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Original research · Tokenized assets

What 95 files show: tokenized assets, September 2026

Ketju keeps one file per tokenized program: what the holder owns, who may hold it in the issuer’s own words, who can freeze or claw it back, read from the chain, and how it exits. This is what 95 of them say when counted.

Counts from published files, not suitability claims. Not investment, legal, tax, or compliance advice.

What is on file

The 95 programs cover funds, stocks, notes, bonds, gold and silver, rental property, and one bank deposit. The count is by program, not by token: xStocks is one file with dozens of tickers, and RealT is one file with hundreds of properties. Every listed token in CoinGecko’s tokenized categories is on a file or left out with a published reason.

Kind of instrumentPrograms
Note20
Commodity19
Mixed16
Stock10
Money-market fund10
Treasury fund9
Credit fund7
Real estate2
Payment stablecoin1
ETF1

Who may hold it

39 of the 95 programs are not offered to US persons. That is the single largest group, larger than the 35 sold to US retail investors. Every tokenized stock from an offshore issuer, every Swiss tracker certificate, and most of the tokenized Treasury funds built for stablecoin treasuries sit in it. An adviser who finds one in a client’s wallet is looking at a holding the issuer says the client may not have. Ketju checks the household against these terms and reads Terms not met; it does not say what the issuer would do about it.

Who may hold, in the issuer’s wordsPrograms
Not offered to US persons39
US retail investors35
US qualified purchasers12
US accredited investors9

The qualified-purchaser and accredited floors are the funds: BUIDL at $5,000,000, BRSRV and BSTBL at $3,000,000, ACRED at $50,000. A mass-affluent household is excluded before quality is reached.

What the holder owns

The files sort each program by whose record counts. In 25 of 95 the documents do not say: the issuer describes the token, the transfer agent, and the fund, and never states whether the chain or the register governs a dispute between them. 17 are notes or swaps that pay like the security and carry no rights in it. 6 are a custodian’s claim on a real share. The share itself, with the holder’s name on the issuer’s list, is the minority.

What the holder ownsPrograms
Not stated25
Issuer direct24
Third-party synthetic17
Issuer indirect14
Commodity receipt7
Third-party custodial6
DTC-tokenized (same CUSIP)1
Issuer liability1

Who holds the key

Ketju reads the deployed contracts and every module they consult on transfer, then reads who holds each power. 87 of the 95 programs have a readable contract. In 53 of them, one private key decides whether a holder can be frozen, paused, or clawed back, or can grant that power. 9 put that decision behind a multisig. 12 have no restraining power at all.

Across the 212 contracts read, 116 (55%) carry both a freeze and a claw-back power; 21 carry neither. The power is the issuer’s ability, not evidence it has been used, and it is how an issuer obeys a court order. But a token is only as safe as the key, and a single key is one laptop.

Every key, program by program, is on the keys page.

One ticker, 10 versions

397 listed stocks and ETFs are tokenized by two or more programs on file. Only 6 of them have any version a US person may hold. NVDA has 10: three give the holder a claim on a real share that a custodian holds, seven are notes that pay like the share, none is offered to US persons, and in 5 a single key can freeze the holder. They share a ticker and little else. Every version, side by side.

The first security used as collateral

On 2026-09-25 Aave v4 on Base began taking AAPLc, AMZNc, GOOGLc, METAc, MSFTc, NVDAc, TSLAc as collateral for USDC loans. It is the first lending market where the collateral is a security, and it is the reason a file cannot stop at the token. A USDC supplier in that market depends on five links: the certificate, issued by an Abu Dhabi company that holds the shares as bare trustee at a US broker; a Chainlink price that runs 24/5 and holds over the weekend while interest accrues; a reserve that pauses for a split or a dividend; a liquidation that sells the certificate into the Base bid, not the share; and an offer made only to non-US persons. The Aave v4 memo records the loan; the Coinbase file records the token.

What is not there yet

  • No Tokenized Securities Venue has filed the public notice the SEC’s September order requires, so no tokenized listed stock trades on a venue under the order. The files say so on each program.
  • The DTC path, the one that would put the listed share itself in a broker’s wallet under the same CUSIP, has a no-action letter and no contract. The file is on record with no address, and the daily document watch is how its first contract will show up.
  • Twenty-five programs whose documents do not say whose record governs. Each file names the document read and the date; the answer waits on the issuer.

Method note

Counts are generated at build from the published eligibility files and the committed control readings on 2026-09-27. A file quotes the issuer’s document for each term and records the date the words were found; a key reading names the contract, the method called, and the block. The files are public at the Register, and this page is regenerated when they change.