Midas mTBILL

The legal starting point is Midas Software GmbH, not the U.S. Treasury. The 2025 base prospectus names the Berlin company as issuer of transferable blockchain certificates; mTBILL carries ISIN CH1371002986.

The certificate is denominated in dollars and has no fixed maturity. A tokenholder has contractual redemption and security rights against Midas, not a securities account in the holder’s own name at a Treasury custodian.

That distinction explains why the token can trade near a dollar while still being neither a stablecoin nor a deposit. NAV is a measuring rule for a security whose value and recovery can move.

The 2024 final terms described the Underlying as Treasury bills below three months and referenced the accumulated eight-week bill return minus 50 basis points. The same document allowed collateral to include bills, Treasury funds or ETFs, Treasury notes, other Treasury obligations and secured repo.

Midas later marketed an operating strategy involving BlackRock and Superstate. That may describe portfolio implementation at a date; it does not rewrite the holder into a shareholder of either manager or lock the legal basket to IB01 or any single fund.

The filed terms named Maerki Baumann and BNY Mellon as custodians. The assets reside in issuer collateral accounts rather than the ERC-20 contract, so proof of token supply alone cannot prove custody.

Ankura and ATG Azimut were named as security agents. They hold the security for tokenholders and can take control after notice, independent verification of default or insolvency, and the required grace process.

Liquidation is collective and procedural. An individual wallet cannot seize a particular bill, and agent fees, legal costs, timing and market price all affect what ultimately reaches holders.

Midas describes the token as permissionless on Ethereum and Base, and its registry also lists Oasis. This refers to transferability of the ERC-20; it does not abolish rules for issuing or redeeming the regulated certificate.

Primary users accept terms and pass geographic, wallet, sanctions and risk-based identity checks. The reviewed public pages describe exclusions for U.S. persons, China and sanctioned jurisdictions. They also describe a U.K. exclusion, but other official materials differ, so this review could not establish the current product-specific terms for U.K. persons. Fiat users require off-chain approval and greenlisting. Holding a transferable token does not itself confer eligibility for primary issuance or redemption.

The exit can be instant only while vault liquidity is available. Otherwise orders enter standard processing; market disruption, underlying illiquidity, screening or operational delay can change timing and price.

mTBILL does not send periodic interest. Treasury return accumulates into the value per token, which Midas describes as portfolio value divided by outstanding supply; an initial NAV around 1.0 is explicitly not a peg or floor.

The 2024 filed fee schedule deducted 0.07% on redemption and 10% of interest. It remains valuable evidence about the design, but the public legal index now lists updated 2025 final terms, making a fresh document and transaction quote necessary.

At 3 September 2026 the attestation engine reported $75.78 million gross AUM against $73.64 million TVL. The 102.91% ratio tested one snapshot; it is evidence of that checkpoint rather than insurance against tomorrow’s shortfall.

The pledge gives the security agents a route to collateral and can put proceeds ahead of unsecured claims to that property. At the same time, Section 8 subordinates all payment claims behind other non-subordinated creditors and waives enforcement whenever payment would cause illiquidity or over-indebtedness.

The holder therefore owns a hybrid risk position: secured as to an enforceable collateral pool, subordinated as to the issuer claim, and dependent on upgradeable contracts and controlled exits. Reading only “bankruptcy remote” or only “qualified subordinated” misses how recovery is actually assembled.