Eligibility file · Credit fund

Coinbase USD Stablecoin Yield Fund (CUSHY)

What the client owns

Share of a Cayman feeder whose manager lends stablecoins and buys credit, targeting SOFR plus 4 to 7 percentage points. Not stated: The issuer’s documents do not say whether the chain or an off-chain register governs. Ketju records the date it checked.

Who may hold it

US qualified purchasers. First purchase $100,000. Superstate’s fund page lists eligible investors as “US UBO, Qualified Purchasers, Non-US UBOs qualified per their jurisdiction” and the structure as an open-ended 506(c) fund. The Form D filed 23 June 2026 claims Rule 506(c) and the Investment Company Act section 3(c)(7) exclusion, which admits only qualified purchasers, so we treat the fund as open to qualified purchasers only. The Form D states the same $100,000 minimum and says the manager may raise, lower, or waive it. It reports $25,000,000 sold to 2 investors since the first sale on 11 June 2026. Investors onboard with Superstate, Northern Trust, and Coinbase Asset Management.

Who can freeze or claw back

Solana: can freeze a holder, claw back, gate who may hold, mint. An account only a program can sign for can freeze a holder and claw back tokens.
Base: can pause transfers, claw back, gate who may hold, mint, change the code. A single key holds the owner key. A single key, through a contract, can change the code with no delay.

How a holder redeems

Redeem with the issuer in its window. Quarterly. Proceeds are paid through Northern Trust, as administrator, on the Redemption Dealing Day for requests received in the previous calendar quarter. One sentence of Superstate’s documentation says liquidity is offered at month end; its fund page and redemption section say quarterly, and we follow them. Settles in USD, USDC.

This file replaced an earlier version on 2026-09-24. Superseded to settle the Base freeze power the file had marked unverified: the whole transfer path is now read from verified source, and it has no freeze on Base. 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: Coinbase USD Stablecoin Yield Fund (CUSHY) Not approved

Issuer

Coinbase Tokenized Stablecoin Yield Feeder Fund Ltd (Cayman Islands exempted company, SEC CIK 2138534); Coinbase Asset Management, LLC as investment manager; Northern Trust Global Fund Services Cayman Limited as administrator; Superstate Services LLC as transfer agent; Coinbase Custody Trust Company as custodian

Registration

Private placement, Rule 506(c)

Official record

Superstate Services LLC (SEC-registered transfer agent, named on Superstate’s fund page); Northern Trust handles subscriptions and redemptions as administrator. The documents we read do not state whether the transfer agent’s books or the chain govern., SEC-registered transfer agent

Instruments

CUSHY

Chains

Solana, Base

Reviewed

2026-09-24

Next review

2027-03-24

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 Cayman fund that earns yield from stablecoin lending and credit.

“CUSHY seeks to generate yield from high-quality stablecoin private credit, direct lending, and tokenized credit opportunities.”

Superstate docs: Coinbase CUSHY · Fund information · words found 2026-09-24

Who may hold it

Qualified purchasers, and non-US owners qualified where they live; the Form D’s 3(c)(7) claim means qualified purchasers.

“US UBO, Qualified Purchasers, Non-US UBOs qualified per their jurisdiction”

Superstate: CUSHY, Coinbase USD Stablecoin Yield Fund (fund page) · Details, Eligible investors · words found 2026-09-24

First purchase minimum

$100,000.

“The minimum initial investment is $100,000.”

Superstate docs: Coinbase CUSHY · Subscribing · words found 2026-09-24

Who it may be transferred to

Only between allowlisted wallets.

“CUSHY is freely transferable between wallet addresses on the Allowlist.”

Superstate docs: Coinbase CUSHY · Introduction · words found 2026-09-24

How a holder redeems

Quarterly, paid on the dealing day after the quarter in which the request arrives.

“Proceeds are delivered on the Redemption Dealing Day for requests received in the previous calendar quarter.”

Superstate docs: Coinbase CUSHY · Redeeming · words found 2026-09-24

Who keeps the official record

Superstate Services LLC is the transfer agent. The documents we read do not state whether its books or the chain govern.

“Superstate Services LLC”

Superstate: CUSHY, Coinbase USD Stablecoin Yield Fund (fund page) · Service providers, Transfer agent · words found 2026-09-24

What the issuer says it can freeze or take back

Superstate’s admin key can add and remove wallets from the allowlist and burn a holder’s tokens.

“This includes all minting, adding or removing users from the allowlist, and forcibly burning an investor’s tokens (if required by exogenous legal circumstances, for example).”

Superstate docs: Smart contracts · EVM contracts · words found 2026-09-24

Fact	Answer
Who onboards the holder	issuer
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
2026-06-23	D	Rule 506(c); Investment Company Act section 3(c)(7)	$100,000	$25,000,000	2

Filed by Coinbase Tokenized Stablecoin Yield Feeder Fund Ltd (SEC CIK 2138534). 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.

Agent	SEC file	On EDGAR since	TA-2 period	Accounts	Issues with master file	Work it hires out
Superstate Services LLC	084-06972	2025-02-03	2025-12-31	107	0	None

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
Solana	Yes	No	Yes	Yes	No	An account only a program can sign for can freeze a holder and claw back tokens.
Base	No	Yes	Yes	Yes	Yes	A single key holds the owner key. A single key, through a contract, can change the code with no delay.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-24. 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
Solana	Mint authority	mint new tokens	a single key	7gF8fi…xAHF
Solana	Freeze authority	freeze a holder	an account only a program can sign for	2Yq4T3…pM7x
Solana	Permanent delegate	claw back tokens	an account only a program can sign for	2Yq4T3…pM7x
Base	Owner	grant and revoke these powers	a single key	0xb6c7…1731
Base	Proxy admin	change the code	a contract run by a single key	0x9c3a…30db
Base	Allowlist owner	decide who may hold, grant and revoke these powers	a single key	0x7747…b2fe

Solana: 4 contract reads, 0 functions in verified source, 2026-09-24

Read from the chain

mintAuthority=7gF8fi4zEebLNGME2Qb5BM5AVasUJ5FeXrMho9DvxAHF
freezeAuthority=2Yq4T3mPNfjtEyTxSbRjRKqLf1pwbTasuCQrWe6QpM7x
permanentDelegate=2Yq4T3mPNfjtEyTxSbRjRKqLf1pwbTasuCQrWe6QpM7x
defaultAccountState=frozen

Base: 5 contract reads, 4 functions in verified source, 2026-09-24

Read from the chain

eip1967.implementation=0xaa9f823300e38ef419e3d66d6fb195d6444346d1
eip1967.admin=0x9c3a0bea94c1246cafe93456fb735406bfbe30db
owner()=0xb6c711108929efd444c54472fe6abd1db08b1731
paused()=false
allowlist()=0x157dae58e832459cd2bd3a8007e50b2b1b3fcf1a

Read from verified source

allowlist in verified source 0xaa9f…46d1
accountingPause in verified source 0xaa9f…46d1
adminBurn in verified source 0xaa9f…46d1
mint in verified source 0xaa9f…46d1

Where it trades

Venue	Kind
Superstate	issuer primary

Redemption

Route	Settlement	Settles in
Redeem with the issuer in its window	Quarterly. Proceeds are paid through Northern Trust, as administrator, on the Redemption Dealing Day for requests received in the previous calendar quarter. One sentence of Superstate’s documentation says liquidity is offered at month end; its fund page and redemption section say quarterly, and we follow them	USD, USDC

Review triggers

Coinbase Asset Management or Superstate publishes the offering memorandum; Ketju then reviews the file again for the investor class, the gates, and the redemption terms
The Solana mint, freeze, or permanent-delegate authority changes, or the Base owner, proxy admin, or implementation changes
Superstate settles whether redemptions are monthly or quarterly, or the fund gates or delays a redemption
A Form D amendment changes the minimum, the exemption, or the investor count

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 revised this file once since filing it. Ketju keeps each earlier version as published, with the reason for the change.

Date	Change
2026-09-24	Filed.
2026-09-24	Revised. Superseded to settle the Base freeze power the file had marked unverified: the whole transfer path is now read from verified source, and it has no freeze on Base.

Sources

Superstate: CUSHY, Coinbase USD Stablecoin Yield Fund (fund page) · primary · accessed 2026-09-24
Supports: eligible investors, Cayman domicile, 506(c) open-ended, monthly subscriptions, quarterly redemptions, service providers, Solana and Base contracts, $25.2M AUM, 0.75% tokenized-class fee
Superstate docs: Coinbase CUSHY · primary · accessed 2026-09-24
Supports: $100,000 minimum, transfers between allowlisted wallets, Northern Trust administrator, quarterly redemption dealing, monthly NAV
Superstate docs: Smart contracts · primary · accessed 2026-09-24
Supports: upgradeable contracts, admin mints, allowlists, and burns
SEC EDGAR: Coinbase Tokenized Stablecoin Yield Feeder Fund Ltd, Form D filed June 23, 2026 · primary · accessed 2026-09-24
Supports: Cayman exempted company, Rule 506(c), section 3(c)(7), $100,000 minimum, waivable, 2 investors, $25M sold, Coinbase Asset Management as investment manager
CUSHY Solana token metadata (api.superstate.com) · primary · accessed 2026-09-24
Supports: issuer-anchored Solana mint
CUSHY implementation on Base (Blockscout verified source, FundTokenV1_3_0) · primary · accessed 2026-09-24
Supports: allowlist, accountingPause, adminBurn, mint

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.