The memo
v2 SUPERSEDES v1. Access resolved 2026-08-01: USYC is issued through a Cayman-domiciled feeder for NON-US PERSONS, with US access limited to qualified purchasers at a $100k minimum. A US mass-affluent client cannot hold it either way. Rejected on access — and the v1 concentration concern stands as a second, independent objection: a client holding USDC and USYC has one counterparty (Circle), not two, so even a future retail class would need that answered before approval.
What would reopen the file
- n/a — rejected on access. Revisit if Circle ships a US retail class AND the USDC/USYC single-counterparty concentration is addressed
Facts on file
- Verdict
- Rejected
- Exposure
- tokenized RWA
- Chains examined
- Ethereum, BSC
- Instruments
- USYC
- Memo version
- v2
- Reviewed
- Next review