# Franklin BENJI (FOBXX), explained for advisors

> BENJI is a share of a registered government money market fund, open to U.S. retail from $20 and closed to IRAs. Who keeps the record, who can freeze it, how it redeems.

- URL: https://riadefi.com/tokenized-assets/programs/franklin-benji/
- Section: Tokenized assets · Explainer
- Author: Jon Ragsdale
- Reviewed: 2026-09-30
- Ketju record: https://ketjuresearch.com/register/files/franklin-benji/

## The short answer

BENJI is the token Franklin Templeton uses for shares of the Franklin OnChain U.S. Government Money Fund (FOBXX), a government money market fund registered under the Investment Company Act. One token is one share, priced to hold $1.00. The prospectus says: “Fund shares, or BENJI tokens, are offered without a sales charge.”[^1] A U.S. resident can open an account in the Benji app with $20. No IRA or other retirement account may invest.[^1]

The chain does not decide who owns a share. Franklin’s transfer agent does, and it can freeze, correct, or move any holder’s shares. The record is the [Ketju eligibility file for BENJI](https://ketjuresearch.com/register/files/franklin-benji/); Ketju’s verdict is in [the BENJI memo](https://ketjuresearch.com/register/franklin-benji/).

## What does the holder own?

The holder owns a fund share with the same claim as any other FOBXX share: a part of a pool of Treasury bills, government agency paper, and repurchase agreements, with a shareholder vote.[^2] The fund launched on April 6, 2021 on Stellar, and Franklin calls it the first U.S.-registered money market fund on chain.[^1][^3] It costs 0.20% a year after a fee waiver that runs to July 31, 2027.[^1]

The official record belongs to Franklin Templeton Investor Services (FTIS), the fund’s transfer agent and a Franklin subsidiary. FTIS keeps it “via a proprietary blockchain-integrated system that utilizes features of traditional book-entry form and one or more public blockchain networks.”[^1] A token balance counts because FTIS says it does. The prospectus says what happens to shares sent to the wrong wallet: whoever holds that wallet “would have no legal claim to such Fund shares.”[^1]

Income arrives as new tokens. Franklin says BENJI “accrues yield daily through newly minted BENJI tokens that are airdropped directly into shareholders wallets.”[^3] The fund reported 686.6 million shares outstanding for August 31, 2026.[^2] Ownership is concentrated. On July 1, 2026 the Stellar Development Foundation held 27.30% of shares and two Franklin companies held about 31% between them.[^1] Ondo’s OUSG fund held $41.3 million of BENJI on September 30, 2026.[^4]

## Who may hold it?

U.S. residents, with no accredited or qualified-purchaser test. The fund is “intended for sale to residents of the United States” and is sold only direct, through the Benji app for individuals and a web portal for institutions.[^1] Franklin publishes no list of the states where it may be sold, so the Ketju file records the states as unconfirmed.[^5]

The minimum depends on the chain, because network fees differ. The prospectus sets the first purchase at $20 on Stellar; $100 on Aptos, Base, and Solana; $1,000 on Polygon and Arbitrum; $20,000 on Avalanche; and $5,000,000 on Ethereum.[^1] Individuals use Stellar only. For an individual, FTIS creates the wallet and keeps its key; only institutions Franklin approves may keep their own keys.[^2][^3]

Retirement accounts are out. The prospectus: “The Fund does not permit investments by employer sponsored retirement plans, SIMPLE-IRAs, SEP-IRAs, SARSEPs or 403(b) plan accounts, IRAs, IRA Rollovers, Coverdale Education Savings Plans or Roth IRAs.”[^1] Because the fund sells only direct, a client’s shares sit in the client’s own Benji account, outside the custodian that holds the rest of the portfolio.[^2]

## Who can freeze it, and what can that key do?

FTIS can. The prospectus says shares on its system “are under the unilateral control of the transfer agent,” which “has the ability to correct errors and unauthorized transactions in, and limit the transferability of, Fund shares.”[^1] On August 12, 2026 SEC staff issued a no-action letter conditioned on FTIS keeping those powers. It describes “Administrative Controls” that let FTIS “maintain, correct, freeze, migrate, or restore the official record,” and requires FTIS to hand them, “including administrative control over any smart contracts,” to any successor transfer agent.[^6]

The chain shows how those controls are held. On Stellar, the issuer account has fourteen signing keys. Ketju’s reading found that any one of its ten heavier keys can revoke a holder’s authorization, which freezes the holder, or claw back shares, alone.[^2] On the five Ethereum-style chains the token can burn any holder’s shares, move shares between holders, and switch off transfers, and on every one of those chains whose role holders Ketju could read, the same three single keys can each replace the token’s code alone.[^2][^5] On Solana one ordinary key can upgrade every Franklin program that holds power over the token.[^2]

Franklin told SEC staff its keys sit behind “multi-signature and multi-party computation techniques, geographically and operationally distributed signers, and offline recovery capabilities.”[^6] A key split by multi-party computation still signs as one address, so the chain cannot show the split. Ketju records what the chain shows, next to what Franklin says.

## How does the holder get out?

Through the Benji app or the institutional portal, and only there. The fund works out its value each hour from 8:00 a.m. Eastern to its 5:00 p.m. close, and the day’s cutoff is 2 p.m. Pacific.[^1] Proceeds go “from your App account to your bank account within seven days after we receive your request in proper form.”[^1] ACH generally arrives in two to three business days.[^5]

Three details slow the exit. A sale over $250,000 may need written instructions with a signature guarantee. Shares bought by electronic transfer may wait up to ten calendar days for the payment to clear before the proceeds go out.[^1] The fund does not “receive or pay out cash in the form of currency or by check.”[^1] The prospectus names no stablecoin redemption.[^2]

Holders may also send shares to each other at any hour, but both wallets must be whitelisted with FTIS. Institutions got this in April 2024 and retail in May 2025.[^3] No exchange lists the shares, so a transfer is not a sale on a market.

## What has gone wrong or changed

| Date | What happened |
| --- | --- |
| 2021-04-06 | The fund launches on Stellar.[^1] |
| 2023-04 | Polygon added. Arbitrum and Avalanche follow in August 2024, Ethereum and Aptos in September 2024, Base in October 2024, Solana in February 2025.[^3] |
| 2025-05 | Retail holders can send shares to each other in the redesigned app.[^3] |
| 2025-07 | Franklin’s Benji page lists BNB Smart Chain as available. The August 2026 prospectus does not name it, and the Ketju file does not yet cover it.[^3][^1] |
| 2026-05-18 | Western Asset Management becomes sub-adviser under Franklin Advisers.[^2] |
| 2026-08-01 | The current prospectus takes effect, with the per-chain minimums and the retirement-account bar.[^1] |
| 2026-08-12 | SEC staff no-action letter on Rule 17f-2 for Franklin funds that hold FOBXX, conditioned on FTIS keeping its administrative controls.[^6] |

Ketju found no public report of a break in the $1.00 price, a redemption suspension, a record correction that touched a holder, or a contract exploit since the 2021 launch; that finding is bounded by what was read. The fund does not now intend to charge a liquidity fee, but its board may add one after notice.[^2]

## What to record in the client file

- That the account is at Franklin, in the client’s own name, and not at the firm’s custodian.
- That the account is not an IRA or other retirement account, which the fund bars.
- The chain and wallet, and who holds the wallet key: FTIS for an individual on Stellar.
- The client’s state, since Franklin publishes no state list.
- Whether the firm has trading authority over the Benji account, and how it treats that under the custody rule. Ketju’s memo leaves this to compliance counsel.
- The Ketju file’s reviewed date, so a change to the signing keys, a new chain, or a new prospectus reaches the client file.

## Sources

[^1]: [Franklin Templeton Trust, Form N-1A post-effective amendment (485BPOS): FOBXX prospectus and SAI effective Aug. 1, 2026](https://www.sec.gov/Archives/edgar/data/1786958/000165558926000970/c485bpos.htm), SEC EDGAR (primary, read 2026-09-30)
[^2]: [Ketju research memo: Franklin BENJI (reviewed 2026-09-23), citing the SAI, Form N-MFP3, Stellar Horizon, and verified contract source](https://ketjuresearch.com/register/franklin-benji/), Ketju Research (secondary, read 2026-09-30)
[^3]: [Benji: chains, retail availability, and launch history](https://digitalassets.franklintempleton.com/benji/), Franklin Templeton Digital Assets (primary, read 2026-09-30)
[^4]: [OUSG: holdings as of Sept. 30, 2026](https://ondo.finance/ousg), Ondo Finance (primary, read 2026-09-30)
[^5]: [Ketju eligibility file: Franklin OnChain U.S. Government Money Fund, BENJI (reviewed 2026-09-28)](https://ketjuresearch.com/register/files/franklin-benji/), Ketju Research (secondary, read 2026-09-30)
[^6]: [Staff no-action letter to Franklin Templeton, Rule 17f-2 (Aug. 12, 2026)](https://www.sec.gov/rules-regulations/no-action-interpretive-exemptive-letters/division-investment-management-staff-no-action-interpretive-letters/franklin-templeton-081226), SEC Division of Investment Management (primary, read 2026-09-30)

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Published by Ketju Research (https://ketjuresearch.com). Educational analysis only; not legal, tax, compliance, or investment advice.
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