Tradable private-credit deal tokens

Research, firm shelf, model-client eligibility, and advisor selection are recorded separately. The scheduled date is the outside bound; new evidence can reopen the file sooner.

Tradable Corp, a Chicago software company founded in 2022, runs a marketplace where private credit managers sell shares of loans they have made. Each loan listed on Tradable gets its own ERC-20 contract on ZKsync Era, and an investor who funds a share receives tokens that count it: one token per dollar of principal, burned as the borrower repays. Tradable’s own registry contract lists 50 of these deal tokens; 37 carry a balance, $2.29 billion of face value in all, and 13 are empty. CoinGecko groups 18 of them as “Tradable” notes worth $1.36 billion; its names and figures do not always match the chain. The token is a count, not a claim anyone can read. The borrower and the manager selling the loan are hidden until an investor signs a non-disclosure agreement, and the holder’s rights live in a subscription agreement that is not public. No offering filing for any Tradable deal appears on EDGAR. Tradable says it is neither a broker-dealer nor an adviser, holds no customer money or securities, and leaves investor qualification to the parties. The holder cannot move the token. The verified contract makes transfer, transferFrom, and approve revert; only the deal’s manager contract can mint, burn, or move a balance, and two ordinary single-signature keys hold the role that tells it to. One of those keys also holds the admin role, which can re-code every Tradable deal token at once through a shared beacon with no delay. Seven of the eight deals filed here take $5,000,000 at the least, and none has money set aside today for early redemptions. The assessment is adverse. An advisor cannot tell a client what the client would own, whose debt it is, what secures it, or which record wins if the chain and the manager’s books disagree, and the chain itself is not approved here. The memo reopens if Tradable or a manager publishes the note terms and the governing record for a deal, and the deal keys move behind a multisig and a delay.

Research triggers: events that reopen the assessment or shelf decision
• Tradable or a manager publishes, for any deal, the note or participation terms: the issuer, the security, and which record governs ownership
• An offering filing (Form D or an offering memorandum) for a Tradable deal becomes public
• The DEAL_ADMIN and ADMIN roles on the AccessManager move to a multisig, or the beacons gain an upgrade delay
• ZKsync Era is approved in this registry, or Tradable deal tokens appear on an approved chain such as Stellar with published contracts
• The Deal implementation behind the beacon changes, or a role is granted to a new address
• Any deal misses a scheduled payment, writes down NAV below 1.0, or burns tokens without a matching repayment

The research file

What a deal token is

A manager with a loan to sell lists it on Tradable. The listing shows the size, the rate, and a one-line description, with the borrower and the seller anonymous; an investor who wants the name and the loan papers asks for access and signs an NDA. The investor then offers an amount, the manager accepts, trims, or declines it, and the investor signs the deal’s subscription agreement. When the manager confirms the money has arrived, the deal manager contract mints tokens to the investor’s wallet, or, for an investor who paid by wire, to a “fiat” wallet Tradable assigns. Interest is paid pro rata to how long each wallet held; each principal repayment burns the same share of every balance, and full repayment burns all of it.

Tradable’s own words leave the legal question open. Its explainer calls a tokenized asset “a digital representation of or a digitized legal ownership interest,” and calls a deal token “an investor’s funded stake in a loan or credit facility.” Which of the two it is, who the stake is against (the borrower, the manager’s fund, or a vehicle between them), and what collateral stands behind it are written only in the subscription agreement, which this review could not read. The deal names help a little: most say “Senior Secured Term Notes” or “Senior Secured Term Loan,” and the metadata Tradable pins to each contract gives a floating cash rate (8.25% for the rent financing deal, 9.75% to 12% for the US buy-now-pay-later lender). None names the issuer of the notes.

Who may hold, and how much

Every investor passes Tradable’s identity, business, and anti-money-laundering checks, run through Quadrata. Tradable’s docs say each manager sets the rules for its own deal, and that some deals are open to any cleared investor while others take only US accredited investors and qualified purchasers. The metadata on all eight filed deals reads the same: US investors only, any entity type, any investor status. Tradable’s terms of service put the accreditation duty on the parties, not on Tradable. With no public offering document, the securities exemption each deal relies on, and so the investor floor it legally needs, is unknown; the file records the stricter accredited reading.

The contracts fix the rest. Each deal manager sets a minimum investment: $5,000,000 on seven of the eight deals filed, $250,000 on the post-settlement legal financing deal. Each deal caps holders at 50, and each keeps a list of eligible wallets that every mint and move checks. On 2026-09-23 the eight deals had between 5 and 12 holders each, and most of the supply sat in fiat wallets; the three largest have never sent a transaction.

How money gets out

The plain exit is maturity: the borrower pays, the manager passes the money on in USDC or by wire, and the tokens burn. Before maturity the holder may ask the manager to redeem, and the manager may say no. An approved request locks the tokens for a five-day period while the manager, or another investor, puts USDC into the deal’s redemption pool; the holder then swaps tokens for USDC and the tokens go back to the manager. On 2026-09-23 the redemption budget on all eight filed deals was zero. Tradable also runs a secondary process: a holder asks, the manager approves, the position is listed, a buyer signs an NDA and bids, and “both the originator and the current holder must approve the transfer.” None of these paths is a right. Each turns on the manager saying yes and someone having cash.

Who controls the token

Every deal token is a beacon proxy that runs the code at one beacon, 0x1E2f5e41Ea5dCB62c8303e240E1d513eD4eC3d74, verified on the ZKsync Era explorer as Deal.sol. The code turns off transfer, transferFrom, and approve. Every power sits behind onlyManager: mint, burn from any wallet, move tokens from any wallet to any other (managedTransfer), add or drop eligible wallets, and set the NAV. The manager is a second beacon proxy per deal (DealManager.sol, also verified), and it asks Tradable’s OpenZeppelin AccessManager at 0xd9a7937CEb7c8fC8629DDE7C8557B24ae60C3717 who may call each function.

The AccessManager’s own events and hasRole answers show two roles that matter. DEAL_ADMIN, which may burn, move, and mint tokens and edit the eligible list on every deal, is held by two addresses with no code, 0x08ac…29ab and 0x1b89…95fe: each is one private key. ADMIN, which may upgrade both beacons, grant any role, and send the unclaimed payouts of a dropped wallet to the manager’s capital account, is held by 0x08ac…29ab and by Tradable’s deal factory contract. Neither role carries an execution delay. One key can therefore change the code of all 50 deal tokens in one transaction. These powers let Tradable keep the chain in step with the loan books; they also mean the chain is only as sound as those two keys.

The chain and the numbers

Tradable runs on ZKsync Era, which this registry rejected on 2026-08-17: an emergency board can upgrade the rollup with no delay, and an operator filter can block transactions, withdrawals included. Tradable announced in July 2026 that it will bring up to $1 billion of private credit to Stellar; no Stellar deal token was found.

CoinGecko’s $1.36 billion is its own count of supply at $1, under names it chose. Its “Tradable APAC Diversified Finance Provider SSTN” points at the contract whose Tradable metadata says “US Buy Now, Pay Later Finance Provider Senior Secured Term Notes.” Three of its names, “Tradable LatAm Fintech SSTN” at $134 million and two “Tradable Singapore Fintech SSL” entries at $114.5 million and $100 million, point at contracts whose supply on 2026-09-23 was zero: $348.5 million of the category sits on contracts whose tokens were all burned or never minted. The chain, Tradable’s registry, and the metadata Tradable pins to each contract are the sources this file uses.

Comparison and decision

The comparison with the private credit already in this registry turns on disclosure. Apollo’s ACRED feeder files a Form D and points to a registered fund with a public prospectus; Figure’s YLDS is a registered certificate with a prospectus and a named transfer agent. A Tradable deal token names no issuer, publishes no terms, and files nothing, and the holder cannot move it. The loans may be sound; nothing found here says otherwise. But an advisor cannot defend owning something whose issuer, security, and governing record are unknown, held on a chain this registry does not approve, under keys that can rewrite any balance. The assessment is adverse. Model-client eligibility is unresolved, because the investor class each deal legally requires is in documents this review could not read.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Tradable product docs: How it Works · primary · accessed 2026-09-23
  Supports: one ERC-20 per deal, minted on funding, pro rata interest, burn on principal repayment, redemption pool, fiat and wallet funding
• Tradable product docs: Investors · primary · accessed 2026-09-23
  Supports: NDA before data room, subscription agreement, fiat wallet, redemption may be denied
• Tradable product docs: Onboarding · primary · accessed 2026-09-23
  Supports: manager sets deal compliance, US only, accredited, qualified purchaser deals, entity accounts
• Tradable product docs: Smart Contract Addresses · primary · accessed 2026-09-23
  Supports: Access Manager, Deal Registry, Deal Beacon, Deal Factory addresses, UUPS and beacon upgradeability
• Tradable Terms of Service (updated February 13, 2026) · primary · accessed 2026-09-23
  Supports: not a broker-dealer or adviser, holds no customer funds or securities, parties own accreditation checks
• Tradable: What Tokenization of Private Credit Actually Means · primary · accessed 2026-09-23
  Supports: representation or legal ownership interest, deal token as funded stake, system of record
• Tradable: What Happens When a Deal Lists on Tradable · primary · accessed 2026-09-23
  Supports: anonymous listings, minimums in the millions, secondary needs originator and holder approval
• Tradable: About Us · primary · accessed 2026-09-23
  Supports: founded 2022 as a joint venture, leadership
• ZKsync Era explorer: verified Deal.sol (deal token implementation) · primary · accessed 2026-09-23
  Supports: transfer disabled, onlyManager mint, burn, managedTransfer, eligible accounts, max holders
• ZKsync Era explorer: verified DealManager.sol · primary · accessed 2026-09-23
  Supports: restricted functions, minimum investment, redemption budget, revokePayout
• Tradable deal metadata, PC0000031 (IPFS, pinned by the contract) · primary · accessed 2026-09-23
  Supports: deal title, cash rate, US only, any investor status
• CoinGecko: tokenized credit category · secondary · accessed 2026-09-23
  Supports: 18 Tradable names, $1.36B market cap, names that differ from metadata

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The most administered layer sets the position’s effective control grade; that is a control description, not a quality or suitability score.