Eligibility file · Money-market fund

Franklin OnChain Institutional Liquidity Fund (iBENJI)

What the client owns

Share of a private Franklin money fund that rwa.xyz describes as holding government securities, cash, and repos at a $1.00 NAV; no fund document is public. 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 $5,000,000. The only signed statement of terms is the Form D filed on 29 May 2025. It claims Rule 506(b) and the Investment Company Act section 3(c)(7) exclusion, which admits only qualified purchasers. It states a $5,000,000 minimum, and we follow it. rwa.xyz lists non-US institutional investors and US qualified institutional buyers, a $5,000,000 first investment, and $100,000 after. The Form D reports no sales and no investors and has not been amended, while 1.72 billion iBENJI were outstanding on 2026-09-24.

Who can freeze or claw back

Ethereum: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. A contract can freeze a holder. A single key holds the role token owner key.
BSC: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. A contract holds the moduleregistry owner key.

How a holder redeems

Redeem with the issuer in its window. No public document states the redemption terms; rwa.xyz lists daily subscriptions and redemptions with no fee.

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: Franklin OnChain Institutional Liquidity Fund (iBENJI) Not approved

Issuer

Franklin Onchain Institutional Liquidity Fund Ltd. (SEC CIK 2068319; Rule 506(b) private fund under section 3(c)(7); its Form D gives Delaware as the jurisdiction, rwa.xyz gives the British Virgin Islands); Franklin Advisers, Inc. as investment manager; Franklin Distributors, LLC as placement agent

Registration

Private placement, Rule 506(b)

Official record

Not named in any public document; the token has a Transfer Agent module, as BENJI does, whose transfer agent is Franklin Templeton Investor Services

Instruments

iBENJI

Chains

Ethereum, BSC

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

No public document says what an iBENJI token represents; rwa.xyz calls it one share of the fund.

Not stated in SEC EDGAR: Franklin Onchain Institutional Liquidity Fund Ltd., Form D filed May 29, 2025, Franklin Templeton Benji DevHub: contract addresses, Franklin Templeton and Binance, Institutional Off-Exchange Collateral Program (2026-02-11, Nasdaq copy of the Business Wire release).

Who may hold it

Qualified purchasers, per the Form D’s section 3(c)(7) claim; no offering document is public.

“X Section 3(c)(7)”

SEC EDGAR: Franklin Onchain Institutional Liquidity Fund Ltd., Form D filed May 29, 2025 · Item 6, Federal Exemption(s) and Exclusion(s) Claimed · words found 2026-09-24

First purchase minimum

$5,000,000, per the Form D.

“Minimum investment accepted from any outside investor $ 5,000,000 USD”

SEC EDGAR: Franklin Onchain Institutional Liquidity Fund Ltd., Form D filed May 29, 2025 · Item 11, Minimum Investment · words found 2026-09-24

Who it may be transferred to

No public document says. Under the contract, only authorized wallets can hold, and Franklin can switch transfers off.

How a holder redeems

No public document states the redemption terms.

Who keeps the official record

No public document says who keeps the record of holders or which record governs.

What the issuer says it can freeze or take back

No public document says. On chain, the contract has functions to freeze a wallet and burn a balance.

Fact	Answer
Who onboards the holder	issuer
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
2025-05-29	D	Rule 506(b); Investment Company Act section 3(c)(7)	$5,000,000	$0	0

Filed by Franklin Onchain Institutional Liquidity Fund Ltd. (SEC CIK 2068319). 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.

What the filing record shows

No Form D amendment since 2025-05-29; a continuing offering amends each year.

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 contract can freeze a holder. A single key holds the role token owner key.
BSC	Yes	Yes	Yes	Yes	Yes	A contract holds the moduleregistry owner 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	ModuleRegistry owner	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Admin role	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role token owner	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role token owner	grant and revoke these powers	a single key	0x42cc…a2d6
Ethereum	Role token owner	grant and revoke these powers	a single key	0x64d4…23e6
Ethereum	Role token owner	grant and revoke these powers	a single key	0xb671…b24f
Ethereum	Role authorization admin	decide who may hold, freeze a holder	a contract	0xe9ca…23e2
Ethereum	Admin role	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x42cc…a2d6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x64d4…23e6
Ethereum	Role module owner	grant and revoke these powers	a single key	0xb671…b24f
Ethereum	Admin role	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x42cc…a2d6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x64d4…23e6
Ethereum	Role module owner	grant and revoke these powers	a single key	0xb671…b24f
Ethereum	Admin role	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x42cc…a2d6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x64d4…23e6
Ethereum	Role module owner	grant and revoke these powers	a single key	0xb671…b24f
Ethereum	Admin role	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a contract	0x27d7…1ad6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x42cc…a2d6
Ethereum	Role module owner	grant and revoke these powers	a single key	0x64d4…23e6
Ethereum	Role module owner	grant and revoke these powers	a single key	0xb671…b24f
BSC	ModuleRegistry owner	grant and revoke these powers	a contract	0xf2f7…18b1

Ketju could not read the role holders on BSC from the public event indexes on its last check. The table shows only what Ketju confirmed.

Ethereum: 6 contract reads, 6 functions in verified source, 2026-09-24

Read from the chain

eip1967.implementation=0xa74372dfde0df8a08a3ac7b60c5379f90ac9c7dd
moduleRegistry=0xf70e2726c60644ad6efe87289c2df830f39d34f7
getModuleAddress(MODULE_AUTHORIZATION)=0x12abff8dca2d09d99019dfcc9bf07539a8264066
getModuleAddress(MODULE_TRANSACTIONAL)=0x1933797bbf8f901b69bb81245d5a82091a0e0b76
getModuleAddress(MODULE_INTENT_VALIDATION)=0x9b61815c4388c7e0a9ef32b5b2b8926c379786d0
getModuleAddress(MODULE_TRANSFER_AGENT)=0xab266e4fa5d088cc440433c3ea1e066fd710a0a5

Read from verified source

authorizeAccount in verified source 0x52eb…8da2
freezeAccount in verified source 0x52eb…8da2
disableERC20Transfer in verified source 0xa743…c7dd
burnShares in verified source 0xa743…c7dd
mintShares in verified source 0xa743…c7dd
upgradeTo in verified source 0xa743…c7dd

BSC: 4 contract reads, 6 functions in verified source, 2026-09-24

Read from the chain

eip1967.implementation=0xd001e4edbea7d0e46cfee05cb95bc9664dc1da34
moduleRegistry=0xafcf771f5bacc9ecf3c32d4d145177aa9945d00c
getModuleAddress(MODULE_AUTHORIZATION)=0xfe1ce41141d489983e87cad56943e4d92bd12014
getModuleAddress(MODULE_TRANSACTIONAL)=0xab56aa7f1ed443401cefb3ed17d2795d4da59f6c

Read from verified source

authorizeAccount in verified source 0xf416…9240
freezeAccount in verified source 0xf416…9240
disableERC20Transfer in verified source 0xd001…da34
burnShares in verified source 0xd001…da34
mintShares in verified source 0xd001…da34
upgradeTo in verified source 0xd001…da34

Where it trades

Venue	Kind
Franklin Templeton Benji platform (institutional onboarding)	issuer primary

Redemption

Route	Settlement	Settles in
Redeem with the issuer in its window	No public document states the redemption terms; rwa.xyz lists daily subscriptions and redemptions with no fee

Review triggers

Franklin publishes an offering memorandum, fact sheet, or terms page for the fund; Ketju then reviews the file again for what the holder owns, who keeps the register, transfer, and redemption
A new Form D or amendment for CIK 2068319 changes the exemption, the exclusion, the minimum, or the sales reported
The ROLE_TOKEN_OWNER holders, the authorization admin, or the implementation of iBENJI on Ethereum or BSC changes
Ketju reads who holds the roles in the BSC modules, and then records who can freeze, pause or upgrade the token on BSC
Franklin issues iBENJI on another chain

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: Franklin Onchain Institutional Liquidity Fund Ltd., Form D filed May 29, 2025 · primary · accessed 2026-09-24
Supports: Delaware corporation formed 2024, Rule 506(b), section 3(c)(7), $5,000,000 minimum, no sales, no investors, Franklin Advisers as investment manager, Franklin Distributors as placement agent
Franklin Templeton Benji DevHub: contract addresses · primary · accessed 2026-09-24
Supports: iBENJI on Ethereum, iBENJI on BNB Smart Chain, module and MultiSig Module addresses
Franklin Templeton and Binance, Institutional Off-Exchange Collateral Program (2026-02-11, Nasdaq copy of the Business Wire release) · primary · accessed 2026-09-24
Supports: Benji-issued fund shares as Binance collateral, Ceffu custody, fund not named
Verified iBENJI implementation MoneyMarketFund on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: upgrade gated by ROLE_TOKEN_OWNER, burnShares, disableERC20Transfer, mintShares
rwa.xyz: iBENJI · secondary · accessed 2026-09-24
Supports: BVI domicile, non-US institutions and US QIBs, $5M first, $100K after, 0.50% management fee, launch 2025-03-25, 44 holders

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