BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I)
Ethereum BUIDL-I: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. A single key holds the owner key.
Solana BUIDL: 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.
In plain words on RIADeFi: BlackRock BUIDL.
This file replaced an earlier version on 2026-09-23. Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager the token consults on every transfer, so the file said the issuer cannot freeze a holder. It can, through lockInvestor. Same claim model, terms, and exit. Earlier versions.
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: BlackRock BUIDL 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
Securitize, the fund’s transfer agent, states that each token is a share of the fund.
“The Company notes that each tokenized share of BUIDL and VBILL represents an ownership interest in the BlackRock USD Institutional Digital Liquidity Fund and VanEck Treasury Fund, Ltd., respectively”
SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Notes to the consolidated financial statements, ”Cash and Cash Equivalents” · words found 2026-10-18
- Who may hold it
Investors eligible for a Rule 506(c) private offering in a Section 3(c)(7) fund, which means qualified purchasers.
“The Fund will issue shares pursuant to Rule 506(c) under the Securities Act of 1933 and Section3(c)(7) of the Investment Company Act.”
BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026) · Press release, fifth paragraph from the end of the body · words found 2026-09-23
- First purchase minimum
$100,000 per outside investor, per the July 2026 Form D. The 2024 launch release said $5 million.
“Minimum investment accepted from any outside investor $ 100,000 USD”
SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026 · Item 11, Minimum Investment · words found 2026-09-23
- First purchase minimum
No document we read states the I Class minimum.
Not stated in BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026), SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026, SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026, SEC EDGAR: Securitize Corp. Form 8-K/A, exhibit 99.2, management’s discussion of results for the quarter ended June 30, 2026 (filed August 13, 2026).
- Account types
The documents we read do not state this.
Not stated in BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026), SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026, SEC EDGAR: BUIDL Form D filing, SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026, SEC EDGAR: Securitize Corp. Form 8-K/A, exhibit 99.2, management’s discussion of results for the quarter ended June 30, 2026 (filed August 13, 2026), Circle: BUIDL-to-USDC transfer contract, BUIDL Solana mint metadata (points at metadata.securitize.io).
- Who it may be transferred to
Holders may transfer at any time, but only to other pre-approved investors.
“Investors can transfer their tokens 24/7/365 to other pre-approved investors.”
BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026) · Press release body · words found 2026-09-23
- How a holder redeems
At NAV, $1 per share, for cash. The transfer agent names no cutoff or settlement time.
“BUIDL and VBILL tokens can be redeemed at their net asset value which is $1 per share and are readily convertible to cash.”
SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Notes to the consolidated financial statements, ”Cash and Cash Equivalents” · words found 2026-10-18
- Who keeps the official record
Securitize, the SEC-registered transfer agent, uses a public blockchain as the master securityholder file for most clients. The passage does not name BUIDL.
“As part of our Asset Servicing offering, we act as the official SEC-registered transfer agent for the majority of our customers. We use distributed ledger technology in the form of a public blockchain as the master securityholder file to provide recordkeeping, accounting, reporting, examination and other services.”
SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Business, ”Securitize’s Role” · words found 2026-10-18
- What the issuer says it can freeze or take back
Securitize says its smart contracts can seize or burn tokens to fix minting or allocation errors.
“While Securitize’s smart contracts provide mechanisms to seize or burn tokens to remediate these situations, such incidents could lead to temporary imbalances, customer disputes, or reputational harm.”
SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · Risk Factors, token minting and allocation errors · words found 2026-10-18
| Fact | Answer |
|---|---|
| Who onboards the holder | broker dealer |
| Voting rights | None |
| Distributions | new tokens |
| 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 |
|---|---|---|---|---|---|
| 2026-07-27 | D/A | Rule 506(c); Investment Company Act section 3(c)(7) | $100,000 | $5,135,523,412 | 28 |
| 2025-07-18 | D/A | Rule 506(c); Investment Company Act section 3(c)(7) | $100,000 | $3,251,152,228 | 42 |
| 2024-03-18 | D | Rule 506(c); Investment Company Act section 3(c)(7) | $100,000 | $0 | 0 |
Filed by BlackRock USD Institutional Digital Liquidity Fund Ltd. (SEC CIK 2013810). 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 2026-07-27 Form D states a $100,000 minimum; the file records $5,000,000. 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.
| Token | Chain | Freeze a holder | Pause | Claw back | Gate holders | Change the code | Keys held by |
|---|---|---|---|---|---|---|---|
| BUIDL | Ethereum | Yes | Yes | Yes | Yes | Yes | A single key holds the owner key. |
| BUIDL-I | Ethereum | Yes | Yes | Yes | Yes | Yes | A single key holds the owner key. |
| BUIDL | 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.
| Token | Chain | Key | What it can do | Held by | Address |
|---|---|---|---|---|---|
| BUIDL | Ethereum | Owner | grant and revoke these powers | a single key | 0xe016…b09e |
| BUIDL | Ethereum | Wallet registrar owner | decide who may hold, grant and revoke these powers | a single key | 0xf3aa…27d9 |
| BUIDL-I | Ethereum | Owner | grant and revoke these powers | a single key | 0xe016…b09e |
| BUIDL-I | Ethereum | Wallet registrar owner | decide who may hold, grant and revoke these powers | a contract run by a single key | 0xc537…9765 |
| BUIDL | Solana | Mint authority | mint new tokens | an account only a program can sign for | APm3MW…2kbJ |
| BUIDL | Solana | Freeze authority | freeze a holder | an account only a program can sign for | APm3MW…2kbJ |
| BUIDL | Solana | Permanent delegate | claw back tokens | an account only a program can sign for | APm3MW…2kbJ |
| BUIDL | Solana | Transfer-hook authority | decide who may hold, change the code | an account only a program can sign for | APm3MW…2kbJ |
| BUIDL | Solana | Hook program upgrade authority | change the code | a single key | 8d36iv…zbB6 |
Ethereum BUIDL: 14 contract reads, 6 functions in verified source, 2026-09-23
- eip1967.implementation=0x603bb6909be14f83282e03632280d91be7fb83b2
- owner()=0xe01605f6b6dc593b7d2917f4a0940db2a625b09e
- isPaused()=false
- target()=0x603bb6909be14f83282e03632280d91be7fb83b2
- getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x1dc378568cefd4596c5f9f9a14256d8250b56369
- getDSService(COMPLIANCE_SERVICE)=0x07a1ebfb9a9a421249ddc71bddb8860cc077e3a9
- getDSService(LOCK_MANAGER)=0x0a65a40a4b2f64d3445a628abcfc8128625483a4
- getDSService(OMNIBUS_TBE_CONTROLLER)=0x59a100bcc70649485422670dc697b64bd1c6e6c1
- getDSService(REGISTRY_SERVICE)=0x0dac900f26de70336f2320f7ccedee70ff6a1a5b
- getDSService(TOKEN_REALLOCATOR)=0xf33675685c8ee774c7f5655c93afedc7b9818ecd
- getDSService(TRANSACTION_RELAYER)=0xd75c86c3e3761e2b2a7960afb670850923899473
- getDSService(TRUST_SERVICE)=0x3a68756d0335e75c909ba1e8fefc1d4832c36c60
- getDSService(WALLET_MANAGER)=0x13cdc85f7bcd5c1f9cbbff0e2d11532eb9abef74
- getDSService(WALLET_REGISTRAR)=0x008075b22bec05c7d0fb789e3420b76056d76cab
- issueTokensWithNoCompliance in verified source 0x603b…83b2
- lockInvestor in verified source 0x0e4d…9fda
- isPaused in verified source 0x603b…83b2
- burn in verified source 0x603b…83b2
- issueTokens in verified source 0x603b…83b2
- setTarget in verified source 0x603b…83b2
Ethereum BUIDL-I: 13 contract reads, 6 functions in verified source, 2026-09-23
- eip1967.implementation=0x9e2693f54831f6f52b0bb952c2935d26919a3626
- owner()=0xe01605f6b6dc593b7d2917f4a0940db2a625b09e
- isPaused()=false
- getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x41a5f31c45fa12913e125914bd79ef49befa1a1f
- getDSService(COMPLIANCE_SERVICE)=0xc7ca0ce7626940838a87656656c6af92b95abd00
- getDSService(LOCK_MANAGER)=0x32708a900a740846445fd49c0c00df15701720a2
- getDSService(OMNIBUS_TBE_CONTROLLER)=0xddf7b95d79872766b4c0f32284fac86155c81b3a
- getDSService(REGISTRY_SERVICE)=0xf8e91fa34311876302d36d14b4f246044fd4332a
- getDSService(TOKEN_REALLOCATOR)=0x95e07b0682da8627decbb068cb57ae7ebe650e9e
- getDSService(TRANSACTION_RELAYER)=0xfd45dd1f78f9501b4e37b7a02e24ec29da64917f
- getDSService(TRUST_SERVICE)=0x712244c054244432d0f9ea16a56121598eba7a2c
- getDSService(WALLET_MANAGER)=0x1df0616fd703643411d62c34dfbfa3a261df7dab
- getDSService(WALLET_REGISTRAR)=0x51d016b8cc89f56fd5a7970892586fb512e202a0
- issueTokensWithNoCompliance in verified source 0x9e26…3626
- lockInvestor in verified source 0xea9b…edcc
- isPaused in verified source 0x9e26…3626
- burn in verified source 0x9e26…3626
- issueTokens in verified source 0x9e26…3626
- upgradeToAndCall in verified source 0x9e26…3626
Solana BUIDL: 4 contract reads, 0 functions in verified source, 2026-09-23
- mintAuthority=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
- freezeAuthority=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
- permanentDelegate=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
- transferHook=FsE8mCJyvgMzqJbfHbJQm3iuf3cRZC6n2vZi1Q8rQCy2
Where it trades
| Venue | Kind |
|---|---|
| Securitize primary market | issuer primary |
Redemption
| Route | Settlement | Settles in |
|---|---|---|
| Redeem with the issuer in its window | Daily redemption through Securitize in U.S. dollars at the stable $1.00 token value | USD |
| Redeem with the issuer in its window | Circle exchanges BUIDL for USDC on demand for approved holders, through a smart contract | USDC |
| Redeem with the issuer in its window | I Class: on chain, holders send BUIDL-I to one address (0x8780…4200), and Securitize burns it there. Holders sent 24,999,000 tokens on 21 September 2026, which Securitize burned on 22 September; it burned 250 million on 17 September. No document we read states the I Class cutoff or how the dollars are paid. | USD |
- The Securitize compliance service, lock manager, proxy target, or issuer role on either Ethereum contract (BUIDL or BUIDL-I) changes
- The Solana mint authority, freeze authority, permanent delegate, or transfer-hook program changes
- A share class opens to accredited investors or below the $5 million minimum
- A NAV break, missed redemption, or unauthorized mint or transfer
- BlackRock or Securitize publishes contract identities for the other five networks; Ketju then reads those chains and adds them
- BlackRock or Securitize states which minimum applies, the $5 million in the launch release or the $100,000 in every Form D
- BlackRock or Securitize publishes the I Class terms (minimum, fee, eligible investors, redemption), or the I Class appears on a chain other than Ethereum
- The two contracts that hold 97% of BUIDL-I (a verified contract named ALMProxy and a Safe multisig) leave, or the I Class holder count changes by more than a few wallets
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 its one-dollar value. 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 revised this file 3 times since filing it. Ketju keeps each earlier version as published, with the reason for the change.
| Date | Change |
|---|---|
| 2026-09-23 | Filed. |
| 2026-09-23 | Revised. Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager the token consults on every transfer, so the file said the issuer cannot freeze a holder. It can, through lockInvestor. Same claim model, terms, and exit. |
| 2026-09-23 | Revised. Superseded to quote the issuer’s terms: every Form D states a $100,000 minimum while the launch release states $5 million; the file keeps the higher figure and says so. |
| 2026-09-23 | Revised. Superseded to add the I Class (BUIDL-I), a second class of the same fund that the file did not list: an Ethereum Securitize DS token holding 239.7 million shares across six wallets on 23 September 2026, run by the same owner key as BUIDL. The file moves to file-records/blackrock-buidl.ts; the BUIDL class terms, contracts, and readings are unchanged. |
Sources
- SEC EDGAR: BUIDL Form D filing · primary · accessed 2026-08-01
Supports: Rule 506(c) private placement, Section 3(c)(7) fund - BlackRock and Securitize: BUIDL launch terms · primary · accessed 2026-08-01
Supports: $5 million initial minimum, qualified purchasers, stable $1 token value, daily accrued dividends paid monthly as new tokens, Securitize as transfer agent - Securitize: BUIDL Solana share class and seven networks · primary · accessed 2026-08-01
Supports: Solana share class, multi-network issuance - Circle: BUIDL-to-USDC transfer contract · primary · accessed 2026-08-01
Supports: USDC exit on demand - BUIDL Solana mint metadata (points at metadata.securitize.io) · primary · accessed 2026-09-23
Supports: issuer-anchored Solana mint, permanent delegate, transfer hook, freeze authority - Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: preTransferCheck compliance gate, pause, seize and omnibusSeize, issueTokens, setTarget upgrade - BlackRock and Securitize press release on Business Wire, March 20, 2024: BlackRock Launches Its First Tokenized Fund, BUIDL (Wayback Machine capture, June 16, 2026) · primary · accessed 2026-09-23
Supports: who may-hold, transfer - SEC EDGAR: BlackRock USD Institutional Digital Liquidity Fund Ltd., Form D/A filed July 27, 2026 · primary · accessed 2026-09-23
Supports: minimum - SEC EDGAR: Securitize Corp. (BUIDL transfer agent) prospectus, Form 424B3, filed August 7, 2026 · primary · accessed 2026-09-23
Supports: redemption, record, freeze, token is an ownership interest in the fund - SEC EDGAR: Securitize Corp. Form 8-K/A, exhibit 99.2, management’s discussion of results for the quarter ended June 30, 2026 (filed August 13, 2026) · primary · accessed 2026-09-23
Supports: BUIDL-I is a Securitize platform asset, BUIDL-I subscriptions and redemptions drove Q2 volume - Verified BUIDL-I implementation on Ethereum (Sourcify, DSToken) · primary · accessed 2026-09-23
Supports: I Class token is a Securitize DS token, burn, pause, issueTokens, upgradeToAndCall - Blockscout: BUIDL-I token on Ethereum (name, supply, holders, transfers) · secondary · accessed 2026-09-23
Supports: on-chain name names the fund and the I Class, 239.7 million supply, six holders, dividend mints each business day, burns from a redemption address, created 17 December 2024 - CoinGecko: BlackRock USD Institutional Digital Liquidity Fund - I Class · secondary · accessed 2026-09-23
Supports: price $1.00 with no market capitalization, stale supply of 71.9 million, Ethereum only