Delta[1] Wellington Ultra Short Treasury On-Chain Fund (“ULTRA” or the “Fund”) STEP 2 Application
Applicant information
Name : FundBridge Capital Pte. Ltd. (“FundBridge Capital”)
Address (Headquarters) : 39 Duxton Hill Level 4, Singapore, 089617
Country: Singapore
Website: www.fundbridge.sg; dapp.deltaapp.io;
Primary Contact
Name: Sue Lynn Lim
Title: Executive Director, CEO & COO, FundBridge Capital Pte. Ltd
Country: Singapore
Email, Telegram, Forum, & other methods of contact: E: suelynn.lim@fundbridge.sg, T: (65) 6535 7888
Key Information
Expected Yield: 4.5% p.a.
Expected Maturity: N/A; open-ended fund
Underlying asset: U.S. Treasury securities, Repos and Reverse Repos, Cash reserves
Minimum/Maximum transaction size: Minimum investment: US$200,000; Maximum investment: None
Current AUM for product: US$21.21 million (as of 14 March 2025)
Current AUM for issuer: Over US$1.3 trillion (as of 31 December 2024)*
*Please note that this amount denotes the AUM of Wellington Management, the sub-manager of ULTRA. As described in greater detail in other sections of this application, the fund covered by this application, ULTRA, is the second sub-fund of the Delta Master Trust, an open-ended, umbrella unit trust designed for launching funds where the fund units are tokenised and issued using the Libeara platform.
Volume of transactions LTM: N/A, new fund
Source of first-loss capital: N/A
Basics and background
1. How will this investment improve Arbitrum’s RWA ecosystem?
The Delta Wellington Ultra Short Treasury On-Chain Fund (“ULTRA” or the “Fund”), a sub-fund of the Delta Master Trust, is a fund whereby its units are tokenised and issued via the Libeara platform. ULTRA is designed to bring investment-grade-rated tokenised assets into the Arbitrum ecosystem, backed by ultra-short-duration U.S. Treasury securities, repos, and cash reserves. These tokens represent the introduction of a highly secure and institutional-grade financial primitive in the Arbitrum ecosystem: investment-grade-rated assets. The fund units are tokenised and issued via the Libeara tokenisation platform.
While several other tokenised fund units are in the market, we understand that ULTRA currently has the highest rating in the market (as described in further details below) and we believe that the fund structure is amongst the most secure in the market due to the legal approach to structuring and the jurisdiction of issuance (Singapore). The Fund units are tokenised and issued via the Libeara tokenisation platform.
Wellington Management serves as the sub-manager of the Fund. As one of the world’s largest investment management firms with an AUM of over US$1.3 trillion, Wellington brings deep expertise in institutional asset management. The firm acts as an investment advisor to thousands of institutions globally, including central banks, sovereign institutions, pension funds, and insurance companies, further strengthening the credibility of the ULTRA Fund.
ULTRA is currently the highest rated fund in the market, with ratings of Aa from Moody’s, AA+f/S1+ from S&P, and AA+ from Particula. These favourable ratings reflect the strength of ULTRA, with its solid credit quality, lowest volatility risk, bankruptcy-remote framework, and advanced technological implementation. With institutional backing from Wellington Management and a strong legal framework in Singapore, ULTRA stands out in the evolving world of tokenised asset.
The fund units are tokenised via Libeara’s tokenisation platform, which ensures the highest levels of institutional grade compliance and technical implementation. Notably, Libeara previously partnered with FundBridge on the establishment of SGD Delta Fund, the first sub-fund of Delta Master Trust, and the ULTRA fund is a second sub-fund under the Delta Master Trust structure. The Delta Master Trust structure:
- enables the creation of separate and distinct portfolios of securities or obligation, each of which is a sub-fund; and
- has been supported by Libeara through its Delta platform to enable the issuance of tokenised units in such sub-funds through a series of smart contracts on the permissionless Ethereum blockchain (or other designated blockchain networks) to investors utilising self-custodial, unhosted wallets.
We believe the Arbitrum community will benefit greatly from the introduction of an investment-grade primitive, as well as the institutional presence of FundBridge, Wellington and Libeara and its partners in the ecosystem. This integration promotes broader adoption of real-world assets, diversifies Arbitrum’s investment opportunities, and underscores the network’s commitment to bridging traditional finance with blockchain.
2. Identify key management personnel and individual experience. Also include third parties utilized for managing assets and their qualifications.
Manager
The Manager of ULTRA, FundBridge Capital Pte. Ltd., is a company incorporated under the laws of Singapore, having its registered office at 39 Duxton Hill #04-01, Singapore 089617.
The Manager was incorporated in Singapore on 3 August 2017 and has been managing discretionary funds since 2018. The Manager is currently regulated by the MAS as a Capital Markets Services License holder to conduct the regulated activity of fund management in Singapore.
Key personnel at the Manager include:
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Sue Lynn Lim - Sue Lynn serves as FundBridge Capital’s CEO & COO responsible for the business strategy, providing oversight and management of the business, including compliance. She has over 20 years of international banking and fund management experience. Prior to FundBridge Capital, Sue Lynn spent 15 years with Standard Chartered Bank, from frontline to business strategy, where she was eventually an Executive Director in the global office. She was ultimately responsible for Portfolio Management and Sales Performance Management for teams across Asia, the Middle East and Africa.
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Bao Vu - Bao is the Investment Director at FundBridge Capital and is responsible for formulating the portfolio allocation strategy, implementation and oversight of fund structures and investment governance of the funds under management. He has over 20 years of global markets and fund management experience, a broad background across different asset classes and is a Chartered Alternative Investment Analyst (CAIA). Bao received his master’s in financial engineering from the prestigious MIT Sloan School of Management. Subsequently, he spent 2 years as an FX structurer at Deutsche Bank before rising to hold director roles across marquee banks such as UBS, Bank of America, and Citibank over the next 14 years, structuring complex deals across all asset classes. In his most recent roles, he advised institutional clients (including some sovereign wealth funds, international asset managers and family offices) on their investments into various proprietary quantitative strategies.
Sub-Manager
The Sub-Manager of the Fund, Wellington Management Singapore Pte. Ltd., is a company incorporated under the laws of Singapore, having its registered office at 8 Marina Boulevard #03-01, Singapore 018981.
The Sub-Manager was incorporated in Singapore on 29 May 2014 and has managed discretionary funds since its establishment. The MAS currently regulates the Sub-Manager as a Capital Markets Services License holder to conduct fund management activities.
Key personnel at the Sub-Manager include:
- Matthew House - Matthew serves as Wellington Management’s Managing Director and Fixed Income Portfolio Manager responsible for managing multisector, short-duration portfolios across a suite of products with customized risk and return objectives. He focuses on each client’s unique needs surrounding liquidity, preservation of capital, and yield for organizations ranging from insurance companies to foundations and corporate liquidity accounts. He also led efforts at Wellington regarding the industry’s transition away from LIBOR to SOFR. Before joining Wellington in 2016, Matthew was a fixed-income analyst and trader at Cigna, where he was responsible for the management and execution of the firm’s short-term liquidity portfolios (2012 – 2016). Before his time at Cigna, he was a senior analyst for Travelers in the Corporate Finance and Actuarial Group. Matthew earned his bachelor’s degree in finance, with a minor in management information systems, from Central Connecticut State University (2011).
Trustee
The Trustee of the Fund is Perpetual (Asia) Limited, a public limited company incorporated in Singapore whose registered office is 8 Marina Boulevard, #05-02, Marina Bay Financial Centre, Singapore 018981.
The Trustee is regulated by the MAS as a trust company licensed under the Trust Companies Act 2005 of Singapore and an approved trustee under Section 289 of the SFA.
The Trustee was incorporated in Singapore on 30 December 2005 and is ultimately owned by Perpetual Limited, which is one of the largest trustees in Australia and is listed on the Australian Securities Exchange
Custodian
The Custodian of the Fund is Standard Chartered Bank (Singapore) Limited, whose registered office address is at 8 Marina Boulevard, #27-01 Marina Bay Financial Centre, Singapore 018981.
The Custodian is regulated by the Monetary Authority of Singapore (“MAS”) and is an Exempt Capital Markets Services Entity. The Custodian is exempt from obtaining a Capital Markets Services Licence in relation to, amongst others, the provision of custodial services for securities.
Administrator
The Fund has appointed Vistra Alternative Investments (Singapore) Pte. Ltd., whose registered address is 9 Raffles Place, #26-01, Republic Plaza, Singapore 048619, as the fund administrator.
Vistra Alternative Investments (Singapore) Pte. Ltd. is part of Vistra Group, a global fund, corporate and private client services company with $395 billion in Assets Under Administration.
Tokenisation Technology Provider
The Manager has appointed Libeara (Singapore) Pte. Ltd., whose registered address is 16 Raffles Quay, #16-02, Hong Leong Building, to provide the technology for issuing and managing the tokenised fund units.
Standard Chartered Bank, a leading global banking group, owns Libeara.
Fiat On/Off-Ramp Provider
Xfers Pte. Ltd. (trading as StraitsX), the holder of a Major Payment Institution license under Singapore’s Payment Services Act 2019, is expected to provide on-ramp and off-ramp services, subject to final approval.
Registered office: 79 Ayer Rajah Crescent #04-08, Singapore 139955.
3. Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.
FundBridge has managed funds since 2018, covering a diverse range of assets, including listed equities, fixed-income instruments, private equity, venture capital, infrastructure, and private debt. FundBridge has been actively managing fixed-income portfolios—primarily corporate bonds and some sovereign bonds in separately managed accounts—since 2018.
Wellington Management is recognised for its global investment strategies across multiple asset classes and has over US$1.3 trillion assets under management.
Libeara provides an institutional-grade technology for tokenisation and fund infrastructure and its Delta platform enables seamless on-chain transactions, ensuring transparency and efficiency in fund operations. It currently has over US$ 130 million assets under tokenisation.
We are happy to provide references.
4. Has your entity or its officers/key contributors been subject to an enforcement action, criminal action or defaulted on legal or financial obligations? Please describe the circumstances if so.
No.
5. Describe any conflicts of interest for your entity and key personnel.
None.
6. Insurance coverages, guarantees, and backstops Name of insurer or guarantor Per incident coverage Aggregate coverage
FundBridge Capital has Professional Indemnity & Director and Officer insurance coverage in place.
7. Historical tracking error in your proposed product, or similar to that being proposed
As a new fund, there is no historical performance to report.
8. Brief reason for above tracking error
N/A.
9. Please describe any experience your firm has in working with decentralized organizational structures
N/A.
10. What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?
FundBridge Capital’s current assets under management (AUM) is US$350 million (including capital commitments), while Wellington Management’s current AUM is in excess of US$1.3 trillion, in each case as of December 31, 2024. As a new fund, ULTRA’s AUM is currently US$21.21 million.
Wellington Management oversees over US$1.3 trillion in client assets globally, managing investments across multiple asset classes, including fixed income, equities, and alternative strategies. The firm serves institutional investors, sovereign wealth funds, and high-net-worth clients worldwide.
Libeara Singapore, as the technology provider for tokenisation and fund infrastructure, facilitates real-time fund metrics tracking and total value locked (TVL) through blockchain-based solutions. Its platform enables seamless on-chain transactions, ensuring transparency and efficiency in fund operations. It currently has over US$ 130 million in assets under tokenisation.
11. How many of these assets held are present on Arbitrum One, if any?
None at present. However, it is intended that the Fund will be available on Arbitrum in the near future, see also our response to Question 36.
Plan Design
12. Please describe your proposed product, including a description of the underlying assets and, if more than one asset, the proposed allocation among assets and general investment guidelines. Where appropriate, include targeted maturity mix and credit quality. Attach supplementary documents as appropriate.
ULTRA is a sub-fund of the Delta Master Trust, an open-ended, umbrella unit trust designed for launching funds where the fund units are tokenised and issued using the Libeara tokenisation platform. A separate portfolio will be maintained for each sub-fund established under the Delta Master Trust, and each sub-fund will have its own investment objectives and risks.
The tokenised fund units will be issued through a series of smart contracts on the permissionless Ethereum blockchain and other blockchain(s) (e.g., Arbitrum) that ULTRA may utilise in the future. These tokens will be accessible via digital asset wallets compatible with web-based and mobile applications, with platform services provided by Libeara.
ULTRA will invest in a portfolio of U.S. Treasury securities with a tenor of less than one year. The fund seeks to maximise the portfolio’s total return by analysing the short end of the yield curve for the best risk/reward characteristics while being mindful of near-term liquidity.
The Fund may also hold repurchase agreements, reverse repurchase agreements, and cash reserves as considered appropriate by the Manager. The investment strategy focuses on preserving capital, maintaining liquidity, and providing a total return in excess the ICE BofA 3-Month Treasury Bill Index. The portfolio is managed on a total return basis.
The full details of ULTRA are available in the supplementary documents provided with this application.
13. Do investors have any shareholder, investor, creditor or similar rights?
Yes. Investors are unitholders of ULTRA and are entitled to the rights set out in the trust deed constituting theDelta Master Trust. For further details, please refer to the supplementary documents provided with this application.
14. Describe the legal and contractual structuring for your product including regulatory bodies overseeing your business and the product and identifying all legal jurisdictions interacting with your product. Attach supplementary documents as appropriate.
ULTRA is a sub-fund of the Delta Master Trust, an open-ended, umbrella unit trust designed for launching funds where the fund units are tokenised and issued using the Libeara tokenisation platform. A separate portfolio is maintained for each sub-fund established under the Delta Master Trust, and each sub-fund has its own investment objectives and risks.
ULTRA has been designed and structured in compliance with the existing financial regulations in Singapore, a leading legal and regulatory jurisdiction. The umbrella unit trust structure was chosen as the fund vehicle due to its many years of use by the industry for open-ended funds (including in the retail investor space) at scale off-chain.
Each of the Manager, Sub-Manager, Trustee, and Custodian are regulated by the Monetary Authority of Singapore (MAS) as follows:
The Manager, FundBridge Capital, is regulated by the MAS as a holder of a Capital Markets Services License to conduct the regulated activity of fund management in Singapore.
The Sub-Manager, Wellington Management Singapore, is regulated by the MAS as a holder of a Capital Markets Services License to conduct fund management activities.
The Trustee, Perpetual (Asia) Limited, is regulated by the MAS as a trust company licensed under the Trust Companies Act 2005 of Singapore and an approved trustee under Section 289 of the SFA.
The Custodian, Standard Chartered Bank, is regulated by the MAS and is an Exempt Capital Markets Services Entity. The Custodian is exempt from obtaining a Capital Markets Services Licence in relation to, amongst others, the provision of custodial services for securities.
Additionally, the Fiat On/Off-Ramp Provider, Xfers Pte. Ltd. (trading as StraitsX), is licensed under the Payment Services Act 2019 as a Major Payment Institution for, inter alia, digital payment token service.
The primary jurisdiction the product interacts with is Singapore. However, ULTRA, its Manager, and/or Trustee may need to comply with the laws, regulations, orders, guidelines, and requests of public, judicial, governmental, and other regulatory authorities in various jurisdictions, particularly relating to matters such as tax compliance, anti-money laundering, sanctions, terrorism financing, or the prevention and detection of crime.
For further details, please refer to the supplementary documents provided with this application.
15. Would Arbitrum’s assets be bankruptcy remote from your own entity and its officers/key contributors? If so, please explain the legal and contractual basis. On a confidential, non-reliance basis, provide any third party legal opinions to support the conclusions.
Yes. Pursuant to the trust deed constituting the Delta Master Trust, each sub-fund of the Delta Master Trust constitutes a trust separate and distinct from other sub-funds of the Delta Master Trust, and the assets of each sub-fund are held on trust by the Trustee for the unitholders of the relevant sub-fund. Consequently, the assets of ULTRA will be held on trust by the Trustee and will not be affected by the liquidation of the Trustee, the Manager, Libeara, or the liabilities of other sub-funds of the Delta Master Trust. In the event of the liquidation of the Trustee, the assets of ULTRA will not form part of the Trustee’s own property and will not be included in the pool of assets to be distributed to the Trustee’s creditors.
As indicated in previous responses, ULTRA has been designed and structured in compliance with the existing financial regulations in Singapore, a leading legal and regulatory jurisdiction. The umbrella unit trust structure was specifically selected as the fund vehicle of choice due to its many years of use by the industry for open-ended funds (including in the retail investor space) at scale off-chain.
Full details of ULTRA are available in the supplementary documents provided with this application.
16. How are Arbitrum’s assets protected vis-a-vis the bankruptcy of the brokerage or applicable financial institution (e.g., bank deposit insurance, securities insurance, etc.)?
Under the terms of the prime services agreement with the Custodian, the assets of ULTRA are to be segregated from the Custodian’s own assets and reflected as being owned by the Trustee (in its capacity as trustee of ULTRA). As such, the liquidation of the Custodian should not affect the assets of ULTRA, which should be assessed by the liquidators to be held on trust for the Trustee (in its capacity as trustee of ULTRA) and not be included in the pool of assets to be distributed to the Custodian’s creditors.
As a regulated entity, the Custodian is also required by applicable laws to adhere to regulations applicable to the handling of customer moneys and assets, further ensuring the protection of the Fund’s assets.
17. Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?
Each sub-fund of the Delta Master Trust is constituted by a separate and distinct trust.
18. Provide a detailed cash flow diagram that shows the flow of funds from ARB/Fiat conversion, investment in underlying asset, payment of expenses, sale of underlying asset, and repayment (Fiat/ARB conversion), including the counterparties and legal jurisdictions involved.
Onboarding
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Arbitrum submits KYC and fund onboarding documents to the Manager (FundBridge Capital).
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Following the Manager’s review and approval, Arbitrum’s wallet address is whitelisted in the Delta smart contracts.
Subscription
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Arbitrum sends USDC from its whitelisted wallet to the on/off-ramp provider via the Fund’s smart contracts, which is converted into USD and deposited into the Fund’s bank account. Alternatively, Arbitrum can wire USD fiat directly to the Fund’s bank account.
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The Administrator reviews investment requests and reconciles cash received in the Fund’s bank account. Following review, fund tokens are minted into Arbitrum’s wallet.
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On a daily basis, the Sub-Manager instructs trades to manage the fund’s portfolio and cash balances.
Redemption
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Arbitrum deposits Fund tokens into the Fund’s smart contracts, which triggers a redemption request to the Administrator.
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On a daily basis, the Sub-Manager instructs trades to manage the Fund’s portfolio and cash balances, creating liquidity to process redemptions when necessary.
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The Administrator reviews redemption requests and wires USD fiat to the on/off-ramp provider, who deposits the corresponding USDC into the Fund’s smart contract, from where it is paid to Arbitrum’s wallet. Alternatively, the Administrator can wire USD fiat directly to Arbitrum’s bank account.
All entities depicted in the flow diagrams above are located in Singapore.
19. Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.
Please refer to sections 19.12 and 19.13 of the Information Memorandum, submitted privately as part of the supplementary documentation, for a complete discussion of tax considerations.
20. Describe the process and expected timeline for liquidation of assets if given instructions to do so by Arbitrum governance.
ULTRA is an open-ended fund with tokenised units capable of being transferred peer-to-peer (P2P) between eligible parties on the Libeara platform, and Arbitrum is free to transfer or redeem its holdings at any time (subject to the Manager’s approval). The Manager offers daily redemptions on trading days, with settlement processed within 1-2 business days.
21. What amount of first-loss equity will Sponsor provide to ensure over-collateralization, how is the first-loss equity denominated, and what is the source of capital?
N/A. All Fund assets are invested in U.S. Treasury securities, repurchase agreements, reverse repurchase agreements, and cash reserves. The Fund is not a lending product and does not require first-loss equity to ensure over collateralization
22. Describe the liquidity and stability of the proposed underlying assets, including anticipated settlement times from the sale of the underlying to the repayment of ARB.
ULTRA invests in U.S. Treasury securities, ensuring high liquidity and stability. U.S. Treasury securities are among the most liquid financial instruments globally, with average daily trading volume (ADV) of $1,022.2 billion in February 2025. These securities settle on a T+1 basis.
Redemptions of Fund units can be made directly to the Manager on any trading day, with processing completed within 1-2 business days.
23. If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.
Like any technology network, blockchains are theoretically vulnerable to outages or attacks. Furthermore, risk vectors exist with respect to blockchain-based services, including wallets and smart contracts.
In issuing Fund units on blockchain, the issuer and its service providers have taken specific precautions to protect investors:
The Administrator, Vistra, maintains an off-chain copy of the Fund unitholder register, allowing for the reconstitution of investor token holdings in the event of wallet compromise or loss, smart contract corruption, or network outage.
Additionally, as experienced managers and administrators of off-chain funds in addition to the on-chain ULTRA, FundBridge Capital and Vistra have processes in place to support materialization of fund units and continuity of fund management and investor support in the event of a complete blockchain network outage.
For full details of risks associated with investment in ULTRA, please see Section 10 of the Information Memorandum, submitted privately in conjunction with this application.
24. Does the product rely on any derivative product (swaps, OTC agreements)?
No.
25. List all the third party counterparties linked to your assets including and not restricted to prime broker if any, custodian, reporting agent, banks for derivatives or loans and provide primary contact details for the third party counterparties
Trustee: Perpetual (Asia) Limited
Contact Details: Phone: +65 6908 8203; Email: contact@perpetual.com.sg
Custodian: Standard Chartered Bank (Singapore) Limited
Contact Details: Phone: +65 6876 0888; Website: www.sc.com
Administrator: Vistra Alternative Investments (Singapore) Pte. Ltd.
Contact Details: Phone: +65 6438 1330; Email: singapore@vistra.com
Manager: FundBridge Capital Pte. Ltd.
Contact Details: Phone: +65 6908 8100; Email: management@fundbridge.sg
Sub-Manager: Wellington Management Singapore Pte. Ltd.
Contact Details: Phone: +65 6534 5115; Email: info@wellington.com
26. Can you explain how is risk management (inv and operational) being done? Can you provide a copy of your risk management policy?
FundBridge maintains a Risk Management Policy Manual and Risk Management Registers on a firm-wide basis, as well as risk registers for each fund that it manages. This risk management framework covers the risks criteria/tools, frequency of monitoring as well as mitigating controls for inherent risks such as financial, investments, operations as well as legal/regulatory risks. The risk management process and internal controls are audited on a periodic basis with the audit frequency depending on the level of risk. FundBridge’s Board of Directors hold quarterly meetings and risk management, controls and compliance issues are reported to the Board.
Performance Reporting
27. What are proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.
While there is no performance benchmark, the investment objective of the Fund is to provide long-term total return in excess of the ICE BofA 3 Month Treasury Bill Index. This index aligns with the Fund’s investment strategy of holding ultra-short-duration U.S. Treasury securities while maximizing total return and maintaining liquidity.
28. Describe the content, format, preparation process, and cadence of performance reports. This should include proof of reserves, if appropriate. Please include a sample report.
Investors will be receiving monthly NAV statements as well as daily NAV prices prepared by the Administrator, Vistra.
29. Who provides the performance reports in respect of the underlying assets?
FundBridge will be providing factsheets on a monthly basis.
30. Describe any formal audit process and timing of such audits.
Financial audits are performed on an annual basis.
Pricing
31. Provide a copy of your standard contract, or one similar to what is being proposed here.
Please see Subscription Agreement provided as supplementary documentation submitted privately with this application.
32. Fee summary
A summary of the applicable fees is set out in the table below.
*Please refer to the Trust Deed for full details of the fees and charges that may be deducted out of the Deposited Property of the Sub-Fund.
In addition, the Sub-Fund shall bear all costs and expenses in relation to the establishment and continued operation of the Sub-Fund out of its assets, including but not limited to:
- all expenses properly incurred for the establishment of the Sub-Fund;
- all expenses properly incurred in connection with the offering of the Sub-Fund; and
- all operating expenses of the Sub-Fund, including any transactional expenses incurred in connection with investments and dispositions, and fees of professional (including legal and audit) advisers.
Please refer to the Trust Deed for further details on the expenses to be borne by the Sub-Fund.
33. Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)
Fees and expenses are accrued and deducted on a daily basis.
Smart Contract/Architecture
34. How many audits have you had and name of auditors? Please provide a copy of reports.
NCC Group has previously conducted a smart contract audit and is currently in the process of finalising a refreshed audit. The report will be submitted privately once issued.
35. Is the project permissioned? If so, how are you managing user identities? Any blacklisting/whitelisting features?
Yes. Investors must complete KYC/AML and onboarding with the Manager. Once onboarded, investors’ Ethereum wallet addresses are whitelisted in the smart contracts, giving onboarded users full access to investment, transfer and redemption functionalities. The whitelist remains on-chain as well. The Administrator can blacklist investors at any time, subject to the Manager’s approval.
36. Is the product present on several chains? Are there any cross-chain interactions?
ULTRA is currently available on Ethereum Mainnet. It is also intended that the Fund will be available on Arbitrum, Avalanche, and Solana, with the Arbitrum integration planned to be completed first.
Support for cross-chain interactions is not part of the near-term roadmap.
37. Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem
ULTRA is not yet used in any protocols, though we expect it to be later this year. We view ULTRA units and the subsequent tokenised fund units issued as bridges between TradFi capital and DeFi functionality, especially given our relationship with Libeara, the tokenisation platform provider, a wholly owned subsidiary of Standard Chartered Bank.
38. How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?
ULTRA is designed and structured in compliance with existing financial regulations in Singapore, a leading legal and regulatory jurisdiction. The umbrella unit trust structure was specifically selected as the fund vehicle of choice for ULTRA due to its many years of use by the industry for open-ended funds (including in the retail investor space) at scale off-chain.
The Manager, Trustee, Custodian, and the Fund’s Bank, Standard Chartered Bank (Singapore) Limited, are regulated entities in Singapore with legal and fiduciary duties to ULTRA investors. Furthermore, processes have been put in place to reconstitute token ownership and materialize tokenised fund units in the event of technical or operational necessity.
Investors trust the Manager and its delegated representative, the Administrator, to mint tokens and process redemptions. Investors trust the Fund’s Bank, Standard Chartered Bank (Singapore) Limited, and Custodian to secure the Fund’s cash and securities.
All Manager and Administrator platform access is secured by 2FA. All platform access and actions are logged and subject to audit. All on-chain activities, including minting, burning and whitelisting, require Manager’s approval using Fireblocks’ MPC App.
Internal and external audits and reviews are performed regularly to ensure compliance with operational processes and regulatory requirements.
39. Is there any custom logic required for your RWA token? If so, please give any details.
ULTRA’s token contract is built on top of the ERC-20 standard OpenZeppelin contract. The contract employs an on-chain whitelisting mechanism to restrict minting and transfers to wallet addresses owned by duly KYC-ed and onboarded investors in the Fund. The contract also maintains a “clawback” function to recover tokens from lost or compromised wallets, requiring the Manager’s approval using Fireblocks’ MPC App.
Supplementary
40. Please attach any further information or documents you feel would help the screening committee or ARB token holders make an informed decision.
The following documents are submitted privately in attachment:
- Information Memorandum
- Trust Deed
- Subscription Agreement
- Sample of Investor monthly NAV report
- Sample of ULTRA Factsheet
- Moody’s Rating Report
- Particula Ratings Report
- S&P Global Ratings Report
[1] Delta is a fund tokenisation platform powered by Libeara
[2] Calculated before the deduction of the Management Fee and Trustee’s Fee in respect of the relevant period.
[3] The Manager may vary the maximum fee payable to Libeara by giving the Holders at least one (1) month’s prior notice.
[4] Operating expenses of the Sub-Fund include any transactional expenses incurred in connection with investments and dispositions and fees of professional (including legal and audit) advisers.
[5] Until the Net Asset Value of the Sub-Fund reaches the Target Ultra Fund Size (the “Ultra Fund Support Period”), the Manager will initially bear the costs attributable to the Sub-Fund’s operating expenses incurred in the Ultra Fund Support Period, which shall be reimbursed in full by Libeara pursuant to the Co-creation Agreement. For the avoidance of doubt, the Sub-Fund will bear its full operating expenses starting from the first day after the Ultra Fund Support Period, notwithstanding the Net Asset Value of the Sub-Fund subsequently drops below the Target Ultra Fund Size.