Tokenized money market fund — 3(c)(7) qualified purchaser, $5M minimum, 9 chains, Securitize as transfer agent.
"The investor eligibility gate — Securitize verifies 3(c)(7) qualified purchaser status before proceeding."
Securitize (SEC-registered transfer agent) verifies that the prospective investor meets Investment Company Act § 3(c)(7) qualified purchaser criteria: $5M+ in investments, accredited investor status, or qualified institutional buyer (QIB) designation. KYC (D1) and licensing (D8) verified. This is the compliance heavyweight — the highest bar in the stablecoin universe. Policy-enforced at L4–L5.
"The subscription gateway — investor signs fund agreement and source-of-funds documentation passes AML/CFT screening."
Investor executes subscription agreement (SEC Form N-PX equivalent for digital fund) and provides source-of-funds evidence. Securitize and BlackRock conduct AML screening (D2) for sanctions, PEPs, and typologies. This is the document boundary — the bridge between traditional fund law and on-chain settlement. D1 (identity), D2 (sanctions reporting), and D8 (licensing) are active.
"The NAV gate — fund administrator confirms daily NAV and allocates subscription at market price."
PwC (SEC-registered fund administrator) calculates daily NAV based on BUIDL holdings (short-term Treasuries, overnight repo, cash). Subscription amount is allocated at NAV. This is the prudential checkpoint — D9 (capital and valuation requirements) and D14 (consumer protection via fair pricing) fire. Policy-enforced at L3.
"The issuance boundary — BUIDL tokens are minted only to whitelisted addresses. The smart contract IS the transfer agent."
BUIDL tokens minted natively on settlement chain (Ethereum, Avalanche, Polygon, Arbitrum, Optimism, Aptos, or Solana). Smart contract enforces whitelist at mint time — only addresses pre-approved by Securitize receive tokens. This is the compliance heavyweight moment: transfer restrictions are code-enforced via ERC-3643 or equivalent compliance layer. L3 Execution (mint contract with whitelist oracle) and L2 Consensus are lit. The contract is the transfer agent — enforcement is code at the application boundary.
"The investor's fund share balance — BUIDL tokens in whitelisted wallet, transfer-restricted by contract."
BUIDL tokens arrive in the investor's whitelisted wallet. Only addresses that have passed Securitize approval can hold or receive BUIDL — the transfer restriction is code-enforced in the smart contract. Investor can redeem daily at NAV via Circle atomic settlement (USDC, same-day finality). BNY Mellon custodizes the backing assets (Treasuries, repo, cash). Recordkeeping (D11) and tax reporting (D12) obligations apply. This is the most regulated path in the Issuance rail.
Resolved 5 steps across 1 chain(s). 0 threshold(s) triggered. Frameworks: Common Reporting Standard / FATCA.
Coverage notes: 5 disclosed gap(s).
Interactive 5-layer stack across issuance, holding, redemption, and transfer — comparing Circle USYC, BlackRock BUIDL, and FOBXX.
Key question: Is the mint gated by an on-chain registry (code-enforced, L3) or by an off-chain API call to the transfer agent (policy-enforced, L4/L5)?
Circle USYC
Circle as issuer + fund administrator. USYC minted natively on Arc. Accredited investor check at L4 (Circle's compliance engine). NAV from Hashnote's calculation agent, published on-chain.
BlackRock BUIDL
Securitize as transfer agent. Minted on Ethereum. Accredited check at L5 (Securitize portal, fully off-chain). NAV from BlackRock, published via Securitize.
Franklin Templeton FOBXX
Franklin Templeton as both fund manager and transfer agent. Minted on Stellar. Authorization flags at L3 (Stellar's built-in asset controls). NAV from Franklin Templeton.
Generic ERC-20 Wrapper
No fund administrator. No compliance checks. Anyone can mint if they call the contract. No NAV enforcement whatsoever.
NAV calculation, publication, and enforcement comparison across 4 tokenized fund issuers with audit trail verification.
The pattern: Circle USYC publishes NAV on-chain at L3 — the only fund where NAV enforcement is code-enforced. BlackRock BUIDL and Franklin Templeton FOBXX rely on off-chain fund administrators. The Generic ERC-20 wrapper column shows what institutional investors see when tokenization happens without compliance architecture: empty cells. The empty cells are the point.