Tradable private-credit deal tokens
Summary
Ketju does not approve Tradable deal tokens: Tradable and the managers do not publish who issues the notes, what secures them or which books govern ownership, and the tokens run on ZKsync Era, a chain Ketju does not approve. 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. An investor who funds a share receives one token per dollar of principal, and the manager burns tokens 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. The holder cannot move the token. Only the deal’s manager contract can mint, burn or move a balance, and two single-signature keys hold the role that directs it. One of those keys can also change the code of every Tradable deal token at once, with no delay. Seven of the eight deals Ketju reviewed require at least $5,000,000. Ketju will review the tokens again if Tradable or a manager publishes the note terms and names the governing books for a deal, and the deal keys move to a multisig with a delay.
- Tradable or a manager publishes, for any deal, the note or participation terms: the issuer, the security, and which books govern 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
- Ketju approves ZKsync Era, or Tradable deal tokens appear on an approved chain such as Stellar with published contracts
- The Deal implementation behind the beacon changes, or Tradable grants a role to a new address
- Any deal misses a scheduled payment, writes down NAV below 1.0, or burns tokens without a matching repayment
Ketju checks this memo every night and opens a review if its venues or files show a warning or a cited document changes. The first confirmation is due 2026-12-23.
Research
How it works
A manager with a loan to sell lists it on Tradable. The listing shows the size, the rate, and a one-line description, and it keeps 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. For an investor who paid by wire, it mints to a “fiat” wallet that Tradable assigns. The manager pays interest pro rata to how long each wallet held the token. 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.” Only the subscription agreement states which of the two the token is, whom the stake is against (the borrower, the manager’s fund, or a vehicle between them) and what collateral secures it. We could not read that agreement. Most deal names say “Senior Secured Term Notes” or “Senior Secured Term Loan.” The metadata Tradable pins to each contract gives a floating cash rate: 8.25% for the rent financing deal, and 9.75% to 12% for the US buy-now-pay-later lender. None names the issuer of the notes.
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.
Eligibility
Every investor passes Tradable’s identity, business, and anti-money-laundering checks, which Quadrata runs. Tradable’s docs say each manager sets the rules for its own deal. Some deals are open to any cleared investor, and others take only US accredited investors and qualified purchasers. The metadata on all eight deals we reviewed reads the same: US investors only, any entity type, any investor status. Tradable’s terms of service put the accreditation duty on the parties and leave Tradable out of it. No deal has a public offering document, so we do not know which securities exemption each deal relies on or which investor minimum it legally needs. The file uses the stricter accredited reading.
The contracts set the rest. Each deal manager sets a minimum investment: $5,000,000 on seven of the eight deals we reviewed, and $250,000 on the post-settlement legal financing deal. Each deal caps holders at 50, and each keeps a list of eligible wallets that it checks on every mint and move. 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 wallets have never sent a transaction.
Withdrawals
The usual way to get cash back 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 refuse. After the manager approves a request, the tokens lock 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 deals we reviewed was zero. Tradable also runs a secondary sale process. A holder asks, the manager approves, Tradable lists the position, and a buyer signs an NDA and bids. Then “both the originator and the current holder must approve the transfer.” The holder has no right to any of these sales or redemptions. Each one needs the manager’s approval and a party with cash.
Who controls it
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). 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 may burn, move, and mint tokens and edit the eligible list on every deal. Two addresses with no code hold it, 0x08ac…29ab and 0x1b89…95fe, and each is one private key. ADMIN may upgrade both beacons, grant any role, and send the unclaimed payouts of a dropped wallet to the manager’s capital account. 0x08ac…29ab and Tradable’s deal factory contract hold it. Neither role carries an execution delay, so one key can change the code of all 50 deal tokens in one transaction. Tradable uses these powers to keep the chain in step with the loan books. They also mean that anyone who holds either key can change any balance.
Size and holdings
Tradable runs on ZKsync Era, which Ketju did not approve 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. We found no Stellar deal token.
CoinGecko groups 18 of the deal tokens as “Tradable” notes worth $1.36 billion. That figure is CoinGecko’s own count of supply at $1, under names CoinGecko 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 point at contracts whose supply on 2026-09-23 was zero: “Tradable LatAm Fintech SSTN” at $134 million, and two “Tradable Singapore Fintech SSL” entries at $114.5 million and $100 million. So $348.5 million of the category sits on contracts whose tokens were all burned or never minted. We use the chain, Tradable’s registry, and the metadata Tradable pins to each contract as the sources.
Comparison
Disclosure separates Tradable from the private credit already in the Register. 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, and we found nothing against them. But an advisor cannot defend owning a token whose issuer, security, and governing books are unknown, on a chain Ketju does not approve, under keys that can change any balance. Our research weighs against the tokens. Whether a typical client qualifies is not settled, because each deal states its legal investor class only in documents we could not read.
Sources
Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.
- 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
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.
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