents, because minting and redemption ran on U.S. banking hours.³ A tokenized fund that redeems only on business days can behave the same way on a Saturday.

The five-question record

1. What is the underlying asset or strategy?
2. What legal claim does the token holder have?
3. Who may hold, transfer, freeze, or redeem it?
4. What happens when the chain or the contract is unavailable?
5. Which risks exist only because of the token?

Ketju answers these five for every tokenized program it tracks, in one eligibility file per program, quoting the issuer’s own documents and reading the powers from the deployed contracts.

What is on file

Two guides go deeper. Tokenized Treasuries covers the fund structure, the transfer agent, and mint and redemption mechanics. Tokenized stocks covers what the holder of a tokenized share owns, from the share itself to a note that only pays like it. The September 2026 report counts what the files say about claims and keys.

Who may hold each program

Every file records who may hold the program, in the issuer’s words, and sorts the answer into one of four floors. Of the 95 programs on file, 39 are not offered to US persons at all, more than the 35 open to US retail investors. Another 21 are limited to accredited investors or qualified purchasers.

A floor is not the only gate. Among the programs open to some US investors, 7 set a first purchase of $1 million or more: BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I) ($5 million), Franklin OnChain Institutional Liquidity Fund (iBENJI) ($5 million), Tradable private-credit deal tokens ($5 million), BlackRock Daily Reinvestment Stablecoin Reserve Vehicle (RSVXX), BRSRV token ($3 million), BlackRock Select Treasury Based Liquidity Fund, OnChain Shares (DOLXX), BSTBL token ($3 million), Fidelity Treasury Digital Fund, OnChain class (FYOXX), FDIT token ($1 million), VanEck Treasury Fund (VBILL) ($1 million). Onboarding is a gate of its own. Before a wallet may hold, the holder is checked by the issuer or its transfer agent in 59 programs, a broker-dealer in 11, a distributor in 10; in 15, nobody does.

The not-offered group matters most in practice. It holds most offshore tokenized stocks and many of the Treasury tokens built for stablecoin treasuries. An adviser who finds one in a client’s wallet is looking at a holding the issuer says the client may not have. The file shows the issuer’s words; what the issuer would do about a US holder is not in them.

IRAs and retirement accounts

Retirement money is where many advisory relationships keep their largest balances, so the first question about a tokenized fund is often whether an IRA may hold it. The files answer from the issuer’s own documents. Of 95 programs, 2 name IRAs as eligible holders, 4 shut them out in writing, and 89 do not say.

Named as eligible:

• ARK Venture Fund (ARKVX), tokenized by Securitize (US retail investors): IRAs may purchase.
• Streamex GLDY (US accredited investors): Individuals, IRAs, revocable trusts, other trusts, entities and family offices that meet the accredited-investor test; a benefit plan answers a separate questionnaire, and the servicer may force a plan to redeem. The document: “Individuals, Individual Retirement Accounts or Plans, and Revocable Trusts.”

Shut out in writing:

• Bitwise Crypto Carry Fund (USCC) (US qualified purchasers): Not IRA eligible.
• BNY Dreyfus On-Chain Liquidity Fund (BCLXX), BLIQUID token (US accredited investors): Not individuals or retirement plans. The document: “Shares of the fund are generally not eligible for retirement plans or individual investors.”
• Circle USYC (Not offered to US persons): Entities only. Individuals, trusts, and IRAs are not offered.
• Franklin OnChain U.S. Government Money Fund (FOBXX), BENJI token (US retail investors): Individuals through the app and institutions through the portal. No IRAs, Roth IRAs, or employer retirement plans. The document: “The Fund does not permit investments by employer sponsored retirement plans, SIMPLE-IRAs, SEP-IRAs, SARSEPs or 403(b) plan accounts, IRAs, IRA Rollovers, Coverdale Education Savings Plans or Roth IRAs.”

Silence is not permission. An IRA is a trust or custodial account, and IRS Publication 590-A requires its trustee or custodian to be a bank, a federally insured credit union, a savings and loan association, or an entity the IRS approves.⁴ A tokenized fund that allows only allowlisted wallets has to onboard that trustee or custodian as the holder. When the terms do not name IRAs, the issuer has not said it will. Where a fund’s prospectus admits IRAs, check that the token route does too: the files record the fund’s terms and the distributor’s onboarding separately, and they do not always agree.

Metal tokens carry a second question. An IRA that buys a collectible is treated as having distributed the amount, and Publication 590-A lists metals among collectibles.⁴ The statute exempts certain bullion only “if such bullion is in the physical possession of a trustee.”⁵ Whether a token that represents vaulted gold meets that test is a question for the IRA custodian and tax counsel. The files record what issuers say about account types; they do not decide the tax treatment.

Employer plans sit under a different regime. The Department of Labor warned 401(k) fiduciaries in March 2022 to use “extreme care” before adding crypto, and rescinded that guidance in full on 2025-05-28; the Department now neither endorses nor disapproves.⁶ An executive order of 2025-08-07 directs agencies to widen 401(k) access to alternative assets, including “actively managed investment vehicles that are investing in digital assets.”⁷ Neither changes what an issuer’s terms allow.

One issuer, three different instruments

Midas issues roughly $2.1 billion, at the August 2026 review, across three tokens with a shared prefix: mTBILL is a tokenized claim on short-dated US Treasuries, mBASIS is a strategy token running a basis trade, and mBTC is a Bitcoin-backed debt instrument built on lending agreements, which makes it credit risk rather than Bitcoin exposure. Government debt, a levered trade, and private credit, dressed alike. The naming invites a client conversation that blends them; the five-question record refuses to. Ketju’s memo takes the three apart, and the eligibility finding turns on a separate wrapper fact: the tokens are not offered to US persons at issuance, and buying a security around its own eligibility restrictions is refused, not treated as a loophole.

The same discipline applies to the oldest wrapper in the category. WBTC tracks the Bitcoin price, and it is not Bitcoin: a custodian holds the underlying coins and can be compelled, and only approved merchants mint or redeem. The control profile records what would remain if the blockchain entry were the only fact you had: a custodial IOU.

Compare like with like

Compare a tokenized Treasury fund with other Treasury funds after fees, duration, liquidity, tax treatment, and access. Compare on-chain credit with credit, not with cash. Tokenization may be the operating advantage; it is rarely the whole investment case.

Next: tokenized Treasuries, tokenized stocks, and DeFi versus tokenized securities.