Delta Wellington Ultra Short Treasury On-Chain Fund (ULTRA)

Research, firm shelf, model-client eligibility, and advisor selection are recorded separately. The scheduled date is the outside bound; new evidence can reopen the file sooner.

ULTRA is a unit of a sub-fund of the Delta Master Trust, a Singapore unit trust. FundBridge Capital manages it, Wellington Management picks the bonds, Perpetual (Asia) is trustee, Standard Chartered holds the assets, Vistra keeps the books, and Libeara, a Standard Chartered company, runs the token contracts. The fund holds US Treasuries due within a year, repos, and cash; each unit was worth about $1.057 on 2026-09-24. Its Form D, amended on 3 November 2025, reports $135.3 million sold to seven investors. The fund is for qualified purchasers. Libeara’s site aims it at accredited and institutional investors under Singapore law; the Form D claims Rule 506(c) and the section 3(c)(7) exclusion, so a US holder must be a qualified purchaser. The minimum is $200,000. Redemptions are daily and settle in one to two business days. The assessment is adverse. The service providers are sound, but the fund has shrunk from Libeara’s $195 million claim of December 2025 to about $7 million on rwa.xyz, one private key can replace the token’s code on both chains read, and every transfer between holders waits in a manager contract for an off-chain release. A client who is a qualified purchaser can hold US Treasury funds with larger books and published documents.

Research triggers: events that reopen the assessment or shelf decision
• FundBridge publishes the information memorandum and trust deed, and they settle which register governs
• The default admin, super admin, and operator admin roles move to a multisig with a delay on every chain
• The transfer limit rises so that holders can move units without an off-chain release
• The fund’s units outstanding return above $100 million across the chains read

The research file

What the fund is and holds

FundBridge’s application to the Arbitrum DAO’s STEP 2 program, filed in March 2025, is the fullest public account. ULTRA is the second sub-fund of the Delta Master Trust, an open-ended umbrella unit trust; the first was an SGD fund. It invests in US Treasury securities with less than a year to run and may hold repos, reverse repos, and cash, aiming to beat the ICE BofA 3-Month Treasury Bill Index on a total-return basis. Each sub-fund is a separate trust whose assets the trustee holds for its unitholders, and the custodian must keep them apart from its own. Income stays in the fund, so the unit price rises: DefiLlama priced a unit at $1.0573 on 2026-09-24. The information memorandum, trust deed, and subscription agreement went to the DAO privately and are not public; the fund’s own page on Libeara’s microsite is behind a password.

Size

The first sale was 19 February 2025. The Form D amendment of 3 November 2025 reports $135,341,364 sold to seven investors. Libeara said on 11 December 2025 that ULTRA had “over US$195 million” across Ethereum, Arbitrum, and Avalanche, and named Theo as the anchor investor on Solana. On 2026-09-24 the Ethereum contract carried 797,543 units and the Arbitrum contract 980,358, about $1.9 million together. rwa.xyz, which also counts 4.84 million units on Solana, shows 6.61 million units worth $6.99 million, down 79% in thirty days, held by fifteen wallets. The fund is a small fraction of what its sponsors described nine months ago. Theo’s thBILL, which is sold as exposure to ULTRA, booked 35.7 million of ULTRA as “pending” on 2026-09-23; that figure does not appear in the units outstanding.

Who may hold, and how money gets out

Libeara’s microsite directs the trust “exclusively at accredited investors and institutional investors as defined under the Securities and Futures Act 2001 of Singapore.” The Form D claims section 3(c)(7), which admits only qualified purchasers, so a US holder must be one. Investors complete KYC with FundBridge, whose approval puts the wallet on the contract’s whitelist. The minimum is $200,000 in both the Form D and the application. Subscriptions come in as USDC through an on- and off-ramp provider or as a dollar wire; Vistra checks the cash and the contract mints units. Redemption is the reverse: the holder sends units to the fund’s contract, and FundBridge says it “offers daily redemptions on trading days, with settlement processed within 1-2 business days.” Units may pass between whitelisted holders “subject to the Manager’s approval.”

Who controls the token

On Ethereum and Arbitrum ULTRA is an upgradeable ERC-20 whose verified code sends every transfer through a KYC contract: both wallets must be approved, unless the tokens go to the clawback wallet. Four roles run it, and on both chains each is held by a plain address, one private key. The default admin, 0x3d5d…35bc, can replace the token’s code. The super admin, 0x0af4…7505, can take any balance into a wallet it chooses. The operator admin, 0x2038…cd92, can swap the KYC contract and set the transfer limit. The minter role sits with another plain address and several contracts. FundBridge says every mint, burn, and whitelist change needs its approval in Fireblocks’ MPC app; a key split that way still signs as one address, which is what the chain shows. The contract has no freeze or pause function, but FundBridge says the administrator can blacklist a holder, and a wallet off the KYC list can neither send nor receive. The transfer limit is zero on both chains, so any transfer with a dollar value goes into the manager contract as a “transfer promise” and reaches the recipient only when an off-chain service releases it. The Solana mint is not named in any public document and was not read; Avalanche shows no units.

Comparison and decision

The comparison that decides is with the tokenized US Treasury funds already filed here for qualified purchasers, which publish their terms and hold far more money, and with registered government money funds any client can buy under a prospectus. ULTRA offers a Singapore trust with sound custody and a Wellington mandate, but its documents are private, its on-chain units have fallen to a few million dollars, one key can rewrite the contract, and a holder cannot move units without an off-chain release. The assessment is adverse; the program stays research-only, and it is ineligible for model clients because they are not qualified purchasers.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• SEC EDGAR: Delta Wellington Ultra Short Treasury On-Chain Fund, Form D/A (2025-11-03) · primary · accessed 2026-09-24
  Supports: Rule 506(c), section 3(c)(7), $200,000 minimum, $135.3M sold to seven investors, first sale 2025-02-19
• FundBridge Capital, ULTRA STEP 2 application (Internet Archive copy of 2025-03-22) · primary · accessed 2026-09-24
  Supports: service providers, strategy and benchmark, bankruptcy remoteness, redemption timing, Vistra register copy, Fireblocks MPC approvals, blacklist and clawback
• Libeara funds microsite: Delta Master Trust · primary · accessed 2026-09-24
  Supports: accredited and institutional investors under the SFA, current ratings
• Libeara: ULTRA and MG999 on Solana (2025-12-11) · primary · accessed 2026-09-24
  Supports: over US$195 million AUM claim, Theo as Solana anchor investor
• Verified ULTRA implementation Ultra.sol on Ethereum (Sourcify) · primary · accessed 2026-09-24
  Supports: KYC check, clawback, transfer promises, role-gated upgrade
• rwa.xyz: ULTRA · secondary · accessed 2026-09-24
  Supports: $6.99M total value, units by chain including Solana, fifteen holders, 79% thirty-day decline

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The most administered layer sets the position’s effective control grade; that is a control description, not a quality or suitability score.