# What 95 files show: tokenized assets, October 2026

> 39 of 95 tokenized programs on file are not offered to US persons. In October 2026: 0 programs filed, 0 programs changed who may hold, the minimum, or the freeze powers, and 0 revisions.

- URL: https://riadefi.com/research/tokenized-assets-on-file-2026-10/
- Issue: October 2026
- Counted: 2026-10-01 (recounted daily until the month closes)
- Series: https://riadefi.com/research/tokenized-assets-on-file/

## 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No file was superseded.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 instrument | Programs |
| --- | --- |
| Notes and bonds | 20 |
| Gold, silver, and other commodities | 19 |
| Programs that mix kinds | 16 |
| Money-market funds | 10 |
| Stocks and shares | 10 |
| Treasury funds | 9 |
| Credit funds | 7 |
| Real estate | 2 |
| Payment stablecoins | 1 |
| ETFs | 1 |
| All programs | 95 |

## 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 words | Programs |
| --- | --- |
| US retail investors | 35 |
| US accredited investors | 9 |
| US qualified purchasers | 12 |
| Not offered to US persons | 39 |

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)](https://ketjuresearch.com/register/files/blackrock-buidl/) at $5 million, [Franklin OnChain Institutional Liquidity Fund (iBENJI)](https://ketjuresearch.com/register/files/franklin-onchain-institutional/) at $5 million, [Tradable private-credit deal tokens](https://ketjuresearch.com/register/files/tradable-deal-tokens/) at $5 million, [Fidelity Treasury Digital Fund, OnChain class (FYOXX), FDIT token](https://ketjuresearch.com/register/files/fidelity-fdit/) 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](/tokenized-assets/who-may-hold/), and [what the documents say about IRAs](/tokenized-assets/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 owns | Programs |
| --- | --- |
| Not stated | 25 |
| Issuer direct | 24 |
| Third-party synthetic | 17 |
| Issuer indirect | 14 |
| Commodity receipt | 7 |
| Third-party custodial | 6 |
| DTC-tokenized (same CUSIP) | 1 |
| Issuer liability | 1 |

## 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](https://ketjuresearch.com/register/keys/).

## 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.](https://ketjuresearch.com/register/stocks/nvda/)

## 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](/asset-classes/tokenized-securities/) 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](https://ketjuresearch.com/register/files/). Earlier and later issues: [the series](/research/tokenized-assets-on-file/).

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Published by Ketju Research (https://ketjuresearch.com). Educational analysis only; not legal, tax, compliance, or investment advice.
Machine-readable index: https://riadefi.com/llms.txt · Content API: https://riadefi.com/content.json