KETJU Research

← Eligibility files

Eligibility file · Real estate

RealT RealTokens (per-property rental interests, in liquidation)

What the client owns
A membership interest in the series that owns one property, represented by that property’s token; RealT sold the interest, not the deed, and its documents do not say whether the chain or RealT’s register governs. 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
Not offered to US persons. First purchase $50. RealT sold to US accredited investors under Rule 506(c) and to non-US persons under Regulation S. The 2022 Form D filings for the Florida corporations show 506(c) offerings of a few thousand dollars each with a $47 minimum. realt.co now answers a US visitor with “This website is not open to US citizens or residents,” so no US person can buy today. The 2021 FAQ put a token at $50 to $150. Since 2026-07-02 the program is in voluntary liquidation and RealT sells nothing new. The minimum is the last primary-market term RealT stated, and no offer is open.
Who can freeze or claw back
Gnosis REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI: can freeze a holder, claw back, gate who may hold, mint, change the code (pause unverified). A single key can claw back tokens. A single key can change the code with no delay.
How a holder redeems
No redemption stated. No redemption. RealT once bought tokens back through its site (“Sell Tokens”) and paid 98% of net rent weekly in stablecoins to whichever wallet held the token. Since 2026-07-02 the program is in voluntary liquidation, and weekly distributions are suspended. A court-appointed special fiduciary (Charles Bullock, appointed April 2026 over about 700 Detroit properties) sells the portfolio. Sale proceeds go first to the fiduciary’s costs, repairs, back taxes, and legal obligations. No document states what a token holder will receive, or when. Settles in USDC, xDAI.

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: RealT Tokens Not approved

Issuer
RealToken Inc. (980 N. Federal Hwy, Boca Raton, Florida; administrative office RealToken Technologies Europe B.V., Schiphol) as sponsor and Series Manager; each property is a series of a Delaware limited liability company or, for the 2022 US offerings on EDGAR, its own Florida corporation named for the address (for example RealToken 11310 Abington Ave., Inc, CIK 1944586)
Registration
Regulation S, offshore
Official record
None named. RealToken Inc., as Series Manager, keeps the holder register through its own KYC registration and the compliance registry it controls on chain; the terms do not say which record governs if the chain and the register disagree.
Instruments
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI REALTOKEN-S-14319-ROSEMARY-ST-DETROIT-MI REALTOKEN-S-14078-CARLISLE-ST-DETROIT-MI
Chains
Gnosis
Reviewed
2026-09-26
Next review
2026-12-26

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 membership interest in the series that owns one property, represented by that property’s token; RealT sold the interest, not the deed, and its documents do not say whether the chain or RealT’s register governs.

“These Series Interests, which are securities under U.S. securities laws, will be represented by cryptographic digital tokens (RealToken), which are a new series of Ethereum blockchain-based smart contract digital tokens meeting the ERC-20 standard as modified to meet transfer restriction requirements under applicable U.S. securities laws.”

RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14) · Section 1, Services; Securities Offerings · words found 2026-10-16

Who may hold it

US accredited investors under Rule 506(c) and non-US persons under Regulation S when RealT was selling; today realt.co turns US visitors away and sells nothing.

“The Series RealTokens offered on the Sites have not been registered under the Securities Act of 1933, as amended (the Securities Act) in reliance on the exempted provisions of Section 4(a)(2) of the Securities Act and Rule 506 of Regulation D promulgated thereunder, and/or Regulation S.”

RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14) · Section 1, Services; Securities Offerings · words found 2026-10-16

First purchase minimum

One token, $50 to $150 when RealT was selling.

“A single token for RealT properties costs between $50 – $150 per token, which are the lowest investment minimums the real estate industry is able to offer.”

RealT FAQ (as archived 2021-02-24) · What are the benefits of tokenized real estate? · words found 2026-10-16

Account types

A person or the business they register for, after identity and qualification checks by RealT.

“The right to use the Sites and the Services is personal to you as the user or to the business you are registering for and is not transferable to any other person.”

RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14) · Section 4, Registration Data; Account Security · words found 2026-10-16

Who it may be transferred to

Only between wallets RealT has registered; the token’s transfer rules enforce it, and the 2021 FAQ named Uniswap, Swapcat, AirSwap, and RealT itself as ways to sell.

“Yes, you can sell your tokens in four different ways: Uniswap ( view all RealToken pools ) Swapcat AirSwap To the RealT website”

RealT FAQ (as archived 2021-02-24) · Can I sell my tokens? · words found 2026-10-16

How a holder redeems

No right to redeem; the terms promise no secondary market, and RealT’s own buyback has ended with the liquidation.

“There can be no assurance that RealToken’s business objectives will be achieved or that a secondary market will ever develop for the Interests, whether via the RealToken Website, via third party registered broker-dealers or otherwise.”

RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14) · Section 1, Services; Securities Offerings · words found 2026-10-16

Who keeps the official record

Not stated: the terms say that the token represents the interest and that RealT decides who may participate. They do not say which record governs a dispute.

Not stated in RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14), RealT FAQ (as archived 2021-02-24), realt.co home page (US visitor).

What the issuer says it can freeze or take back

Not stated in the terms; the chain shows a user-validity rule, a freeze rule, and a seize power on every sampled token, and RealT has used seize. No explorer has verified the code of Rule 11, so we could not tell whether anything can pause every transfer at once.

Not stated in RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14), RealT FAQ (as archived 2021-02-24), realt.co home page (US visitor).

FactAnswer
Who onboards the holderissuer
Voting rightsNone
Distributionscash
SIPC coverage of the walletNo

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.

TokenChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MIGnosisYesUnverifiedYesYesYesA single key can claw back tokens. A single key can change the code with no delay.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-26. 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.

TokenChainKeyWhat it can doHeld byAddress
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MIGnosisOwnergrant and revoke these powers, change the codea single key0x52d7…3669
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MIGnosisProcessor ownerclaw back tokens, decide who may hold, grant and revoke these powersa single key0x13ab…dfb7
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MIGnosisProcessor().ruleEngine ownergrant and revoke these powersa single key0x13ab…dfb7
Gnosis REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI: 18 contract reads, 0 functions in verified source, 2026-09-26
Read from the chain
  • name=RealToken S 15777 Ardmore St Detroit MI
  • rules=[11,1] params=[100038,0]
  • processor=0x3221a28ed2b2e955da64d1d299956f277562c95c
  • ruleEngine=0x8f2f90ac35edf2da147dd745f5f6c64bc54f2299
  • rule(1)=0x266d5d1c64c5566f3067694c62b4684881ba03aa
  • rule(11)=0xff9ce4516ce9d9e76897f216ddac93c029b0ff28
  • trustedIntermediaries=[0x296033cb983747b68911244ec1a3f01d7708851b]
  • getThreshold=1 getOwners=5
  • owner=0x52d782d2fb1b06e272c8b85ae9d87c6a22043669
  • owner=0x13abf9c02c150d7d4bfc65939b4fab216babdfb7
  • zos.proxy.admin=0x190686de2615dc4120f2f21580048cfe2cd97381
  • SeizerAdded(0x5fc96c182bb7e0413c08e8e03e9d7efc6cf0b099)
  • SeizerAdded(0xa28e8d538af2aa5e7dc224b7cd6ae4d66943c53a)
  • SupplierAdded(0x5fc96c182bb7e0413c08e8e03e9d7efc6cf0b099)
  • AdministratorAdded(0x5fc96c182bb7e0413c08e8e03e9d7efc6cf0b099)
  • Seize(0x440bdbff7dd5e41da47ea49d9edcb8cff0bb9567,2)
  • Seize(0x64210d8b400d7d8a5489ff8ef1af402ef40986b2,1)
  • Seize(0x25d38e194822156582d20592781968521f4241fc,20)

Where it trades

VenueKind
YAM, RealT’s peer-to-peer order book on Gnosis (yam.realtoken.network); buyers must pass the same registry as primary buyersdex
RMM, RealT’s Aave-fork lending market on Gnosis (rmm.realtoken.network), where holders post tokens as collateraldex

Redemption

RouteSettlementSettles in
No redemption statedNo redemption. RealT once bought tokens back through its site (“Sell Tokens”) and paid 98% of net rent weekly in stablecoins to whichever wallet held the token. Since 2026-07-02 the program is in voluntary liquidation, and weekly distributions are suspended. A court-appointed special fiduciary (Charles Bullock, appointed April 2026 over about 700 Detroit properties) sells the portfolio. Sale proceeds go first to the fiduciary’s costs, repairs, back taxes, and legal obligations. No document states what a token holder will receive, or when.USDC, xDAI

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.

DateChange
2026-09-26Filed.

Sources

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.