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. The file records the gap and the date it was 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 stated primary-market term, not a live offer.

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 it exits

No exit 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: weekly distributions are suspended, a court-appointed special fiduciary (Charles Bullock, appointed April 2026 over about 700 Detroit properties) sells the portfolio, and sale proceeds go first to the fiduciary’s costs, repairs, back taxes, and legal obligations. What reaches a token holder, and when, is not stated.. Settles in USDC, xDAI.

Research and shelf status are on the memo: RealT Tokens Adverse research finding

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 · v1

Next review

2026-12-26

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

“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 2026-09-26

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 2026-09-26

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 2026-09-26

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 2026-09-26

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 2026-09-26

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 2026-09-26

Who keeps the official record

Not stated: the terms say the interest is represented by the token and that RealT decides who may participate, but not 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. Rule 11’s code is not verified on any explorer, so whether anything can pause every transfer at once is unread.

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).

Fact	What the file records
Who onboards the holder	issuer
Voting rights	None
Distributions	cash
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
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI	Gnosis	Yes	Unverified	Yes	Yes	Yes	A single key can claw back tokens. A single key can change the code with no delay.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-26. 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
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI	Gnosis	Owner	grant and revoke these powers, change the code	a single key	0x52d7…3669
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI	Gnosis	Processor owner	claw back tokens, decide who may hold, grant and revoke these powers	a single key	0x13ab…dfb7
REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI	Gnosis	Processor().ruleEngine owner	grant and revoke these powers	a single key	0x13ab…dfb7

Gnosis REALTOKEN-S-15777-ARDMORE-ST-DETROIT-MI: 18 contract reads at block 48440379, 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

Venue	Kind
YAM, RealT’s peer-to-peer order book on Gnosis (yam.realtoken.network); buyers must pass the same registry as primary buyers	dex
RMM, RealT’s Aave-fork lending market on Gnosis (rmm.realtoken.network), where tokens are posted as collateral	dex

How it exits

Path	Settlement	Settles in
No exit 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: weekly distributions are suspended, a court-appointed special fiduciary (Charles Bullock, appointed April 2026 over about 700 Detroit properties) sells the portfolio, and sale proceeds go first to the fiduciary’s costs, repairs, back taxes, and legal obligations. What reaches a token holder, and when, is not stated.	USDC, xDAI

Reopen conditions: events that change an answer above

RealT, the special fiduciary, or a court publishes the distribution plan for token holders: what a token receives from property sales, whether tokens are seized, burned, or bought back, and when
A Seize event on any RealToken contract after 2026-09-26 (the reader watches the sampled three; the seizer role belongs to RealT’s key 0x5fc9… and to contract 0xa28e…), or a change of the rule engine, processor, or compliance Safe owners
The proxy admin key 0x1906… upgrades the token implementation, or the processor owner 0x13ab… changes the rule engine
realt.co lifts the US block, publishes a new offering, or files a new Form D or a Regulation A offering statement on EDGAR
The Wayne County settlement is amended, the fiduciary’s term ends, or a bankruptcy petition is filed by RealToken Inc. or a series
The French criminal complaint or the Detroit suit produces an order that names token holders’ rights

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 key that appears, disappears, or changes shape counts as a change only when the chain’s own log shows the grant, revocation, or signer change between yesterday’s block and today’s; a difference the log does not show updates this file’s key list and nothing more. A change opens a review item in the governance queue and reopens the file before any client action. Subscribers get an email naming each of their clients who hold it, with the household result.

File history

Not revised since it was filed. A revision keeps the superseded copy as published, with the reason.

Date	Change
2026-09-26	Filed.

Sources

RealT Terms of Service, 11 October 2022 (PDF as archived 2025-05-14) · primary · accessed 2026-09-26
Supports: series LLC membership interests, ERC-20 modified for transfer restrictions, Rule 506 and Regulation S, RealToken decides participation, no assurance of a secondary market, account personal to the user or business, RealToken Inc. not a broker-dealer
RealT FAQ (as archived 2021-02-24) · primary · accessed 2026-09-26
Supports: digital representation of ownership in the LLC that owns the deed, accredited US investors only, Regulation D and Regulation S, ID verification then purchase agreement, $50 to $150 per token, rent paid weekly in stablecoins to the holding wallet, Uniswap, Swapcat, AirSwap, RealT buyback
realt.co home page (US visitor) · primary · accessed 2026-09-26
Supports: not open to US citizens or residents, RealToken Inc., Boca Raton, redeem through RealT or a secondary market
SEC EDGAR: Form D, RealToken 11310 Abington Ave., Inc (CIK 1944586), filed 2022-09-08 · primary · accessed 2026-09-26
Supports: Rule 506(c), Florida corporation formed 2022, $6,110 offered, $2,170 sold to 5 investors, $47 minimum, REITs and Finance
SEC EDGAR full-text search: Form D filings naming RealToken · primary · accessed 2026-09-26
Supports: 17 Form D filings by per-property RealToken corporations, June to September 2022
RealT community token API (api.realtoken.community) · primary · accessed 2026-09-26
Supports: 829 tokens listed, 792 with a Gnosis contract, 794 rental property tokens, 22 factoring, 12 loan income, 1 equity, token names and prices
YAM order book · primary · accessed 2026-09-26
Supports: peer-to-peer venue live
RMM lending market · primary · accessed 2026-09-26
Supports: lending market live
Crypto Briefing: crypto real estate empire collapses as $140 million tokenized property venture enters liquidation · secondary · accessed 2026-09-26
Supports: voluntary liquidation announced 2026-07-02 by co-founder Jean-Marc Jacobson, fiduciary Charles Bullock, about 700 properties, escrow about $640,000, 14,000 to 22,000 investors, $140 million raised
Lofty: the RealT liquidation explained · secondary · accessed 2026-09-26
Supports: weekly distributions suspended, progressive sale of the entire portfolio, proceeds go first to fiduciary costs, repairs, back taxes, legal obligations, fiduciary control to at least end of October 2026, settlement 2026-04-22
Outlier Media: RealT’s Detroit landlord and property-management failures · secondary · accessed 2026-08-17
Supports: Detroit nuisance-abatement suit, special fiduciary powers: repairs, sales, demolition, evictions

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