KETJU Research

← The Register

Tokenized real-world assets

Superstate Opening Bell

Not approved No defect found; not on the approved list
Verdict
Not approved
No defect found; not on the approved list
Who can freeze it
Governed, no freeze
Withdrawals
There is no redemption.
Reviewed
2026-10-18 · next 2026-12-23
Researched memo

Summary

Ketju does not approve Superstate Opening Bell: the token is the share itself, but on-chain trading is not switched on, and the only way to sell is a slow transfer back to a broker. Opening Bell puts a listed company’s own common stock on a blockchain. Superstate Services LLC, an SEC-registered transfer agent (file 084-06972), keeps the records for shares that holders move out of a brokerage into Superstate. Galaxy’s 8-K calls tokenized GLXY ”Galaxy Digital Class A Common Stock, with all the rights that confers.” In the SEC staff’s January 2026 terms it is an issuer-sponsored security whose on-chain record feeds the master file. Five companies are live on 2026-09-23. Only FWDI has size: 7,280,819 tokens, 3.16 million of them lent out on Kamino. A US retail client qualifies after Superstate’s KYC, with no accredited status needed. The client keeps voting and dividend rights but loses SIPC cover. Superstate runs the allowlist. On Solana, a permanent delegate can move or burn tokens in any account, so a wallet balance is not a bearer position. The structure is sound. Today the only sound use for a client is converting shares the client already owns, in small size, after testing the DRS path back to the client’s broker.

Changes

2026-10-18The memo’s first sentence said Ketju had not reached a verdict on Superstate Opening Bell, but the Register showed Not approved. Ketju found no defect in the structure and has not approved it, because on-chain trading is not switched on. Ketju corrected the first sentence, and the verdict did not change. The prior memo

Research

How it works

Superstate launched Opening Bell in May 2025. Superstate Services LLC signs a Digital Transfer Agency Agreement with each company. Galaxy signed on 2025-05-20, Exodus on 2025-08-08, SharpLink on 2025-09-24, Forward Industries in September 2025 and Solana Company on 2025-10-17. The Exodus agreement, the only one filed in full, sets the terms: a $1 annual fee, a two-year term that renews itself, termination on 60 days’ notice, New York law and AAA arbitration. Superstate keeps ”Subsidiary Securityholder Records”, defined as the official ownership and transfer records for on-chain eligible shares. They include book-entry shares held at Superstate and tokens. The company’s recordkeeping transfer agent keeps the master securityholder file, and that file includes Superstate’s records. The Exodus agreement, filed with its 10-K, says so. A shareholder moves shares in by DRS transfer from a broker (2 to 3 business days). The holder can keep them in book-entry form at Superstate, or mint them as tokens to an allowlisted wallet, usually within minutes. Superstate mints or burns only on the shareholder’s written instruction and updates its records in the same step. Galaxy’s 8-K says the registered shareholder list updates in real time when tokens change hands. In the SEC staff’s January 2026 terms, this is an issuer-sponsored security whose on-chain record feeds the master file. It is neither a wrapper, nor a custodial receipt, nor a swap.

Who controls it

Superstate decides who may hold. Its agreement obliges it to program the tokens so they move only to wallets and DEX pools on its allowlist. It must first verify each wallet owner’s name, address and taxpayer ID and screen for sanctions. It may refuse any transfer it thinks improper. On termination it will, if the company asks, freeze all token transfers and let holders convert back to book-entry or certificates. Allowlist changes in the portal carry a 24-hour hold. On Solana the five mints use Token-2022 with accounts frozen by default. A freeze authority and a permanent delegate, both held by 2Yq4T3mPNfjtEyTxSbRjRKqLf1pwbTasuCQrWe6QpM7x (the same key Superstate uses on USTB), can freeze accounts and move or burn tokens in any account. The mints use a scaled-UI multiplier for splits, and each mint has its own mint authority. Those powers let a transfer agent correct its records, and they mean a wallet balance is not a bearer position. The SBET contract on Ethereum is a transparent upgradeable proxy over an ”EquityToken” implementation. Superstate’s docs say it will move EVM tokens to allowlist v4.2 in September 2026, which adds a Uniswap v4 hook check.

Size and holdings

Galaxy (GLXY), Forward Industries (FWDI), Exodus (EXOD) and Solana Company (HSDT) are live on Solana, and SharpLink (SBET) on Ethereum and Linea. Superstate’s asset pages on 2026-09-23 show the following. FWDI has 7,280,819.10 tokens and 1,442,616.90 book-entry shares, with 3,156,493.10 tokens deposited in Kamino. GLXY has 13,399.18 tokens and 30,134.82 book-entry shares, with 0.58 in Kamino. EXOD has 60 tokens and 250 book-entry shares. SBET has 1,912 book-entry shares and no tokens. HSDT has none. The filings agree. Forward Industries reported about 7,290,000 tokenized shares at 2026-06-30, and SharpLink’s August 2026 10-Q says it has tokenized no common stock. Upexi announced on 2025-06-26 that it would tokenize through Opening Bell, and SOL Strategies signed a memorandum of understanding on 2025-05-08. Neither appears on the asset list.

Losses and incidents

We found no incident, forced burn or record error in the filings and documents we reviewed. That finding covers only those sources.

Eligibility

Any investor in a supported country may hold without accredited status, so a US retail client qualifies after Superstate’s KYC.

Withdrawals

There is no redemption. Burning an equity token ”does not trigger a payout”; it turns the token back into a book-entry share at Superstate. To sell on Nasdaq or NYSE American, the holder asks for a DRS transfer through the recordkeeping transfer agent to a broker. Superstate’s terms call this a multi-step process of several business days. Superstate charges no fee; the transfer agent, broker and blockchain may. In practice no one can sell on-chain yet. Superstate lists Jupiter for GLXY spot trading, with no volume. Galaxy’s 10-Q for 2026-06-30 says it has not enabled AMM trading, and Superstate told Markets Media in August 2026 that AMM trading waits on the SEC. The SEC’s Innovation Exemption of 2026-09-17 now lets a Tokenized Securities Venue run permissioned AMM pools for tokenized NMS stock, with symbol and volume caps. None lists an Opening Bell token yet.

Comparison

Ondo Stocks and xStocks sell notes that track a share price. The holder is a creditor of an offshore issuer, and US persons are barred. DTC tokenization keeps the share inside DTC and the broker chain. Opening Bell is the only model Ketju has reviewed where the wallet holds the share itself, registered to the holder by name, with votes and dividends from the company. The Exodus agreement lets each shareholder choose cash or shares for dividends. Against a brokerage position, the holder gives up SIPC cover and a fast sale. The holder gains nothing a client needs today except use as collateral on Kamino.

Open questions

Superstate does not publish the list of countries or US states for tokenized equities. Only the Exodus agreement is public. Filings describe the Galaxy, Forward, SharpLink and Solana Company agreements but do not include them in full. None of the five companies pays a cash dividend, so no one has tested how dividends reach token holders. This memo does not settle whether a registered adviser can treat a client’s self-custodied, DRS-registered token as held by a qualified custodian, under the custody rule.

Sources

Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.

The asset and the chain

This memo covers the protocol. A position also holds an asset and settles on a chain. Whichever of the three holds the most power over the position decides who can freeze it. These tables describe control and do not judge quality.

ChainVerdictFreezeWhat it can do
SolanaApproved with limits Governed, no freeze no admin key can seize funds, but stake is concentrating and the Nakamoto coefficient is below 25.
EthereumApproved No freeze key Ethereum has no sequencer, no upgrade key and no operator who can be compelled to act; rule changes require social consensus.
Every memo is public. Subscribers link the research to the positions their clients hold, and Ketju emails them when the evidence changes. $299 per firm per month, first 30 days free. Start the trial.