The memo
REJECTED. BCAP is a tokenized, indirect fractional non-voting economic interest in Blockchain Capital III Digital Liquid Venture Fund, LP, an illiquid venture-capital fund, sold under Regulation D to a maximum of 99 US accredited investors (Investment Company Act Section 3(c)(1)) plus Regulation S offshore investors. There is no investor-initiated redemption right: the issuer may redeem tokens only at its own option, no earlier than the ten-year anniversary of the 2017 issuance — 2027 at the earliest — and secondary transfer is restricted to selling an entire position to a single buyer, enforced by Securitize's whitelist-only DS Protocol. DefiLlama's roughly $959M TVL figure is not locked, tradeable value; it is outstanding token supply times an oracle-fed NAV price that jumped from roughly $22-28 to roughly $106 per token in about three weeks in April-May 2026, with token supply essentially flat — a move far outside this fund's own single-digit-to-10% quarterly NAV history, most plausibly explained by a mark-to-market of the fund's stake in Securitize itself following Securitize's SPAC listing (down roughly 40% within a week of trading). None of this is suitable for an RIA's liquid crypto sleeve.
What would reopen the file
- An investor-initiated redemption right exists, not solely an issuer option starting in 2027
- A confirmed, liquid, non-whole-position secondary market exists for retail-inaccessible accredited holders
- The April-May 2026 4x NAV repricing is independently explained and confirmed from a primary TokenHub report
- Fund concentration in any single underlying position, including Securitize itself, is disclosed and bounded
Facts on file
- Verdict
- Rejected
- Exposure
- other
- Chains examined
- ZKsync Era
- Instruments
- BCAP
- Memo version
- v1
- Reviewed
- Next review