Apollo Diversified Credit Securitize Fund (ACRED)
Solana: can freeze a holder, claw back, gate who may hold, mint, change the code. An account only a program can sign for can freeze a holder and claw back tokens. A single key can change the code with no delay.
Subscribers see which of their clients hold this program and whether each household qualifies under these terms, and Ketju emails them when the file changes. $299 per firm per month, first 30 days free.
The verdict is on the memo: Apollo Diversified Credit Securitize Fund (ACRED) Not approved
Eligibility
Each answer quotes the issuer’s own words from the document named under it. Ketju reads each document again and records whether the words are still there. Where the documents say nothing, the row states that.
- What the holder owns
A share of a fund that invests in Apollo Diversified Credit Fund. Securitize’s own filing calls the tokens non-voting, non-redeemable shares, so holders sell their shares back only through the fund’s repurchase offers.
“non-voting, non-redeemable participating shares issued as part of the funds’ respective share capital”
SEC EDGAR: Securitize Holdings prospectus, Form 424B3, filed August 7, 2026 · Notes to the consolidated financial statements, 6. Investment in Funds · words found 2026-10-18
- Who may hold it
Accredited investors who pass Securitize’s identity check and accreditation review, and who buy through Securitize Markets.
“Verify your identity, complete your investment profile questionnaire, and submit an accreditation application”
Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund) · Getting Started, Subscription Process, step 01 · words found 2026-09-23
- First purchase minimum
$50,000, which Securitize’s page shows as a figure in its Minimum Investment tile.
“$50,000”
Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund) · Key facts tile, Minimum Investment · words found 2026-09-23
- Account types
The documents we read do not state this.
Not stated in Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund), Apollo and Securitize, ”Apollo and Securitize Announce Partnership and Launch Tokenized Access to Credit Fund on Aptos, Avalanche, Ethereum, Ink, Polygon, and Solana Networks” (PR Newswire, 2025-01-30), SEC EDGAR: Securitize Tokenized Apollo Diversified Credit Fund, Ltd., Form D/A filed February 12, 2026.
- Who it may be transferred to
The fund’s transfer restrictions and investor eligibility rules limit transfers. Securitize does not promise a secondary market on its page.
“Secondary market trading is not guaranteed and may be limited by regulatory transfer restrictions, platform availability, or investor eligibility requirements.”
Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund) · Live Marketplaces, note under the table · words found 2026-09-23
- How a holder redeems
Monthly redemptions inside a quarterly notice period, with no promise that a full redemption is met.
“$0 Monthly redemptions are available during a quarterly notice period with the fund. Full redemptions are not guaranteed and may be subject to delays due to market conditions or blockchain settlement mechanics.”
Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund) · Fund Profile footnote (7) · words found 2026-09-23
- Who keeps the official record
Securitize is the fund’s transfer agent and fund administrator.
“Securitize also serves as ACRED’s digital transfer agent and fund administrator.”
Apollo and Securitize, ”Apollo and Securitize Announce Partnership and Launch Tokenized Access to Credit Fund on Aptos, Avalanche, Ethereum, Ink, Polygon, and Solana Networks” (PR Newswire, 2025-01-30) · Release body · words found 2026-09-23
- What the issuer says it can freeze or take back
The documents we read do not state this.
Not stated in Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund), Apollo and Securitize, ”Apollo and Securitize Announce Partnership and Launch Tokenized Access to Credit Fund on Aptos, Avalanche, Ethereum, Ink, Polygon, and Solana Networks” (PR Newswire, 2025-01-30), SEC EDGAR: Securitize Tokenized Apollo Diversified Credit Fund, Ltd., Form D/A filed February 12, 2026, SEC EDGAR: Securitize Holdings prospectus, Form 424B3, filed August 7, 2026.
| Fact | Answer |
|---|---|
| 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 |
|---|---|---|---|---|---|
| 2026-02-12 | D/A | Rule 506(c); Investment Company Act section 3(c)(1) | $0 | $110,943,000 | 26 |
| 2025-02-12 | D | Rule 506(c); Investment Company Act section 3(c)(1) | $0 | $40,000,000 | 5 |
Filed by Securitize Tokenized Apollo Diversified Credit Fund, Ltd. (SEC CIK 2056038). Sold to date counts every sale since the first and does not show the fund’s size today. Ketju reads EDGAR daily and reviews this file again when a new filing appears.
- The 2026-02-12 Form D states a $0 minimum; the file records $50,000. The note under “Who may hold it” states which figure Ketju uses.
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 |
EDGAR records Securitize LLC as the former name of Securitize Transfer Agent, LLC, changed 2025-04-14.
Who controls it
Ketju read these powers from the deployed contracts and their verified source code: the token and every contract it checks on a transfer. A power listed here is something the issuer can do; it does not mean the issuer has used it.
| Chain | Freeze a holder | Pause | Claw back | Gate holders | Change the code | Keys held by |
|---|---|---|---|---|---|---|
| Ethereum | Yes | Yes | Yes | Yes | Yes | A single key holds the owner key. |
| Solana | Yes | No | Yes | Yes | Yes | An account only a program can sign for can freeze a holder and claw back tokens. A single key can change the code with no delay. |
Who holds the keys
Ketju read every current holder of each power from the chain on 2026-09-23. A single key is one private key, and whoever holds it acts alone. A multisig needs the stated number of signers. A timelock delays every action, so holders can see it before it takes effect.
| 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 |
| Solana | Mint authority | mint new tokens | an account only a program can sign for | Fr3R46…TYbH |
| Solana | Freeze authority | freeze a holder | an account only a program can sign for | Fr3R46…TYbH |
| Solana | Permanent delegate | claw back tokens | an account only a program can sign for | Fr3R46…TYbH |
| Solana | Transfer-hook authority | decide who may hold, change the code | an account only a program can sign for | Fr3R46…TYbH |
| Solana | Hook program upgrade authority | change the code | a single key | 8d36iv…zbB6 |
Ethereum: 14 contract reads, 6 functions in verified source, 2026-09-23
- eip1967.implementation=0xfc8a9000c161e3c6e073e967107ce926a44a06e2
- owner()=0x59c1eacec450c57dcb9b8725d0f96635c2b676ee
- isPaused()=false
- getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x49465989b80ea0ae4f4129a0f803a4f38b09ea6c
- getDSService(COMPLIANCE_SERVICE)=0xdfe6b0edd2bee2dfe2759b8a5749aa750ff147af
- getDSService(LOCK_MANAGER)=0x4914665651c7ae7f6ef6ffea3dcd554a1a39ec91
- getDSService(OMNIBUS_TBE_CONTROLLER)=0xdcc82829b3eb1d497d2ff982c76eaec44435a4e9
- getDSService(REGISTRY_SERVICE)=0x3a8e9cd2e17e1f2904b7f745da29c9ca765cc319
- getDSService(SECURITIZE_SWAP)=0x368e7478ff8c88c9002c32e1f576fabe2e9ddf7b
- getDSService(TOKEN_REALLOCATOR)=0x7b021a22fe5a6caefd81623ff8fbe7e97b0e61ee
- getDSService(TRANSACTION_RELAYER)=0x9b70f9b94ac226eb5d9f7c33e5b95001f470224e
- getDSService(TRUST_SERVICE)=0xc397436742eaf7c325ddbfc4dc63d95822b27101
- getDSService(WALLET_MANAGER)=0x5275732d1bfe540350165267346537670bc2138a
- getDSService(WALLET_REGISTRAR)=0xddf17a432b312a6c0e42f3b34adbe914b12cb44f
- issueTokensWithNoCompliance in verified source 0xfc8a…06e2
- lockInvestor in verified source 0xf73d…d6c5
- isPaused in verified source 0xfc8a…06e2
- burn in verified source 0xfc8a…06e2
- issueTokens in verified source 0xfc8a…06e2
- upgradeToAndCall in verified source 0xfc8a…06e2
Solana: 4 contract reads, 0 functions in verified source, 2026-09-23
- mintAuthority=Fr3R4632hv5LU2YNXYMnErnLE1XYMe1KPjR8q91KTYbH
- freezeAuthority=Fr3R4632hv5LU2YNXYMnErnLE1XYMe1KPjR8q91KTYbH
- permanentDelegate=Fr3R4632hv5LU2YNXYMnErnLE1XYMe1KPjR8q91KTYbH
- transferHook=FsE8mCJyvgMzqJbfHbJQm3iuf3cRZC6n2vZi1Q8rQCy2
Where it trades
| Venue | Kind |
|---|---|
| Securitize primary market | issuer primary |
Redemption
| Route | Cutoff | Settlement | Fee | Settles in |
|---|---|---|---|---|
| Redeem with the issuer in its window | 2:00 p.m. Eastern | Quarterly repurchase offers of at least 5% of the underlying fund’s shares, with monthly redemptions inside the quarterly notice period. Proceeds arrive once the underlying fund pays, and a full redemption is not guaranteed. The 2025 launch release said redemptions were daily at NAV; the current page says quarterly | 0 bps | USDC, USDG |
- Securitize publishes contract addresses for Avalanche, Polygon, Ink, Sei, or Aptos; Ketju then reads each chain and adds it
- Securitize or Apollo publishes the private placement memorandum; Ketju then reviews the file again for the investor class, the gates, and the distribution policy. Securitize’s page uses limited-partnership wording, which does not match the BVI company on the Form D
- The compliance service, lock manager, proxy target, or owner key on Ethereum changes, or the Solana mint, freeze, permanent-delegate, or transfer-hook authority changes
- Apollo Diversified Credit Fund cuts a quarterly repurchase offer below 5%, prorates tenders, or delays proceeds past the posted deadline
- The fund leaves the 3(c)(1) exclusion or nears 100 beneficial owners
- Anemoy’s Centrifuge wrapper of ACRED (ACRDX), a separate program with its own file, changes how much ACRED it holds or how it redeems
Daily checks
Every day Ketju reads each control function in the table above and the contracts the token checks on a transfer. Ketju compares the token’s on-chain supply with yesterday’s, and its market quote with yesterday’s quote, since a fund of this kind accrues a few basis points a day. Ketju also reads every document quoted above and reviews the file again if a quoted passage disappears from its document. Ketju reads EDGAR for the issuer’s Form D filings and the transfer agent’s registration and reviews the file again when a new filing appears. Ketju counts a new, removed, or changed key as a change only when the chain’s own log shows the grant, revocation, or signer change since yesterday. If the log does not show it, Ketju updates the key list in this file and does nothing more. A change opens a review before any client action. Subscribers get an email that names each of their clients who hold the token, with the household result.
File history
Ketju has not revised this file since filing it. If Ketju revises it, the earlier version stays as published, with the reason.
| Date | Change |
|---|---|
| 2026-09-23 | Filed. |
Sources
- Securitize, ACRED primary-market page · primary · accessed 2026-09-23
Supports: $50,000 minimum, BVI domicile, quarterly redemptions, USDC and USDG ramps, Solana mint via Loopscale market link - Securitize, ACRED primary-market page content (Builder.io content API behind securitize.io/primary-market/apollo-diversified-credit-securitize-fund) · primary · accessed 2026-09-23
Supports: minimum, who may hold, transfer, redemption, quarterly repurchase schedule, feeder into Apollo Diversified Credit Fund - SEC EDGAR: Securitize Tokenized Apollo Diversified Credit Fund, Ltd., Form D/A filed February 12, 2026 · primary · accessed 2026-09-23
Supports: BVI business company, incorporated 2024, Rule 506(c), section 3(c)(1) exclusion, no non-accredited investors, $0 minimum on the form, 26 investors, $110.9M sold, Securitize Markets as placement agent - Apollo and Securitize, ”Apollo and Securitize Announce Partnership and Launch Tokenized Access to Credit Fund on Aptos, Avalanche, Ethereum, Ink, Polygon, and Solana Networks” (PR Newswire, 2025-01-30) · primary · accessed 2026-09-23
Supports: launch chains, Securitize Markets as sole channel, transfer agent and fund administrator, daily-NAV redemptions at launch - SEC EDGAR: Securitize Holdings prospectus, Form 424B3, filed August 7, 2026 · primary · accessed 2026-09-23
Supports: non-voting participating shares, sACRED receipt tokens, ACRED held as loan collateral - ACRED Solana mint metadata (points at metadata.securitize.io) · primary · accessed 2026-09-23
Supports: issuer-anchored Solana mint - Securitize, ”ACRED on Sei: Instant Subscription with Fund Bridging” (Builder.io content API behind the Securitize blog) · primary · accessed 2026-09-23
Supports: Sei deployment, atomic USDC subscription contract, Wormhole bridging - Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: preTransferCheck compliance gate, pause, seize, issueTokens, upgradeToAndCall, owner key shared with the STAC and VBILL contracts