Research summary
ACRED is a token for a share in a British Virgin Islands company that owns one thing: Class I shares of Apollo Diversified Credit Fund, a registered interval fund that lends to companies and against assets. The company, Securitize Tokenized Apollo Diversified Credit Fund, Ltd., was formed in 2024 and sells under Rule 506(c) to accredited investors only. It relies on the section 3(c)(1) exclusion, so it may never have more than 100 beneficial owners; its February 2026 Form D reported 26 investors and $110.9 million sold. Securitize is placement agent, transfer agent, and fund administrator, and its page sets a $50,000 minimum. The token cannot be more liquid than the fund beneath it. Apollo’s fund offers to buy back at least 5% of its shares once a quarter. ACRED takes redemption requests monthly inside that quarterly notice period and pays only after the underlying fund pays, with no promise of a full redemption. Money goes in at once, through a USDC swap; it comes out on Apollo’s quarterly schedule, prorated if too many holders ask at the same time. The wrapper adds costs the fund itself does not carry. Securitize estimates the feeder’s own expenses at 0.72% a year on top of the underlying Class I expenses of 3.34%, and it reports a further 0.50% lost to US withholding tax on the fund’s distributions, because the holder of the fund shares is a foreign company. On Ethereum one ordinary Securitize key owns the ACRED contract, the same key that owns the STAC and VBILL contracts; the contract can be upgraded, paused, and made to lock an investor or take back tokens. On Solana one address holds mint, freeze, and permanent-delegate power. The assessment is adverse because ACRED loses the comparison with the fund it holds. An advisor can buy Apollo Diversified Credit Fund directly: it has a public prospectus, sits under the Investment Company Act, takes $2,500 in Class A, and offers the same quarterly repurchases. ACRED wraps those shares in an unregistered offshore company, limits it to accredited investors and 100 owners, and adds a fee layer, a tax drag, and a single key. It reopens if a tokenized share class is issued by the registered fund itself, or if the feeder’s costs and liquidity match holding the fund directly.
Observable review triggers
- Apollo Diversified Credit Fund issues a tokenized share class itself, under its registered prospectus
- The feeder’s expenses and withholding drag fall to the cost of holding Class I directly, or the feeder moves onshore
- The private placement memorandum becomes available and changes the investor class, minimum, gates, or redemption terms read here
- Apollo Diversified Credit Fund cuts a quarterly repurchase offer below 5%, prorates a tender, or delays payment past the posted date
- The ACRED owner key, proxy implementation, compliance service, or lock manager on Ethereum changes, or the Solana mint, freeze, delegate, or hook authority changes
- The feeder nears 100 beneficial owners or leaves the section 3(c)(1) exclusion
- Any loss of principal, NAV markdown above 2% in a month, or token incident
Facts on file
- Research assessment
- Adverse
- Client selection
- Not considered
- Exposure
- tokenized RWA
- Chains examined
- Ethereum, Solana, Aptos, Avalanche, Ink, Polygon, Sei
- Instruments
- ACRED
- Reviewed
- Next review