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Eligibility file · Treasury fund

BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I)

What the client owns
Share of a British Virgin Islands private fund holding cash, U.S. Treasury bills, and repurchase agreements; I Class share of the same British Virgin Islands fund; one token is one share at a stable $1.00. Issuer direct: The on-chain record is the securityholder file; the holder is the registered owner.
Who may hold it
US qualified purchasers. First purchase $5,000,000. BlackRock’s 2024 launch release states a $5 million minimum; every Form D on EDGAR, through July 2026, states $100,000 for any outside investor. We use the higher figure until BlackRock or Securitize says which applies. The I Class (BUIDL-I) is a class of the same fund, sold under the same Form D, so the same qualified-purchaser test applies. No BlackRock or Securitize document we read states the I Class minimum, fee, or intended investors.
Who can freeze or claw back
Ethereum BUIDL: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. A single key holds the owner key.
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.
How a holder redeems
Redeem with the issuer in its window. Daily redemption through Securitize in U.S. dollars at the stable $1.00 token value. Settles in USD.

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 Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager the token consults on every transfer, so the file said the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

Issuer
BlackRock USD Institutional Digital Liquidity Fund Ltd. (BVI); BlackRock Financial Management as manager; Securitize as transfer agent and placement agent
Registration
Private placement, Rule 506(c)
Official record
Securitize, LLC, SEC-registered transfer agent
Instruments
BUIDL BUIDL-I
Chains
Ethereum, Solana
Reviewed
2026-09-23
Next review
2027-03-23

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

FactAnswer
Who onboards the holderbroker dealer
Voting rightsNone
Distributionsnew tokens
SIPC coverage of the walletNo

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.

FiledFormExemption claimedMinimumSold to dateInvestors
2026-07-27D/ARule 506(c); Investment Company Act section 3(c)(7)$100,000$5,135,523,41228
2025-07-18D/ARule 506(c); Investment Company Act section 3(c)(7)$100,000$3,251,152,22842
2024-03-18DRule 506(c); Investment Company Act section 3(c)(7)$100,000$00

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 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.

AgentSEC fileOn EDGAR sinceTA-2 periodAccountsIssues with master fileWork it hires out
Securitize Transfer Agent, LLC084-066382019-07-222025-12-3118,33754PACIFIC 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.

TokenChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
BUIDLEthereumYesYesYesYesYesA single key holds the owner key.
BUIDL-IEthereumYesYesYesYesYesA single key holds the owner key.
BUIDLSolanaYesNoYesYesYesAn 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.

TokenChainKeyWhat it can doHeld byAddress
BUIDLEthereumOwnergrant and revoke these powersa single key0xe016…b09e
BUIDLEthereumWallet registrar ownerdecide who may hold, grant and revoke these powersa single key0xf3aa…27d9
BUIDL-IEthereumOwnergrant and revoke these powersa single key0xe016…b09e
BUIDL-IEthereumWallet registrar ownerdecide who may hold, grant and revoke these powersa contract run by a single key0xc537…9765
BUIDLSolanaMint authoritymint new tokensan account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaFreeze authorityfreeze a holderan account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaPermanent delegateclaw back tokensan account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaTransfer-hook authoritydecide who may hold, change the codean account only a program can sign forAPm3MW…2kbJ
BUIDLSolanaHook program upgrade authoritychange the codea single key8d36iv…zbB6
Ethereum BUIDL: 14 contract reads, 6 functions in verified source, 2026-09-23
Read from the chain
  • 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
Read from verified source
Ethereum BUIDL-I: 13 contract reads, 6 functions in verified source, 2026-09-23
Read from the chain
  • 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
Read from verified source
Solana BUIDL: 4 contract reads, 0 functions in verified source, 2026-09-23
Read from the chain
  • mintAuthority=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
  • freezeAuthority=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
  • permanentDelegate=APm3MWbXfMMKAWgsDVnxcAGbLjvRxubPu1A8a5SA2kbJ
  • transferHook=FsE8mCJyvgMzqJbfHbJQm3iuf3cRZC6n2vZi1Q8rQCy2

Where it trades

VenueKind
Securitize primary marketissuer primary

Redemption

RouteSettlementSettles in
Redeem with the issuer in its windowDaily redemption through Securitize in U.S. dollars at the stable $1.00 token valueUSD
Redeem with the issuer in its windowCircle exchanges BUIDL for USDC on demand for approved holders, through a smart contractUSDC
Redeem with the issuer in its windowI 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

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.

DateChange
2026-09-23Filed.
2026-09-23Revised. 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.
2026-09-23Revised. 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.
2026-09-23Revised. 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

Every file is public. With a subscription, Ketju checks each of your households against the file and checks the file every day. $299 per firm per month, first 30 days free. Start the trial.