Securitize Tokenized AAA CLO Fund (STAC)
This file replaced an earlier version on 2026-09-24. Superseded to reconcile the minimum with the fund’s Form D. The November 2025 Form D states a $0 minimum and claims Rule 506(c) and section 3(c)(1); the file kept Securitize’s $100,000 tile without naming the filing. The file now cites the Form D and says it keeps the stricter figure. Earlier versions.
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: Securitize Tokenised AAA CLO Fund Not approved
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.
- Who may hold it
Eligible investors who pass Securitize KYC, AML, and investor qualification and accreditation checks.
“Eligible investors can subscribe to the Securitize Tokenized AAA CLO Fund directly through Securitize, with shares issued as digital tokens on Ethereum. These tokenized shares will offer fractional ownership and transparent recordkeeping through Securitize’s integrated Know Your Customer (KYC), Anti-Money Laundering (AML), and investor qualification and accreditation infrastructure.”
Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29) · Release body · words found 2026-09-23
- First purchase minimum
$100,000; Securitize’s page shows the figure in its Minimum Investment tile.
“$100,000”
Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · Key facts tile, Minimum Investment · words found 2026-09-23
- Account types
The documents we read do not state this.
Not stated in Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund), Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29), Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12).
- Who it may be transferred to
Only to other whitelisted holders, starting one day after issue.
“(6) Tokens can be transferred to other whitelisted holders one day after issuance.”
Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · Fund Profile footnote (6) · words found 2026-09-23
- How a holder redeems
Redemptions depend on CLO sales, which the fund expects on T+2 or T+3 but does not guarantee.
“(4) CLOs may take several days to liquidate the Fund’s position, either in whole or in part, which may be necessary for the Fund to be able to provide redemption funds to a redeeming Shareholder. It is expected that CLO liquidations will generally be facilitated on a T+2 or T+3 timing, however, there can be no guarantee of such timing.”
Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · Fund Profile footnote (4) · words found 2026-09-23
- Who keeps the official record
Securitize keeps the ownership records, including on-chain ownership, through its transfer agent.
“Securitize provides integrated KYC, AML and investor accreditation, along with transparent recordkeeping and onchain ownership through its transfer agent infrastructure.”
Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12) · Release body · words found 2026-09-23
- What the issuer says it can freeze or take back
The documents we read do not state this.
Not stated in Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund), Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29), Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12).
| Fact | Answer |
|---|---|
| Who onboards the holder | broker dealer |
| Voting rights | None |
| Distributions | reinvested |
| 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 |
|---|---|---|---|---|---|
| 2025-11-05 | D | Rule 506(c); Investment Company Act section 3(c)(1) | $0 | $5,000,000 | 1 |
Filed by Securitize AAA CLO Tokenized Fund, Ltd. (SEC CIK 2095325). 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.
- The 2025-11-05 Form D states a $0 minimum; the file records $100,000. The note under “Who may hold it” states which figure Ketju uses.
The transfer agent’s SEC record
A transfer agent registers with the SEC on Form TA-1 and reports each year on Form TA-2: how many securityholder accounts it keeps and for how many issues it keeps the master securityholder file, the list that says who owns each share.
| Agent | SEC file | TA-2 period | Accounts | Issues with master file | Work it hires out |
|---|---|---|---|---|---|
| Securitize Transfer Agent, LLC | 084-06638 | 2025-12-31 | 18,337 | 54 | PACIFIC STOCK TRANSFER CO |
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 single key holds the owner key. |
Who holds the keys
Ketju read every current holder of each power from the chain on 2026-09-23. 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 | Owner | grant and revoke these powers | a single key | 0x59c1…76ee |
| Ethereum | Wallet registrar owner | decide who may hold, grant and revoke these powers | a single key | 0x3ee6…1a3e |
Ethereum: 12 contract reads, 6 functions in verified source, 2026-09-23
- eip1967.implementation=0x77684815f44b28726bc3efa4471b88ef3b93feb0
- owner()=0x59c1eacec450c57dcb9b8725d0f96635c2b676ee
- isPaused()=false
- getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0x07952f21df5068bfa900ff317e6aaf4fe376a561
- getDSService(COMPLIANCE_SERVICE)=0xd8edd463579cda2249cf91a36767421b4bbd69bb
- getDSService(DEPRECATED_SECURITIZE_SWAP)=0xc793b33120e5b74b601b00af8fe2d30167ceb923
- getDSService(LOCK_MANAGER)=0x6fce11ccc5c6861f74e5bf02f4d4ac0a7832b870
- getDSService(REGISTRY_SERVICE)=0x71080eb74e2816124327af399ac8cc518bbc7f49
- getDSService(TRANSACTION_RELAYER)=0x705924779443f6b869bffdcc553708498862f4b6
- getDSService(TRUST_SERVICE)=0xec0f580a0fe6ea53654537d34788aebad70a6370
- getDSService(WALLET_MANAGER)=0x412ab53abc69877f0976484a131087008f354897
- getDSService(WALLET_REGISTRAR)=0x10e0b0d4ecfa6921cc52f2edbc594c1ff4e9a62e
- preTransferCheck in verified source 0x7768…feb0
- lockInvestor in verified source 0xe33f…45c6
- isPaused in verified source 0x7768…feb0
- burn in verified source 0x7768…feb0
- issueTokens in verified source 0x7768…feb0
- upgradeToAndCall in verified source 0x7768…feb0
Where it trades
| Venue | Kind |
|---|---|
| Securitize primary market | issuer primary |
Redemption
| Route | Cutoff | Settlement | Settles in |
|---|---|---|---|
| Redeem with the issuer in its window | 2:30 p.m. Eastern for subscriptions | Holders may request redemption daily. The fund expects the CLO sales that pay for redemptions on T+2 or T+3, with no guarantee. The general partner may offer an on-demand liquidity pool. Holders must wait one day after issuance | USDC, USD |
- Securitize publishes the offering memorandum with the eligible-investor class, gates, valuation policy, and complete fees; Ketju will then check the file against it
- The compliance service, lock manager, proxy implementation, or issuer role on Ethereum changes
- Securitize publishes the Solana mint address; Ketju will then read that chain and add it
- A redemption gate, a suspension, or settlement beyond the stated window
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 the transfer agent’s registration 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 revised this file 3 times since filing it. Ketju keeps each earlier version as published, with the reason for the change.
| Date | Change |
|---|---|
| 2026-09-23 | Filed. |
| 2026-09-23 | Revised. Superseded the same day: the control reading stopped at the token ABI and missed the Securitize lock manager, so the file said the issuer cannot freeze a holder. It can, through lockInvestor. Same claim model, terms, and exit. |
| 2026-09-23 | Revised. Superseded to add the issuer’s own words for each term; the accredited floor now says which words it rests on. |
| 2026-09-24 | Revised. Superseded to reconcile the minimum with the fund’s Form D. The November 2025 Form D states a $0 minimum and claims Rule 506(c) and section 3(c)(1); the file kept Securitize’s $100,000 tile without naming the filing. The file now cites the Form D and says it keeps the stricter figure. |
Sources
- SEC EDGAR: Securitize AAA CLO Tokenized Fund, Ltd., Form D filed November 5, 2025 · primary · accessed 2026-09-24
Supports: Rule 506(c), section 3(c)(1), minimum accepted from any outside investor, amount sold, investor count - Securitize: STAC primary-market page · primary · accessed 2026-09-23
Supports: $100,000 minimum, accredited investors where applicable, BVI domicile, instant subscription with 2:30 p.m. Eastern deadline, daily redemptions, T+2 or T+3 CLO liquidation, one-day hold, 0.40% expense ratio - Securitize STAC launch with BNY, 2025-10-29 · primary · accessed 2026-08-01
Supports: BNY custody and NAV, AAA CLO mandate - Securitize STAC Solana expansion and fund risk disclosure, 2026-06-12 · primary · accessed 2026-08-01
Supports: Solana share class, structured-credit risk disclosure - Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: preTransferCheck compliance gate, pause, seize, issueTokens, upgradeToAndCall - Securitize and BNY, ”Securitize Launches Tokenized AAA CLO Fund with Services Provided by BNY” (BNY newsroom, 2025-10-29) · primary · accessed 2026-09-23
Supports: who may-hold - Securitize, STAC primary-market page content (Builder.io content API behind securitize.io/primary-market/Securitize-BNY-CLO-Fund) · primary · accessed 2026-09-23
Supports: minimum, transfer, redemption - Securitize, ”Securitize Expands STAC, Tokenized AAA CLO Fund, to Solana” (PR Newswire, 2026-06-12) · primary · accessed 2026-09-23
Supports: record