The firms behind tokenized funds

01 / BEHIND THE TOKEN

A digital share still depends on familiar fund services

Consider two questions: who holds a fund's investments, and who records an investor's shares? They sound similar, but they concern different assets and different responsibilities. A firm that safeguards the fund's Treasury bills is not necessarily the firm that provides a shareholder's wallet.

BUIDL's March 2024 launch announcement illustrates the distinction. It named Bank of New York Mellon as custodian of the fund's assets and fund administrator, and Securitize as transfer agent and tokenization platform. The technology and conventional fund services were described together, with separate responsibilities.¹

EXHIBIT 1

A digital share still needs a fund operating behind it

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The same distinction matters when a provider has a broad title. Circle identifies Circle International Bermuda Limited as USYC's token administrator. That is a role in managing USYC on behalf of the fund; it should not be read as a statement that the same entity provides the fund's accounting and administration.¹⁴

For a team choosing providers, the useful starting point is a short list of responsibilities: who holds the investments, who calculates and maintains the accounts, who handles ownership changes, and who runs the digital records. The next step is to identify the firm appointed to each one.

02 / THE OWNERSHIP RECORD

The token and the shareholder register are not always the same thing

Two funds can both offer blockchain-based shares while maintaining ownership records differently. That difference matters when a transfer needs correcting, records disagree or an investor needs to establish their holding.

In the reviewed Franklin Templeton staff letter, Franklin Templeton Investor Services maintains an integrated system combining book-entry and blockchain records for FOBXX. Spiko's prospectus assigns its shareholder register to Spiko Finance and describes the use of distributed ledgers. WisdomTree's regulatory information identifies an official offchain register maintained by WisdomTree Transfers, with blockchain movements reflected in that register.²¹⁶⁴

EXHIBIT 2

Three ways to maintain a fund's ownership record

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These arrangements should not be collapsed into a single label such as "onchain fund." The description may tell a reader that blockchain is involved without explaining which record the fund relies on or who can change it.

Buyers should ask how transfers reach the shareholder register, how discrepancies are resolved and which firm is responsible for an exceptional transaction. These questions are more useful than assuming a particular blockchain settles the issue.

03 / FUND STRUCTURE

A familiar asset manager does not explain every layer of a fund

A tokenized product may give investors access to another fund rather than hold the underlying investments directly. This creates an additional structure to understand, not simply another name for the same fund.

ACRED is a useful example. The January 2025 announcement describes the Apollo Diversified Credit Securitize Fund as a route into Apollo Diversified Credit Fund. It also identifies Securitize as the feeder's fund administrator and digital transfer agent. The roles should be attached to the feeder, rather than assumed from the Apollo fund beneath it.¹⁰

The reverse issue arises when several products share a structure. Our review includes four sub-funds of Spiko SICAV. Its prospectus names common providers for custody, administration, transfer agency and the shareholder register. Those four entries are not evidence of four unrelated provider appointments.¹⁶

The right question is not simply which firms are involved. It is what each firm does for this particular fund.

Public documents do not always answer every operating question on their own. In the documents selected for this review, a digital-record or token-infrastructure provider was named for 15 of the 20 products; a custodian or depositary was named for 10. This says something about the documents reviewed, not whether the other funds have those services.

EXHIBIT 3

Which providers did the reviewed documents name?

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A missing name is therefore a question to follow up, not a conclusion about the fund. The full prospectus, offering documents or a direct response from the issuer may provide the answer.

04 / CHOOSING PROVIDERS

Build the operating model before choosing the technology

For asset managers planning a tokenized fund, the review suggests a straightforward approach: establish who is accountable for each part of the fund, then assess how the technology supports that arrangement.

Tokenization can change the way shares move. It does not make these operating decisions disappear. Understanding them gives buyers a firmer basis for comparing providers and gives issuers a clearer explanation of how their fund works.