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Eligibility file · Treasury fund

Theo Short Duration US Treasury Fund (thBILL)

What the client owns
Share of a Theo basket vault that holds tULTRA, a Theo vault token counting shares of the ULTRA ultra-short US Treasury fund (Theo’s page also names Fidelity International’s FILQ, which the Ethereum vault did not list on 2026-09-23); Theo says holders have no claim over the underlying assets. 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 minimum not stated. Theo’s terms bar citizens and residents of the United States. Its docs say only users who pass KYC may mint or redeem. No document read states a minimum; the product page as archived on 2026-09-14 said “No minimums, no lockups, no paperwork,” and the page read on 2026-09-23 no longer says it.
Who can freeze or claw back
Ethereum: can pause transfers, mint, change the code. A single key can pause transfers. Admin key: a timelock with a 2-day delay.
Arbitrum: no power on the contract. Owner key: a 3-of-5 multisig.
Base: no power on the contract. Owner key: a 3-of-4 multisig.
Hyperliquid L1: no power on the contract. Owner key: a 3-of-4 multisig.
How it exits
Redeem with the issuer in its window. KYC’d users redeem through Theo for USDC; Theo says the token side settles at once and the underlying within four business days. The holder receives USDC, not fund shares. Settles in USDC.

Research and shelf status are on the memo: Theo Short Duration US Treasury Fund (thBILL) Adverse research finding

Issuer
Theo (no legal entity named in its docs or terms); the basket holds tULTRA, Theo’s wrapper for ULTRA, the Delta Wellington Ultra Short Treasury On-Chain Fund, a Singapore unit trust managed by FundBridge Capital with Wellington Management as investment manager, Standard Chartered as custodian, and Libeara as tokenization provider
Registration
Other
Official record
None named
Instruments
thBILL
Chains
Ethereum, Arbitrum, Base, Hyperliquid L1
Reviewed
2026-09-23 · v1
Next review
2027-03-23

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

Theo says thBILL holders have no claim over the underlying assets; a redemption returns the value in USDC.

“Participants have no claims over underlying assets.”

Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18) · Minting and Redemption · the site refuses automated reads; quoted as read 2026-09-23

Who may hold it

Not US citizens or residents, nor sanctioned persons; the token itself has no allowlist.

“citizens or residents of the United States or any jurisdiction subject to United States embargo or sanctions”

Theo Docs: Terms & Conditions (read from the Internet Archive copy of 2025-08-07) · Eligibility and Restricted Users · the site refuses automated reads; quoted as read 2026-09-23

First purchase minimum

The documents read do not state a minimum.

Not stated in Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18), Theo Docs: Terms & Conditions (read from the Internet Archive copy of 2025-08-07), Theo: thBILL product page, Theo: thBILL is Live (2025-07-24).

Account types

The documents read do not say.

Not stated in Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18), Theo Docs: Terms & Conditions (read from the Internet Archive copy of 2025-08-07), Theo: thBILL product page, Theo: thBILL is Live (2025-07-24).

Who it may be transferred to

Transfers are open on every chain; Theo markets the token for DEX trading and as collateral.

“Use thBILL as collateral, trade on secondary markets, or put it to work in any integrated DeFi protocol”

Theo: thBILL product page · How it works, step 04 · words found 2026-09-23

How a holder redeems

Only users who pass Theo’s KYC may redeem, for USDC; the underlying settles within four business days.

“thBILL can only be minted and redeemed by users who have passed KYC.”

Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18) · Minting and Redemption · the site refuses automated reads; quoted as read 2026-09-23

Who keeps the official record

The documents read do not say who keeps the record of holders or which record governs.

Not stated in Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18), Theo Docs: tULTRA (read from the Internet Archive copy of 2025-08-07), Theo Docs: tTokens (read from the Internet Archive copy of 2025-08-07), Theo Docs: Terms & Conditions (read from the Internet Archive copy of 2025-08-07), Theo: thBILL product page.

What the issuer says it can freeze or take back

The documents read do not say; the thBILL contract can pause every transfer but cannot freeze one holder.

Not stated in Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18), Theo Docs: tTokens (read from the Internet Archive copy of 2025-08-07), Theo Docs: Terms & Conditions (read from the Internet Archive copy of 2025-08-07).

FactWhat the file records
Who onboards the holderissuer
Voting rightsNone
Distributionsreinvested
SIPC coverage of the walletNo

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.

ChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
EthereumNoYesNoNoYesA single key can pause transfers. Admin key: a timelock with a 2-day delay.
ArbitrumNoNoNoNoNoOwner key: a 3-of-5 multisig.
BaseNoNoNoNoNoOwner key: a 3-of-4 multisig.
Hyperliquid L1NoNoNoNoNoOwner key: a 3-of-4 multisig.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-23. 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.

ChainKeyWhat it can doHeld byAddress
EthereumEmergency rolepause transfersa single key0x7afb…d94a
EthereumAdmin rolegrant and revoke these powersa timelock with a 2-day delay0x2bb4…ca02
ArbitrumOwnergrant and revoke these powersa 3-of-5 multisig0x9487…1295
BaseOwnergrant and revoke these powersa 3-of-4 multisig0x9487…1295
Hyperliquid L1Ownergrant and revoke these powersa 3-of-4 multisig0x9487…1295
Ethereum: 2 contract reads at block 26042349, 3 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.implementation=0x325478a069b0dbbdfbee909fa3741f84259ba519
  • paused()=false
Read from verified source
Arbitrum: 1 contract read at block 508223465, 0 functions in verified source, 2026-09-23
Read from the chain
  • owner()=0x94877640dd9e6f1e3cb56bf7b5665b7152601295
Base: 1 contract read at block 51701725, 0 functions in verified source, 2026-09-23
Read from the chain
  • owner()=0x94877640dd9e6f1e3cb56bf7b5665b7152601295
Hyperliquid L1: 1 contract read at block 46701966, 0 functions in verified source, 2026-09-23
Read from the chain
  • owner()=0x94877640dd9e6f1e3cb56bf7b5665b7152601295

Where it trades

VenueKind
Theo app (KYC mint and redeem)issuer primary
Uniswap and other DEX pools on Ethereum, Arbitrum, Base, and HyperEVMdex

How it exits

PathSettlementSettles in
Redeem with the issuer in its windowKYC’d users redeem through Theo for USDC; Theo says the token side settles at once and the underlying within four business days. The holder receives USDC, not fund sharesUSDC
Secondary market only; no issuer redemptionDEX pools and lending markets on Ethereum, Arbitrum, Base, and HyperEVM, with market making Theo says it arrangesUSDC

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

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