The memo
v2 SUPERSEDES v1, which held this under review "pending whether retail-sized clients can access it at all." Resolved 2026-08-01, and the answer is no: BUIDL is restricted to QUALIFIED PURCHASERS (Investment Company Act §2(a)(51) — $5M+ in investments for an individual), with a $5M minimum initial subscription for individuals, a $250k redemption minimum, and Securitize KYC plus wallet whitelisting before a single token can be minted. Our clients are mass affluent; they are categorically not qualified purchasers. REJECTED ON ACCESS, NOT QUALITY. The v1 assessment stands: the largest tokenised Treasury fund, the tokenisation thesis in its most institutional form, and never a sovereignty play. It is simply an instrument our client base is not permitted to buy, and an advisor cannot recommend what a client cannot hold.
What would reopen the file
- n/a — rejected on access. Revisit immediately if BlackRock/Securitize ship a retail or accredited-investor share class
Facts on file
- Verdict
- Rejected
- Exposure
- tokenized RWA
- Chains examined
- Ethereum, Solana, Aptos, Arbitrum, Polygon
- Instruments
- BUIDL
- Memo version
- v2
- Reviewed
- Next review