VanEck Treasury Fund (VBILL)
Solana: can freeze a holder, claw back, gate who may hold, mint, change the code. An account only a program can sign for can freeze a holder and claw back tokens. A single key can change the code with no delay.
This file replaced an earlier version on 2026-09-24. Superseded to reconcile the minimum with the fund’s Form D. The May 2026 Form D/A states $100,000 as the minimum accepted from any outside investor, the lowest share-class figure; the file kept the $1,000,000 Ethereum class minimum without naming the filing. The file now cites the Form D and says which figure it follows. 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: VanEck Treasury Fund (VBILL) Under review
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
Qualified purchasers only, under the private placement memorandum.
“The Fund is available to Qualified Purchasers Only. Please carefully read the Private Placement Memorandum before investing.”
Securitize and VanEck: VBILL launch release · General Disclosures · words found 2026-09-23
- First purchase minimum
$100,000 on Avalanche, BNB Chain, and Solana; $1,000,000 on Ethereum.
“Minimum subscriptions start at $100,000 for investments on Avalanche, BNB Chain, and Solana, and $1,000,000 on Ethereum.”
Securitize and VanEck: VBILL launch release · Release body, paragraph on share classes · words found 2026-09-23
- Account types
The documents we read do not state this.
Not stated in Securitize and VanEck: VBILL launch release, Securitize, VBILL primary-market page content (Builder.io content API behind securitize.io/primary-market/vaneck-vbill), Securitize: VBILL primary-market page.
- Who it may be transferred to
Transfer rules, platform access, and investor eligibility may limit trading.
“Note: Secondary market trading is not guaranteed and may be limited by regulatory transfer restrictions, platform availability, or investor eligibility requirements.”
Securitize, VBILL primary-market page content (Builder.io content API behind securitize.io/primary-market/vaneck-vbill) · Live Marketplaces note · words found 2026-09-23
- How a holder redeems
The fund redeems daily, and third-party USDC swaps may also give liquidity.
“(4) Liquidity via a smart contract swap is potentially available through 3rd party providers. Redemptions directly through the fund are available on a daily basis. Liquidity and redemptions may be subject to delays due to market conditions or blockchain settlement mechanics.”
Securitize, VBILL primary-market page content (Builder.io content API behind securitize.io/primary-market/vaneck-vbill) · Fund Profile footnote (4) · words found 2026-09-23
- Who keeps the official record
The fund issues and records its shares on blockchains.
“Shares of VBILL are issued and recorded on blockchain networks, offering investors greater transparency and faster settlement times compared to traditional fund structures.”
Securitize and VanEck: VBILL launch release · 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 and VanEck: VBILL launch release, Securitize, VBILL primary-market page content (Builder.io content API behind securitize.io/primary-market/vaneck-vbill).
| 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 |
|---|---|---|---|---|---|
| 2026-05-29 | D/A | Rule 506(c); Investment Company Act section 3(c)(7) | $100,000 | $167,635,143 | 15 |
| 2025-05-29 | D | Rule 506(c); Investment Company Act section 3(c)(7) | $100,000 | $0 | 0 |
Filed by VanEck Treasury Fund, Ltd. (SEC CIK 2068562). 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 2026-05-29 Form D states a $100,000 minimum; the file records $1,000,000. 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. |
| Solana | Yes | No | Yes | Yes | Yes | An account only a program can sign for can freeze a holder and 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 2026-09-23. 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 | 0x62c8…50f3 |
| Solana | Mint authority | mint new tokens | an account only a program can sign for | BJXUcH…cgiK |
| Solana | Freeze authority | freeze a holder | an account only a program can sign for | BJXUcH…cgiK |
| Solana | Permanent delegate | claw back tokens | an account only a program can sign for | BJXUcH…cgiK |
| Solana | Transfer-hook authority | decide who may hold, change the code | an account only a program can sign for | BJXUcH…cgiK |
| Solana | Hook program upgrade authority | change the code | a single key | 8d36iv…zbB6 |
Ethereum: 14 contract reads, 6 functions in verified source, 2026-09-23
- eip1967.implementation=0xaf88485377cca5e690e7dcb1ba81370f0b575156
- owner()=0x59c1eacec450c57dcb9b8725d0f96635c2b676ee
- isPaused()=false
- getDSService(COMPLIANCE_CONFIGURATION_SERVICE)=0xf2afc03c9d30f6dff7a23a05f34ced7b0f894d22
- getDSService(COMPLIANCE_SERVICE)=0xc7bf9c1e49884c8b778f39800e18b52f4a9e2157
- getDSService(LOCK_MANAGER)=0xc8498692cb1fcb757b00d2687053ff4364321422
- getDSService(OMNIBUS_TBE_CONTROLLER)=0x7095ca685a789c71688850ab7a4138665b6158ae
- getDSService(REGISTRY_SERVICE)=0x897e452425bd1c860d7f9bc14ea045cbbc0fa0d4
- getDSService(SECURITIZE_SWAP)=0x488efd3ed474b205a0aade3732e4741432cba50b
- getDSService(TOKEN_REALLOCATOR)=0xf24b92e58763083b539e7a5ee5d989203bf6ff35
- getDSService(TRANSACTION_RELAYER)=0x57ccfc7de73f759f3567239ec9c9784045516cf2
- getDSService(TRUST_SERVICE)=0x08b9c1f3e2f236890b975dee37ee3579a0d4516b
- getDSService(WALLET_MANAGER)=0x115bdfa49d214f867116d05fd9a82abcfb97ebdf
- getDSService(WALLET_REGISTRAR)=0xeb9cc4f3f1bbcb7fd884bbd2e670b8a9f3b2099f
- issueTokensWithNoCompliance in verified source 0xaf88…5156
- lockInvestor in verified source 0xa2cd…edcc
- isPaused in verified source 0xaf88…5156
- burn in verified source 0xaf88…5156
- issueTokens in verified source 0xaf88…5156
- upgradeToAndCall in verified source 0xaf88…5156
Solana: 4 contract reads, 0 functions in verified source, 2026-09-23
- mintAuthority=BJXUcHs7R8m9oxzQkFxphZUXMY8SPsK8uPi5Sx7ycgiK
- freezeAuthority=BJXUcHs7R8m9oxzQkFxphZUXMY8SPsK8uPi5Sx7ycgiK
- permanentDelegate=BJXUcHs7R8m9oxzQkFxphZUXMY8SPsK8uPi5Sx7ycgiK
- transferHook=FsE8mCJyvgMzqJbfHbJQm3iuf3cRZC6n2vZi1Q8rQCy2
Where it trades
| Venue | Kind |
|---|---|
| Securitize primary market | issuer primary |
Redemption
| Route | Cutoff | Settlement | Settles in |
|---|---|---|---|
| Redeem with the issuer in its window | 2:00 p.m. Eastern | The fund redeems daily. Holders cannot transfer or redeem tokens until 72 hours after issuance. Third-party contracts offer USDC swaps where available | USDC, USD |
- Securitize publishes the executed offering memorandum with eligibility definitions, fees, gates, and suspension rights; Ketju will then check the file against it
- The compliance service, lock manager, proxy target, or issuer role on Ethereum changes, or the Solana mint, freeze, permanent-delegate, or transfer-hook authority changes
- The fund opens a share class to investors below qualified-purchaser status, or changes a share class minimum
- A NAV oracle failure, a missed daily redemption, or a Wormhole bridge incident affecting holders
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 4 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 the same day: the Ethereum share class minimum of $1,000,000 had been filed inside a venue name. The minimum is now the stricter figure with the per-chain terms stated as a term, and the venue is just the venue. |
| 2026-09-23 | Revised. Superseded to add the issuer’s own words for each term; no fact changed. |
| 2026-09-24 | Revised. Superseded to reconcile the minimum with the fund’s Form D. The May 2026 Form D/A states $100,000 as the minimum accepted from any outside investor, the lowest share-class figure; the file kept the $1,000,000 Ethereum class minimum without naming the filing. The file now cites the Form D and says which figure it follows. |
Sources
- SEC EDGAR: VanEck Treasury Fund, Ltd., Form D/A filed May 29, 2026 · primary · accessed 2026-09-24
Supports: Rule 506(c), section 3(c)(7), minimum accepted from any outside investor, amount sold, investor count - Securitize and VanEck: VBILL launch release · primary · accessed 2026-09-23
Supports: qualified purchasers only per the private placement memorandum, $100,000 minimum on Avalanche, BNB Chain, Solana, $1,000,000 minimum on Ethereum, State Street custodian, Securitize Fund Services administrator, RedStone daily NAV, British Virgin Islands, who may-hold, minimum, record - Securitize: VBILL primary-market page · primary · accessed 2026-09-23
Supports: 1:30 p.m. Eastern subscription deadline, 2:00 p.m. Eastern liquidity deadline, 72-hour hold after issuance, daily redemptions, 0.2% unitary fee, share classes and minimums by chain - VBILL Solana mint metadata (points at metadata.securitize.io) · primary · accessed 2026-09-23
Supports: issuer-anchored Solana mint, permanent delegate, transfer hook, freeze authority - Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: preTransferCheck compliance gate, pause, seize and omnibusSeize, issueTokens, upgradeToAndCall - Securitize, VBILL primary-market page content (Builder.io content API behind securitize.io/primary-market/vaneck-vbill) · primary · accessed 2026-09-23
Supports: transfer, redemption