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. Ketju records the date it 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 we read states a minimum; the product page as archived on 2026-09-14 said “No minimums, no lockups, no paperwork,” and the page we 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. A timelock with a 2-day delay holds the admin key.
Arbitrum: no power on the contract. A 3-of-5 multisig holds the owner key.
Base: no power on the contract. A 3-of-4 multisig holds the owner key.
Hyperliquid L1: no power on the contract. A 3-of-4 multisig holds the owner key.

How a holder redeems

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 and no fund shares. Settles in USDC.

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The verdict is on the memo: Theo Short Duration US Treasury Fund (thBILL) Not approved

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

Next review

2027-03-23

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

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

Anyone except US citizens, US residents and 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 we 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 we read do not say which account types may hold.

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 we 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 we read do not mention freezing; 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).

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.

Chain	Freeze a holder	Pause	Claw back	Gate holders	Change the code	Keys held by
Ethereum	No	Yes	No	No	Yes	A single key can pause transfers. A timelock with a 2-day delay holds the admin key.
Arbitrum	No	No	No	No	No	A 3-of-5 multisig holds the owner key.
Base	No	No	No	No	No	A 3-of-4 multisig holds the owner key.
Hyperliquid L1	No	No	No	No	No	A 3-of-4 multisig 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	Emergency role	pause transfers	a single key	0x7afb…d94a
Ethereum	Admin role	grant and revoke these powers	a timelock with a 2-day delay	0x2bb4…ca02
Arbitrum	Owner	grant and revoke these powers	a 3-of-5 multisig	0x9487…1295
Base	Owner	grant and revoke these powers	a 3-of-4 multisig	0x9487…1295
Hyperliquid L1	Owner	grant and revoke these powers	a 3-of-4 multisig	0x9487…1295

Ethereum: 2 contract reads, 3 functions in verified source, 2026-09-23

Read from the chain

eip1967.implementation=0x325478a069b0dbbdfbee909fa3741f84259ba519
paused()=false

Read from verified source

pause in verified source 0x3254…a519
mint in verified source 0x3254…a519
upgradeToAndCall in verified source 0x3254…a519

Arbitrum: 1 contract read, 0 functions in verified source, 2026-09-23

Read from the chain

owner()=0x94877640dd9e6f1e3cb56bf7b5665b7152601295

Base: 1 contract read, 0 functions in verified source, 2026-09-23

Read from the chain

owner()=0x94877640dd9e6f1e3cb56bf7b5665b7152601295

Hyperliquid L1: 1 contract read, 0 functions in verified source, 2026-09-23

Read from the chain

owner()=0x94877640dd9e6f1e3cb56bf7b5665b7152601295

Where it trades

Venue	Kind
Theo app (KYC mint and redeem)	issuer primary
Uniswap and other DEX pools on Ethereum, Arbitrum, Base, and HyperEVM	dex

Redemption

Route	Settlement	Settles in
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 and no fund shares	USDC
Secondary market only; no issuer redemption	DEX pools and lending markets on Ethereum, Arbitrum, Base, and HyperEVM, with market making Theo says it arranges	USDC

Review triggers

Theo names the legal issuer of thBILL or publishes terms that give holders a claim; Ketju will then review the file again for the claim, the investor test, and the holder register
The thBILL implementation, the DEFAULT_ADMIN_ROLE timelock, or the EMERGENCY_ROLE key on Ethereum changes, or an OFT owner on Arbitrum, Base, or HyperEVM changes
tULTRA on Ethereum takes delivery of ULTRA shares, or its pending assets stop matching its total assets
The Ethereum basket’s deposit list gains FILQ or another asset, as Theo’s product page already claims, or drops tULTRA
Theo publishes thBILL on another chain

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
2026-09-23	Filed.

Sources

Theo Docs: thBILL (read from the Internet Archive copy of 2026-07-18) · primary · accessed 2026-09-23
Supports: basket of tokenized T-bills, tULTRA only at launch, KYC mint and redeem, four business days, no claim over underlying assets, USDC on redemption
Theo Docs: tULTRA (read from the Internet Archive copy of 2025-08-07) · primary · accessed 2026-09-23
Supports: ULTRA fund facts, FundBridge, Wellington, Standard Chartered, Libeara, Singapore unit trust, one-to-one backing claim
Theo Docs: tTokens (read from the Internet Archive copy of 2025-08-07) · primary · accessed 2026-09-23
Supports: pending assets, optimistic minting, roles: 3/5 owner, MPC minter, whitelist manager, 2/4 emergency
Theo Docs: Addresses (Markdown, read from the Internet Archive copy of 2026-07-18) · primary · accessed 2026-09-23
Supports: thBILL on Ethereum, thBILL OFT on Arbitrum, Base, HyperEVM, thBILL minter, timelock and admin multisig
Theo Docs: Terms & Conditions (read from the Internet Archive copy of 2025-08-07) · primary · accessed 2026-09-23
Supports: US citizens and residents barred, interface is not a broker or custodian
Theo: thBILL product page · primary · accessed 2026-09-23
Supports: ULTRA and FILQ named as holdings, proportional share wording, chains, market makers, $175M+ TVL claim
Theo: thBILL is Live (2025-07-24) · primary · accessed 2026-09-23
Supports: launch date, optimistic minting, chains at launch
Verified thBILL implementation IToken.sol on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: ERC-4626 multi-asset vault, pause blocks every transfer, rescueAsset, setConfig, upgradeToAndCall

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