RIADeFi
Original research · Tokenized assets on file · October 2026

What 95 files show: tokenized assets, October 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 said on 2026-10-01, and what changed in the month.

By All issues

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

Changed since last month

Since the last count, on 2026-09-30: no program filed; 0 programs changed who may hold them, 0 changed the minimum, and 0 changed what the file records about freezing a holder.

Revisions

No file was superseded.

What is on file

The count is by program, not by token: one file can cover dozens of tickers, or hundreds of properties. On 2026-10-01 the files covered 10 kinds of instrument.

Kind of instrumentPrograms
Notes and bonds20
Gold, silver, and other commodities19
Programs that mix kinds16
Money-market funds10
Stocks and shares10
Treasury funds9
Credit funds7
Real estate2
Payment stablecoins1
ETFs1
All programs95

Who may hold it

39 of the 95 programs are not offered to US persons. That is the largest group, larger than the 35 open to US retail investors. An advisor who finds one of the 39 in a US client’s wallet is looking at a holding the issuer’s terms do not allow.

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

The accredited and qualified-purchaser floors are mostly funds, with minimums to match: BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I) at $5 million, Franklin OnChain Institutional Liquidity Fund (iBENJI) at $5 million, Tradable private-credit deal tokens at $5 million, Fidelity Treasury Digital Fund, OnChain class (FYOXX), FDIT token at $1 million.

Retirement accounts narrow it further: 2 programs name IRAs as eligible, 4 exclude them in writing, and the rest do not say. Every program, row by row, and what the documents say about IRAs.

What the holder owns

The files sort each program by whose record counts. In 25 of 95 the documents do not say whether the chain or the issuer’s 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.

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 can freeze it

Ketju reads the deployed contracts and every module they consult on transfer. 89 of the 95 programs have a readable contract, and 47 of those gate who may hold. Across the 248 contracts read, 131 (53%) carry both a freeze and a claw-back power; 22 carry neither. A power is the issuer’s ability, not evidence it has been used, and it is how an issuer obeys a court order.

In 53 of the 89 readable programs, one private key decides whether a holder can be frozen, paused, or clawed back, or holds the admin key that grants that power. 8 put that decision behind a multisig and 14 behind a contract, a timelock, or a program. In 10 a power exists but its holder was not read, and 4 show no freeze or claw-back power at all. Key holders last read on 2026-09-30. Every key, program by program, is on the keys page.

One ticker, 9 versions

19 listed stocks and ETFs are tokenized by two or more programs on file. Only 2 of them have any version a US person may hold. NVDA has the most, 9: six are notes that pay like the share, three give a claim on a real share a custodian holds. None is offered to US persons. They share a ticker and little else. Every version, side by side.

What is not there yet

  • No program on file trades on a Tokenized Securities Venue under the SEC’s exemption of 2026-09-17 (the tokenized-securities guide sets out its conditions). Each file says so where it applies.
  • The DTC path, the one that would put the listed share itself in a broker’s wallet under the same CUSIP, is on file with no contract address yet. The daily document watch is how its first contract will show up.
  • 25 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

Counts are generated at build from the published eligibility files as they stood at the end of 2026-10-01, and this issue is recounted every day until the month closes. 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. A superseded file is archived with the date it stopped standing and the reason, never erased, so a past month counts the same on every rebuild. The files are public at the Register. Earlier and later issues: the series.