The memo
NOT class-disposed, because Midas is genuinely mixed and a blanket verdict would be wrong in both directions. ~$2.1B issued, $50M Series A led by RRE and Creandum with Framework, Franklin Templeton and Coinbase Ventures. German issuer (Midas Software GmbH, Berlin) with UK protocol entity, and an EU-first regulatory approval to offer tokenised products to retail. Three products, three different risk categories: mTBILL is a tokenised claim on short-dated US Treasuries — the same instrument class as BUIDL and OUSG, and potentially approvable on the same terms. mBASIS is an ARBITRAGE STRATEGY token. That is a basis trade, the same category we rejected at Ethena, and it must never be blended with mTBILL in a client conversation because the shared "m" prefix invites exactly that. mBTC is a Bitcoin-backed debt instrument incorporating lending agreements — credit risk, not Bitcoin exposure. One issuer, three instruments, ranging from government debt to a levered trade. v2 SUPERSEDES v1 on the decisive fact, resolved 2026-08-01: Midas tokens are NOT OFFERED TO US PERSONS at issuance (UK, China and sanctioned jurisdictions also excluded). The tokens trade permissionlessly on secondary markets — and acquiring a security around its own eligibility restrictions on behalf of clients is explicitly REFUSED, not a loophole. Rejected on access for a US client base. Worth keeping in view: the EU retail approval makes Midas the closest thing this instrument class has to the retail share class it lacks — if that model reaches the US, mTBILL (and only mTBILL; mBASIS remains a basis trade in the Ethena category) is re-reviewable.
What would reopen the file
- n/a — rejected on access. Revisit on any US-eligible Midas offering; confirm current issuer terms directly before acting
Facts on file
- Verdict
- Rejected
- Exposure
- tokenized RWA
- Chains examined
- Ethereum
- Instruments
- MTBILL
- Memo version
- v2
- Reviewed
- Next review