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Tokenized real-world assets

Exodus Movement (EXOD) common stock tokens

Not approved No defect found; not on the approved list
Verdict
Not approved
No defect found; not on the approved list
Who can freeze it
Governed, no freeze
Withdrawals
There is no redemption, because the token is a claim on no one.
Reviewed
2026-10-18 · next 2026-12-23
Researched memo

Summary

Ketju does not approve the EXOD common stock tokens: they are a sound record of a listed share, but only record holders can use them and selling takes about five business days. Exodus Movement put its own stock on a blockchain. Each share of Class A common stock (NYSE American: EXOD, CUSIP 30209R106) has a matching Common Stock Token. The token carries no ownership of the share. The Form 10 that took Exodus to the NYSE American in December 2024 says the tokens ”give no ownership interest in the Class A common stock.” Ownership is ”recorded solely on the books” of Securitize, the SEC-registered transfer agent. Moving a token between two wallets Securitize has whitelisted tells Securitize to move the share on its books. In the SEC staff’s January 28, 2026 terms, that is the issuer-indirect model. On September 23, 2026 about 11.16 million EXIT tokens sat outside Securitize’s reserve on Algorand, 10.96 million of them in one address. That is slightly more than the 11,015,102 Class A shares Exodus reported on August 3, 2026, and we could not reconcile the gap from public records. Securitize can claw back and burn Algorand tokens, and Superstate’s Solana mint has a permanent delegate. A client can hold these tokens, because they record a listed share the client can own directly. The token adds nothing to the share’s rights and takes the custodian out of the record. The research so far supports use with limits: the client holds as a record holder, in a wallet the client controls, and plans sales five business days out. For most clients the share in a brokerage account is the better way to own EXOD.

Changes

2026-10-18The memo’s first sentence said Ketju had not reached a verdict on the EXOD common stock tokens, but the Register showed Not approved. Ketju found no defect in the tokens and has not approved them, because only record holders can use them. Ketju corrected the first sentence, and the verdict did not change. The prior memo

Research

How it works

The April 9, 2021 offering circular set the rule that still holds: ”Common Stock Tokens are not shares of Class A common stock; rather, they are digital representations of the number of shares purchased and held by a given stockholder.” They carry no voting, governance or economic rights and ”cannot be traded independently of the Class A common stock.” Exodus sold $75 million of Class A stock at $27.42 a share under Regulation A+, paid in Bitcoin, Ether or USDC, with Securitize as transfer agent. The tokens went live on Algorand in 2021 under the ticker EXIT.

The SEC staff pressed the point during the Form 10 review in 2024. Its October 31, 2024 letter said calling the tokens analogous to paper certificates conflicted with the statement that tokens give no ownership interest, and Exodus removed the analogy. Its November 12, 2024 reply called the tokens ”digital markers” that ”are devoid of any legal rights or economic value.” When Exodus moved its charter from Delaware to Texas on December 8, 2025, each token ”automatically continued in existence” and now represents the Texas share.

Under the SEC staff statement of January 28, 2026, an issuer can put the securityholder file on-chain (issuer-direct). Or it can issue a token that ”does not convey any rights, obligations, or benefits of the security” and is used ”indirectly to effect transfers of the security on the master securityholder file.” Exodus’s filings describe the second model. Since October 2025 a holder can also move shares to Superstate and hold them as a token on Solana. Exodus’s own release says those tokens ”are not shares” either. The Knowledge Base page that says ”Legal ownership is recorded on-chain via Superstate’s Opening Bell” contradicts the October 20, 2025 release. It also contradicts the 10-K, which says the tokenized stock ”represents the same ownership interests as the corresponding shares … reflected in the company’s official share register.” The filings control.

Who controls it

Securitize keeps the master file. On Algorand it uses a standard asset, because Algorand does not support its DS Protocol. The asset is frozen by default, and Securitize unfreezes a wallet only after KYC. When a token moves, Securitize checks both wallets and the transfer restrictions and records the share transfer. It reconciles its books against the chain at each transfer and nightly, and on a mismatch it may reverse the transaction, relying on Rules 17Ad-10 and 17Ad-11. Asset 213345970 names one account, MAKF3…, as manager, reserve and clawback. The Form 10 says only Securitize can create or delete tokens. The offering circular says Securitize uses clawback to pull tokens from a seller’s wallet and burn them.

Superstate Services LLC, a second SEC-registered transfer agent, became co-transfer agent under an August 8, 2025 agreement that pays it $1 a year. Superstate keeps ”Subsidiary Security holder Records” for shares it holds and passes changes to Securitize for the master file. It must keep an allowlist of wallets and DEX pools and program the token so only allowlisted addresses can hold it. It mints or burns on a shareholder’s written instruction. On termination it may ”freeze the continued ability to transfer Tokenized Shares.” The Solana mint is a Token-2022 mint with frozen default accounts and a permanent delegate. Superstate showed 60 shares on Solana and 250 in book entry on September 23, 2026.

Amendment No. 6 to the Securitize agreement, effective August 28, 2025, prices each new tokenized share class at $7,500. On Arbitrum a Securitize DS token named $EXOD-B holds 19,072,962 units, close to the 19,188,156 Class B shares outstanding. No Exodus filing we found describes it.

Eligibility

Anyone who can own EXOD can hold the token, but only as a record holder. The Form 10 says tokens are ”available only to record holders”; tokens for shares in street name at DTC ”will be held by Securitize.” Shares bought on the exchange sit in street name at DTC. A brokerage client must ask the broker to direct-register (DRS) the shares with Securitize’s co-agent, Pacific Stock Transfer, which takes about five business days. The client must then create a Securitize ID, pass KYC and register an Algorand wallet by email. For Solana, the holder then signs a transfer document to move book-entry shares to Superstate (requests after 1 p.m. ET go the next business day), adds a Solana wallet to Superstate’s allowlist, and tokenizes.

The 2021 offering excluded residents of Arizona, Florida and Texas from the primary sale. That limit applied to the offering, and no filing we read limits holding by state. The whitelist admits ”persons or entities.” No minimum appears in any filing or support page we read. Exodus’s FAQ says brokerages and custodians do not support the tokens, which are ”intended for use in self-custodial environments.”

Withdrawals

There is no redemption, because the token is a claim on no one. To sell, a holder sends Algorand tokens back to Securitize, which burns them and books the shares. A Solana holder first detokenizes at Superstate and moves the shares to Securitize. A broker then pulls the shares by DRS, and the holder sells on the NYSE American for dollars. Exodus puts the full trip at about five business days. Token transfers between whitelisted record holders also move the shares, but neither Exodus nor Securitize publishes counterparties.

Trading venues

The venues that once traded the token have closed. Securitize Markets stopped trading EXOD in October 2023, and the tZERO ATS in December 2023. The stock moved to the OTCQB in January 2024, the OTCQX in April 2024, and the NYSE American on December 18, 2024. The Form 10 predicted that token use ”will meaningfully decrease” once shares settled through DTC, and the numbers bear it out. About 208,000 of 11 million Class A tokens sit in some 3,300 Algorand wallets other than the two largest.

Client considerations

Rights, votes and any dividend follow the share on Securitize’s books; the token carries none of them. A client who holds EXOD in token form is a direct-registered shareholder holding a self-custodied pointer to the share. The client is no brokerage customer: there is no SIPC cover and no custodian statement, and the client must guard a key. An adviser who held the key would have custody. Securitize can claw back and burn Algorand tokens and reverse transfers it finds wrong, and Superstate’s delegate can move Solana tokens. A mistaken or stolen token is fixed on the books; the chain does not settle it. Exodus also reserves the right to stop using tokens. Counterfeit Algorand assets named Exodus or EXOD exist, including one named ”213345970.” Only asset 213345970 carries Securitize’s clawback. EXOD is a controlled company, and Class B shares carry ten votes each. The token works as a record and does not work for trading. It suits only a client who wants to hold EXOD in self-custody on purpose.

Sources

Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.

The asset and the chain

This memo covers the protocol. A position also holds an asset and settles on a chain. Whichever of the three holds the most power over the position decides who can freeze it. These tables describe control and do not judge quality.

ChainVerdictFreezeWhat it can do
SolanaApproved with limits Governed, no freeze no admin key can seize funds, but stake is concentrating and the Nakamoto coefficient is below 25.
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