Eligibility file · Note
OpenTrade Loan Vaults (XMMF, XTBT, XEVT, XFTB, XHYC)
What the client owns
A lender makes a secured loan to OpenTrade SPC, a Cayman segregated portfolio company, not a purchase of fund shares. Issuer indirect: The token points at a record kept off chain; the transfer agent’s file governs and the chain is a mirror.
Who may hold it
US accredited investors. First purchase minimum not stated. OpenTrade takes high net worth individuals, companies, professional clients, and sophisticated or accredited investors, or the local equivalent, and turns away retail. The platform terms list the UK financial promotion categories. No document read bars US persons, and EDGAR shows no OpenTrade filer or Form D, so the file takes accredited, the only US status the documents name, as the floor. Kroll runs the KYC checks; the lender then signs the Master Lending Agreement with OpenTrade SPC by DocuSign, and OpenTrade whitelists its wallet. No minimum is stated for these vaults; the separate Figment staking vault states 1,000 USDC.
Who can freeze or claw back
Ethereum XTBT: can gate who may hold, mint, change the code.
Ethereum XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. Pool admin key: a single key.
Avalanche XTBT: can gate who may hold, mint, change the code.
Avalanche XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. Pool admin key: a single key.
Plume Mainnet XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. Pool admin key: a single key.
Ethereum XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. Pool admin key: a single key.
Avalanche XTBT: can gate who may hold, mint, change the code.
Avalanche XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. Pool admin key: a single key.
Plume Mainnet XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. Pool admin key: a single key.
How it exits
Redeem with the issuer in its window (18:00 GMT). The lender asks to withdraw from its whitelisted wallet at any time; OpenTrade repays USDC, USDT, or EURC to that wallet and burns the tokens, most the same day and at most two business days after the cutoff. In the XMMF contract the pool admin accepts each request and sends the cash; the full request is burned whatever cash is sent, and a code comment says the payment can be partial. Settles in USDC, USDT, EURC.
Research and shelf status are on the memo: OpenTrade Research unresolved
Who may buy, hold, transfer, and redeem
Each answer rests on the issuer’s own words, quoted from the document named under it. Ketju re-reads each document and records whether the words are still there. Where the documents say nothing, the row says so.
- What the holder owns
A lender makes a secured loan to OpenTrade SPC, a Cayman segregated portfolio company, not a purchase of fund shares.
“The legal structure for OpenTrade’s Stablecoin Yield products is secured lending to a bankruptcy remote Cayman Segregated Portfolio Company (SPC), OpenTrade SPC, which is operated by an independent board of directors and an FCA regulated investment firm.”
OpenTrade Docs: Legal · Summary · words found 2026-09-24
- Who may hold it
High net worth individuals, companies, professional clients, and sophisticated or accredited investors, or the local equivalent; no retail.
“OpenTrade clients must be high-net worth individuals, companies, professional clients, sophisticated investors, accredited investors, or the equivalent in the jurisdiction in which they reside and/or operate.”
OpenTrade Docs: Eligibility Requirements · No Retail Users · words found 2026-09-24
- First purchase minimum
The documents read do not state a minimum for these vaults.
Not stated in OpenTrade Docs: Eligibility Requirements, OpenTrade Docs: Onboarding, OpenTrade Docs: How to Invest in a Vault, OpenTrade Docs: USDC Money Market Fund Fidelity (V5) Vault, OpenTrade Docs: EURC Money Market Fund Fidelity (V4) Vault, OpenTrade Docs: Master Lending Agreement, OpenTrade Platform Terms of Service.
- Account types
Institutions, businesses, and high net worth individuals.
“Lenders are KYC’d Web3 institutions, businesses, and HNWI.”
OpenTrade Docs: Blockchain Protocol · Protocol Roles, Lenders · words found 2026-09-24
- Who it may be transferred to
OpenTrade says the tokens cannot be transferred; the contracts let one allowlisted wallet send to another and refuse every other wallet.
“Vault tokens are currently non-transferable and can only be issued to and redeemed by white-listed wallets that have undergone onboarding.”
OpenTrade Docs: How to Invest in a Vault · Note under the opening paragraphs · words found 2026-09-24
- How a holder redeems
Withdraw any time from a whitelisted wallet; most are paid the same day and all within two business days of the 6pm GMT cutoff.
“Most withdrawals are processed within same day. Instant liquidity facilities are available on request for customers that meet certain eligibility criteria. The current Withdrawal Processing Time is maximum of 2 business days.”
OpenTrade Docs: How to Make a Withdrawal · Withdrawal Processing Time · words found 2026-09-24
- Who keeps the official record
The token is not the record: the Master Lending Agreement and each Loan Confirmation set the lender’s rights.
“Tokens confer no legal rights or obligations on either the holder or issuer and are used only as a means of automating the accounting, authentication, and settlement process in a way that is interoperable and composable with Web3 tooling and infrastructure.”
OpenTrade Docs: Vault Tokens · Vault Tokens, note · words found 2026-09-24
- What the issuer says it can freeze or take back
The terms let OpenTrade suspend a lender’s platform access; they do not mention freezing tokens, but a wallet taken off a vault’s allowlist can no longer send or redeem.
“We may suspend your access to the Platform if: (i) you cease to meet the Eligibility Requirements”
OpenTrade Platform Terms of Service · Section 6.6, Account suspension and closure · words found 2026-09-24
| Fact | What the file records |
|---|---|
| Who onboards the holder | issuer |
| Voting rights | None |
| Distributions | reinvested |
| SIPC coverage of the wallet | No |
Who can change the record
Powers read from the deployed contracts and their verified source: the token and every contract it consults on transfer. A power recorded here is the issuer’s ability, not evidence it has been used.
| Token | Chain | Freeze a holder | Pause | Claw back | Gate holders | Change the code | Keys held by |
|---|---|---|---|---|---|---|---|
| XTBT | Ethereum | No | No | No | Yes | Yes | pool controller 0x9d3cb4372e9b565165332742d1389e899dbef021 via crossChainTransferMintDestination; deposits mint only to allowlisted lenders |
| XMMF | Ethereum | No | Yes | No | Yes | Yes | A single key can pause transfers. Pool admin key: a single key. |
| XTBT | Avalanche | No | No | No | Yes | Yes | pool controller 0x7c0d9a4e234c6741d69f8d2c5c2385dbb28be19b via crossChainTransferMintDestination; deposits mint only to allowlisted lenders |
| XMMF | Avalanche | No | Yes | No | Yes | Yes | A single key can pause transfers. Pool admin key: a single key. |
| XMMF | Plume Mainnet | No | Yes | No | Yes | Yes | A single key can pause transfers. Pool admin key: a single key. |
Who holds the keys
Every current holder of each power, read from the chain on 2026-09-24. A single key is one private key: whoever holds it acts alone. A multisig needs the stated number of signers. A timelock makes every action wait, so holders can see it coming.
| Token | Chain | Key | What it can do | Held by | Address |
|---|---|---|---|---|---|
| XMMF | Ethereum | Pool admin role | grant and revoke these powers | a single key | 0xbd0c…c9fd |
| XMMF | Ethereum | Admin role | grant and revoke these powers | a single key | 0xad79…922a |
| XMMF | Ethereum | Pauser role | pause transfers | a single key | 0xad79…922a |
| XMMF | Avalanche | Pool admin role | grant and revoke these powers | a single key | 0xbd0c…c9fd |
| XMMF | Avalanche | Pool admin role | grant and revoke these powers | a single key | 0xc184…14c7 |
| XMMF | Avalanche | Admin role | grant and revoke these powers | a single key | 0xad79…922a |
| XMMF | Avalanche | Pauser role | pause transfers | a single key | 0xad79…922a |
| XMMF | Plume Mainnet | Pool admin role | grant and revoke these powers | a single key | 0xbd0c…c9fd |
| XMMF | Plume Mainnet | Admin role | grant and revoke these powers | a single key | 0xad79…922a |
| XMMF | Plume Mainnet | Pauser role | pause transfers | a single key | 0xad79…922a |
Ethereum XTBT: 6 contract reads at block 26044937, 2 functions in verified source, 2026-09-24
Read from the chain
- eip1967.beacon=0x61424410c0bb1c580ed6363fe9405d9e84fa0578
- 0x61424410c0bb1c580ed6363fe9405d9e84fa0578.implementation()=0xf6e658a3c792dd1a71aec72ea766d8a08bb402e9
- poolAccessControl()=0x224d97719968be1bcf665f327ce9748702428a07
- hasRole(DEPLOYER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- hasRole(PAUSER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- paused()=false
Read from verified source
- isAllowed in verified source 0xb95a…2454
- crossChainTransferMintDestination in verified source 0xf6e6…02e9
Ethereum XMMF: 7 contract reads at block 26044937, 3 functions in verified source, 2026-09-24
Read from the chain
- eip1967.beacon=0x0a3b7bb45ac8e267cc4e4b2cbdb52b967d82df18
- 0x0a3b7bb45ac8e267cc4e4b2cbdb52b967d82df18.implementation()=0x6d11b6d8e71e92d497ac7593277453df55c89af1
- poolAccessControl()=0x36961d7afebdfd59d55ad81725a0c0b7eeb560d4
- serviceConfiguration()=0xec4f65e0a0268ff38ecec711ad5159b96dabab98
- hasRole(DEPLOYER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- hasRole(PAUSER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- paused()=false
Read from verified source
- isAllowed in verified source 0xb95a…2454
- paused in verified source 0x1048…b6d8
- upgradeTo in verified source 0x1048…b6d8
Avalanche XTBT: 6 contract reads at block 96027989, 2 functions in verified source, 2026-09-24
Read from the chain
- eip1967.beacon=0x859532e143f5841cd0d8e0982f27fe013913c3bb
- 0x859532e143f5841cd0d8e0982f27fe013913c3bb.implementation()=0xe946a01c2e82d665a155931da325f123595c5121
- poolAccessControl()=0x1be8ac8a1a0db298034169bd49c2d662d52db493
- hasRole(DEPLOYER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- hasRole(PAUSER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- paused()=false
Read from verified source
- abi:routescan:43114:0xcbc913ba4a386fa243b6a135acc2913b5d15567e#isAllowed
- abi:routescan:43114:0xe946a01c2e82d665a155931da325f123595c5121#crossChainTransferMintDestination
Avalanche XMMF: 7 contract reads at block 96027994, 3 functions in verified source, 2026-09-24
Read from the chain
- eip1967.beacon=0x4d3b32bb456a6e387682f6cd37facefe9a219d0c
- 0x4d3b32bb456a6e387682f6cd37facefe9a219d0c.implementation()=0xda3a53497aef995707dc0568603e9f45e2518500
- poolAccessControl()=0x7124a26c3e60f7337d9e307d498904245e52010d
- serviceConfiguration()=0xa3be07c2734ed1ce269cf026cbe8d09d146014e1
- hasRole(DEPLOYER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- hasRole(PAUSER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- paused()=false
Read from verified source
- abi:routescan:43114:0xcbc913ba4a386fa243b6a135acc2913b5d15567e#isAllowed
- paused in verified source 0xc301…fa4e
- upgradeTo in verified source 0xc301…fa4e
Plume Mainnet XMMF: 7 contract reads at block 95179754, 3 functions in verified source, 2026-09-24
Read from the chain
- eip1967.beacon=0xa9cc3bcf7c22895da2a7c32a99276d734840d8d3
- 0xa9cc3bcf7c22895da2a7c32a99276d734840d8d3.implementation()=0x999de6688407b7b9e9f5c7b66d7fe3e158aee8fa
- poolAccessControl()=0xd749db273397f2349e6363f517919d5cd278ef7d
- serviceConfiguration()=0x785b01f10496ec28aacec6fb19aec8a191199a18
- hasRole(DEPLOYER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- hasRole(PAUSER_ROLE,0xad795e380725d85e0c62da50b91126a12043922a)=true
- paused()=false
Read from verified source
- isAllowed in verified source 0xa267…0559
- paused in verified source 0x3faf…345d
- upgradeTo in verified source 0x3faf…345d
Where it trades
| Venue | Kind |
|---|---|
| OpenTrade app and API (whitelisted wallets only) | issuer primary |
How it exits
| Path | Cutoff | Settlement | Settles in |
|---|---|---|---|
| Redeem with the issuer in its window | 18:00 GMT | The lender asks to withdraw from its whitelisted wallet at any time; OpenTrade repays USDC, USDT, or EURC to that wallet and burns the tokens, most the same day and at most two business days after the cutoff. In the XMMF contract the pool admin accepts each request and sends the cash; the full request is burned whatever cash is sent, and a code comment says the payment can be partial | USDC, USDT, EURC |
- OpenTrade files a Form D or other SEC filing, bars US persons, or states a minimum for these vaults
- DEFAULT_ADMIN_ROLE, DEPLOYER_ROLE, or PAUSER_ROLE on any chain moves from 0xad795e380725d85e0c62da50b91126a12043922a, the protocol pause is set, or a beacon implementation changes
- The pool admin 0xbd0ca95c5a104e14e60d0868667af174d146c9fd or a vault’s access-control contract changes
- OpenTrade publishes addresses for Prime+, the EURC CLO vault, Sierra LP, or the Figment staking vault, or drops a vault from its address page
- OpenTrade settles which vault XTBT names: its address page says the Flexible Term USDC Vault, its Fidelity V5 vault page says the Fidelity money market vault
Reopen conditions: events that change an answer above
What the monitor reads daily
Every control function in the table above and the contracts the token consults on transfer; the token’s on-chain supply against yesterday’s; and its market quote against yesterday’s quote, since a fund of this kind accrues a few basis points a day. Every document quoted above is re-read too, and a quote that leaves its document reopens the file. A change opens a review item in the governance queue and reopens the file before any client action.
Sources
- OpenTrade Docs: Eligibility Requirements · primary · accessed 2026-09-24
Supports: no retail users, high net worth, companies, professional, sophisticated, or accredited investors, sanctioned countries barred, enhanced due diligence - OpenTrade Docs: Onboarding · primary · accessed 2026-09-24
Supports: KYC/AML/CFT checks, Master Lending Agreement by DocuSign, wallet whitelisting - OpenTrade Docs: How to Invest in a Vault · primary · accessed 2026-09-24
Supports: vault tokens non-transferable, only whitelisted wallets - OpenTrade Docs: How to Make a Withdrawal · primary · accessed 2026-09-24
Supports: withdraw any time, 6pm GMT cutoff, two business days at most, tokens burned on repayment - OpenTrade Docs: Vault Tokens · primary · accessed 2026-09-24
Supports: tokens confer no legal rights, Master Lending Agreement governs, not fungible across vaults - OpenTrade Docs: Legal · primary · accessed 2026-09-24
Supports: secured lending to a Cayman SPC, Loan Confirmations, Security Trust Deed - OpenTrade Docs: Master Lending Agreement · primary · accessed 2026-09-24
Supports: OpenTrade SPC the only borrower, adapted from GMSLA, English law - OpenTrade Docs: Key Parties · primary · accessed 2026-09-24
Supports: Open Trade Technology Ltd, OpenTrade SPC, OpenTrade Foundation, Five Sigma Finance, Vantru security trustee, Kroll KYC - OpenTrade Docs: Blockchain Protocol · primary · accessed 2026-09-24
Supports: Perimeter fork, ERC-4626 vaults, Open Trade Technology Ltd as protocol operator and vault admin, lenders are institutions, businesses, HNWI - OpenTrade Docs: Contract Addresses · primary · accessed 2026-09-24
Supports: eleven vault token addresses, Ethereum, Avalanche, Plume, collateral per vault - OpenTrade Platform Terms of Service · primary · accessed 2026-09-24
Supports: UK financial promotion categories, account suspension, sanctions representations - OpenTrade Docs: USDC Money Market Fund Fidelity (V5) Vault · primary · accessed 2026-09-24
Supports: Fidelity Institutional Liquidity USD Fund, JP Morgan Transfer Agency, T+0 before 18:00 GMT, T+2 at most, page gives symbol XTBT - OpenTrade Docs: EURC Money Market Fund Fidelity (V4) Vault · primary · accessed 2026-09-24
Supports: XEVT, Fidelity Institutional Liquidity EUR Fund, T+0 before 18:00 GMT, T+2 at most - Verified PoolFlex implementation (XTBT, XEVT) on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: transfers only between allowlisted wallets, transfers not stopped by the protocol pause, pool controller mint - Verified PoolDynamic implementation (XMMF) on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: transfers only between allowlisted wallets, protocol pause stops transfers, pool admin off-chain deposit mint, redemption repayment can be partial - Verified ServiceConfigurationV6 on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: PAUSER_ROLE sets the protocol pause, DEPLOYER_ROLE, role holders by RoleGranted events - Verified PoolFactoryFlex beacon on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: setImplementation gated by DEPLOYER_ROLE - SEC EDGAR company search for OpenTrade (no filer found) · primary · accessed 2026-09-24
Supports: no Form D, no SEC filer named OpenTrade or Open Trade