The memo
REJECTED ON AN UNRESOLVED ELIGIBILITY QUESTION AND UNDISCLOSED CONTROL MECHANICS, NOT A CLEAR ACCESS BAR. USDtb is materially a wrapper on BlackRock BUIDL — described at launch as backed over 90% by BUIDL plus a stablecoin reserve for redemption liquidity — and BUIDL is already rejected in this registry on qualified-purchaser access grounds. The issuer itself changed structurally in October 2025: issuance, redemption, and reserve management moved from an offshore BVI/Cayman entity (Pallas) to Anchorage Digital Bank, N.A., an OCC-chartered federally regulated digital-asset bank, with US Bank custodying the non-BUIDL reserve portion. That is a genuine step toward a more US-regulated structure, but it creates a live, unresolved conflict this review could not settle: Ethena's general application interface has historically excluded US users, while Anchorage is itself a US OCC bank now running wire and SWIFT-based mint and redeem — it is not established which rule now governs US-person access. Redemption minimums and fees are undisclosed in every source reviewed, and no source confirmed whether the USDtb contract carries an issuer-side freeze or blacklist function. Until eligibility and control are affirmatively confirmed, this stays rejected rather than assumed accessible.
What would reopen the file
- US-person eligibility for direct USDtb minting and redemption is affirmatively confirmed under the current Anchorage-issued structure
- Minimum investment size and fee schedule are publicly disclosed
- The USDtb contract's freeze or blacklist mechanics, or their absence, are confirmed from primary contract source
- Current reserve composition (BUIDL versus cash and other holdings) is disclosed at a specific, dated percentage
Facts on file
- Verdict
- Rejected
- Exposure
- tokenized RWA
- Chains examined
- Ethereum
- Instruments
- USDTB
- Memo version
- v1
- Reviewed
- Next review