The memo
REJECTED ON ACCESS AND MISCLASSIFICATION RISK. MI4 is not a tokenized treasury or money-market product despite sitting in this backlog's issuer/RWA queue — it is a crypto-native, market-cap-weighted digital-asset index fund holding BTC, ETH, and SOL with a staking and restaking yield overlay (Mantle's mETH, Bybit's bbSOL, Ethena's sUSDe), explicitly marketed as "the crypto equivalent to the S&P 500." Confusing this for a stable-NAV treasury product would misstate the risk to a client. Independent of that classification issue, the fund is a BVI limited partnership restricted to non-US persons under Regulation S or US accredited investors under Regulation D, with a $100,000 minimum subscription — the same access bar already applied to BUIDL, USYC, Ondo Global Markets, and Anemoy/JTRSY in this registry. On-chain figures also show only 6 holders against a roughly $117.6M tracked balance, an extreme concentration this review treats as a real counterparty and liquidity consideration distinct from smart-contract risk.
What would reopen the file
- A US-eligible offering opens to this registry's target client population
- The on-chain tracked balance reconciles with the fund's reported total AUM, or the discrepancy is explained from a primary source
- Holder concentration diversifies meaningfully beyond the current 6 holders
- This entry's crypto-index classification is confirmed to remain distinct from any stable-NAV treasury product comparison in advisor-facing materials
Facts on file
- Verdict
- Rejected
- Exposure
- other
- Chains examined
- Mantle
- Instruments
- MI4
- Memo version
- v1
- Reviewed
- Next review