Delta Wellington Ultra Short Treasury On-Chain Fund (ULTRA)
Arbitrum: can claw back, gate who may hold, mint, change the code. A single key holds the admin key.
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The verdict is on the memo: Delta Wellington Ultra Short Treasury On-Chain Fund (ULTRA) 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 unit of the ULTRA sub-fund, with the rights the Delta Master Trust deed gives unitholders.
“Investors are unitholders of ULTRA and are entitled to the rights set out in the trust deed”
FundBridge Capital, ULTRA STEP 2 application to the Arbitrum DAO (Internet Archive copy of 2025-03-22) · Question 13 · words found 2026-09-24
- Who may hold it
Accredited and institutional investors under Singapore law; the Form D’s 3(c)(7) claim means a US holder must be a qualified purchaser.
“directed exclusively at accredited investors and institutional investors as defined under the Securities and Futures Act 2001 of Singapore”
Libeara funds microsite: Delta Master Trust landing page · Footer notice · words found 2026-09-24
- First purchase minimum
$200,000, per the Form D and FundBridge’s application.
“Minimum investment accepted from any outside investor $ 200,000 USD”
SEC EDGAR: Delta Wellington Ultra Short Treasury On-Chain Fund, Form D/A filed November 3, 2025 · Item 11, Minimum Investment · words found 2026-09-24
- Who it may be transferred to
Only between whitelisted, onboarded holders, and subject to the manager’s approval.
“ULTRA is an open-ended fund with tokenised units capable of being transferred peer-to-peer (P2P) between eligible parties on the Libeara platform”
FundBridge Capital, ULTRA STEP 2 application to the Arbitrum DAO (Internet Archive copy of 2025-03-22) · Question 20 · words found 2026-09-24
- How a holder redeems
Daily on trading days, settled in one to two business days.
“The Manager offers daily redemptions on trading days, with settlement processed within 1-2 business days.”
FundBridge Capital, ULTRA STEP 2 application to the Arbitrum DAO (Internet Archive copy of 2025-03-22) · Question 20 · words found 2026-09-24
- Who keeps the official record
Vistra keeps an off-chain copy of the unitholder register to rebuild holdings. The documents we read do not state which record governs if the two differ.
“The Administrator, Vistra, maintains an off-chain copy of the Fund unitholder register”
FundBridge Capital, ULTRA STEP 2 application to the Arbitrum DAO (Internet Archive copy of 2025-03-22) · Question 23 · words found 2026-09-24
- What the issuer says it can freeze or take back
The administrator can blacklist a holder with the manager’s approval; the contract has a clawback but no freeze function.
“The Administrator can blacklist investors at any time, subject to the Manager’s approval.”
FundBridge Capital, ULTRA STEP 2 application to the Arbitrum DAO (Internet Archive copy of 2025-03-22) · Question 35 · 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 |
|---|---|---|---|---|---|
| 2025-11-03 | D/A | Rule 506(c); Investment Company Act section 3(c)(7) | $200,000 | $135,341,364 | 7 |
| 2024-11-06 | D | Rule 506(c); Investment Company Act section 3(c)(7) | $200,000 | $0 | 0 |
Filed by Delta Wellington Ultra Short Treasury On-Chain Fund, a sub-fund of the Delta Master Trust (SEC CIK 2043109). 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.
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 | No | No | Yes | Yes | Yes | A single key holds the admin key. |
| Arbitrum | No | No | Yes | Yes | Yes | A single key holds the admin key. |
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 |
|---|---|---|---|---|
| Ethereum | Admin role | grant and revoke these powers, decide who may hold | a single key | 0x3d5d…35bc |
| Arbitrum | Admin role | grant and revoke these powers, decide who may hold | a single key | 0x3d5d…35bc |
Ethereum: 1 contract read, 4 functions in verified source, 2026-09-24
- eip1967.implementation=0xbf9c9fcb5915d835220a9454ec146a39cd0d8d8f
- KYCContract in verified source 0xbf9c…8d8f
- clawback in verified source 0xbf9c…8d8f
- mint in verified source 0xbf9c…8d8f
- upgradeTo in verified source 0xbf9c…8d8f
Arbitrum: 1 contract read, 4 functions in verified source, 2026-09-24
- eip1967.implementation=0x0bd2267bae2729150b29ed374a7cc73197d1ffe2
- KYCContract in verified source 0x0bd2…ffe2
- clawback in verified source 0x0bd2…ffe2
- mint in verified source 0x0bd2…ffe2
- upgradeTo in verified source 0x0bd2…ffe2
Where it trades
| Venue | Kind |
|---|---|
| Libeara Delta platform (FundBridge onboarding) | issuer primary |
Redemption
| Route | Settlement | Settles in |
|---|---|---|
| Redeem with the issuer in its window | Daily redemptions to the manager on trading days, settled in one to two business days. The holder sends units to the fund’s contract and receives USDC through the fund’s on- and off-ramp provider, or US dollars by wire | USDC, USD |
- FundBridge or Libeara publishes the information memorandum, trust deed, or contract addresses; Ketju then reviews the file again for who keeps the register, the investor class, and the Solana and Avalanche contracts
- The DEFAULT_ADMIN_ROLE, SUPER_ADMIN, or OPERATOR_ADMIN holder or the implementation of ULTRA on Ethereum or Arbitrum changes, or the transfer limit rises above zero
- An issuer source identifies the Solana mint, which rwa.xyz shows holding most units; Ketju then reads it and adds it
- A new Form D or amendment for CIK 2043109 changes the exemption, the exclusion, or the minimum
- The fund suspends or delays a redemption past two business days
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 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 |
|---|---|
| 2026-09-24 | Filed. |
Sources
- SEC EDGAR: Delta Wellington Ultra Short Treasury On-Chain Fund, Form D/A filed November 3, 2025 · primary · accessed 2026-09-24
Supports: Singapore unit trust, Rule 506(c), section 3(c)(7), $200,000 minimum, $135.3M sold to seven investors, first sale 2025-02-19 - FundBridge Capital, ULTRA STEP 2 application to the Arbitrum DAO (Internet Archive copy of 2025-03-22) · primary · accessed 2026-09-24
Supports: service providers, unitholder rights under the trust deed, $200,000 minimum, KYC and whitelist, daily redemption, one to two business days, Vistra off-chain register copy, blacklist and clawback, Fireblocks MPC approvals - Libeara funds microsite: Delta Master Trust landing page · primary · accessed 2026-09-24
Supports: accredited and institutional investors under the SFA, sub-fund list, ratings - Libeara: FundBridge and Libeara Launch Regulated Tokenised Treasury Fund on Avalanche (2025-08-28) · primary · accessed 2026-09-24
Supports: accredited and institutional investors, Delta Master Trust under Singapore law, fiat or USDC channels - Libeara: ULTRA and MG999 on Solana (2025-12-11) · primary · accessed 2026-09-24
Supports: chains: Ethereum, Arbitrum, Avalanche, Solana, over US$195 million AUM claim, Theo as Solana anchor investor - Verified ULTRA implementation Ultra.sol on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: KYC check on both sides of a transfer, clawback to a wallet the super admin sets, transfer limit and transfer promises, upgrade by DEFAULT_ADMIN_ROLE - Theo Docs: tULTRA (Internet Archive copy of 2025-08-07), whose vault’s asset() is the Ethereum ULTRA contract · primary · accessed 2026-09-24
Supports: issuer-anchored Ethereum contract, fund facts