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. The lender does not buy 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 we read bars US persons, and EDGAR shows no OpenTrade filer or Form D. We therefore use accredited investor, the only US status the documents name, as the investor test. 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. A single key holds the pool admin 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. A single key holds the pool admin key.
Plume Mainnet XMMF: can pause transfers, gate who may hold, mint, change the code. A single key can pause transfers. A single key holds the pool admin key.

How a holder redeems

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.

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: OpenTrade Not approved

Issuer

OpenTrade SPC, a Cayman segregated portfolio company, borrows every loan through its Treasury Management Segregated Portfolio 1. Open Trade Technology Ltd (England, company 14583521) runs the platform and is vault admin. Five Sigma Finance Ltd advises the SPC, and Mulvaney Trustees (UK) Ltd, trading as Vantru, is security trustee. We found no SEC filing

Registration

Other

Official record

None. Each loan is set out in a Loan Confirmation emailed to the lender under the Master Lending Agreement; the documents do not say who keeps the register of lenders

Instruments

XMMF XMMF-USDT XTBT XEVT XFTB XHYC XHYCB

Chains

Ethereum, Avalanche, Plume Mainnet

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 lender makes a secured loan to OpenTrade SPC, a Cayman segregated portfolio company. The lender does not buy 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 we 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

A lender may withdraw at any time from a whitelisted wallet. OpenTrade pays most withdrawals 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 Master Lending Agreement and each Loan Confirmation set the lender’s rights; the token does not.

“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	Answer
Who onboards the holder	issuer
Voting rights	None
Distributions	reinvested
SIPC coverage of the wallet	No

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.

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. A single key holds the pool admin 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. A single key holds the pool admin key.
XMMF	Plume Mainnet	No	Yes	No	Yes	Yes	A single key can pause transfers. A single key holds the pool 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.

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, 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, 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, 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, 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, 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

Redemption

Route	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

Review triggers

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

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 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

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

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