Matrixdock STBT - STEP Application

Applicant information

Name:
Matrixdock

Address (Headquarters):
8 Kallang Avenue, 17-01/03, Aperia Tower 1, Singapore, 339509

Country:
Singapore

Website:

Primary contact:
Benjamin Stani, Ecosystem Growth Lead, Hong Kong
benjamin.stani@matrixport.com, Telegram @b_tc_21

JJ Tan, Product Manager, Singapore
jj.tan@matrixport.com Telegram @jiajingtan

Key Information

Expected Yield: Currently approximately 5.1%, subject to market conditions of T-bill and repo rates

Expected Maturity: T-bills with staggered maturity dates within 6 months maturity, repos

Underlying assets: T-bills, Repos, Cash (0-5%)

Minimum/Maximum transaction size: Minimum $100k mint, Minimum $10k redemption, No Maximum

Current AUM for product: $49.3M

Current AUM for issuer: $49.3M

Volume of transactions LTM: $803M (including deposits, redemptions, on-chain transactions)

Source of first-loss capital: Surplus of assets above STBT supply, currently approximately $100k USD, supplied by Matrixdock

Basics and background

1. How will this investment improve Arbitrum’s RWA ecosystem?

STBT is able to be bridged between Ethereum mainnet and Arbitrum One through its integration with Chainlink CCIP. By allocating part of STEP to STBT, the amount can be kept on Arbitrum chain’s TVL. It also serves as an excellent example of RWA tokens that are secured on Ethereum mainnet through minting and redeeming, but interoperable with Arbitrum to have greater transactional efficiency with cheaper gas.

Additionally, the inclusion of STBT can expand the user reach of Arbitrum’s RWA ecosystem to a larger audience, especially in the Asia Pacific region where Matrixdock has a strong presence and is well-connected to institutional clients. This will also demonstrate the composability of T-bill tokens on Arbitrum, where more protocols will be encouraged to incorporate yield-generating RWA tokens as part of their strategies or underlying collateral for DeFi operations.

2. Identify key management personnel and individual experience. Also include third parties utilized for managing assets and their qualifications.

Eva Meng, Head of RWA

As Head of RWA, Eva oversees Matrixdock, an RWA tokenization brand owned by Matrixport. Eva is passionate about bridging digital assets and traditional finance and is focused on leading the team to build cutting-edge technology in the tokenization space. Prior to Matrixport, Eva spent over 6 years in the digital asset mining industry.

Rohit Apte, Head of Trading

As Head of Trading, Rohit leads the trade desk with focus on Matrixport’s tokenized U.S. Treasury Bills (T-Bills) offering – the Short-term Treasury Bill Token (STBT). Rohit has over 18 years of experience in trading across traditional and cryptocurrency markets. Prior to venturing into crypto, Rohit was co-head of trade desk at HSBC.

Kyle Wang, Technical Lead

Dr. Wang leads Matrixport’s Blockchain research, bringing extensive experience in blockchain development. He also acts as the lead developer for SmartBCH, a sidechain of Bitcoin Cash. He held key roles at Bitmain (2016-2019) and CoinEx Chain (2019-2020). He got a Ph.D. degree in Computer Architecture from Peking University in 2009.

3. Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.

Matrixdock is a digital asset platform that provides access to Real World Assets (RWA) through tokenization. It is a brand fully owned by Matrixport, an all-in-one crypto financial service platform that offers custody, asset management, brokerage and RWA tokenization services. Matrixport currently custodies and manages approximately USD 4 billion of crypto assets. Its client base includes more than 5000+ miners, high-networth individuals, family offices, hedge funds, ventures, protocols and foundations across Asia, Europe, Australia and offshore countries. With its vast product portfolio and geographic reach, Matrixport can help bootstrap the adoption of STBT by providing support including custody, DeFi asset management products with respect to STBT, trading liquidity and lending etc.

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.

There are no conflicts of interest.

6. Insurance coverages, guarantees, and backstops

STBT currently does not have any additional insurance coverage. However, our stringent choice of trusted custodians ensures that client securities are segregated, and cannot be commingled by law. Additionally, our bankruptcy remoteness structure provides a strong safeguard of funds in the unlikely event of incidents.

7. Historical tracking error in your proposed product, or similar to that being proposed product

There is no historical tracking error between STBT and the underlying assets, as the increase in NAV is directly reflected in the increase in total STBT supply during business days. STBT is crypto-native and distributes yield during non-business days using an automated formula. The STBT supply is reconciled with the NAV of underlying assets on the next business day, ensuring the accuracy of yield.

8. Brief reason for above tracking error

Not applicable

9. Please describe any experience your firm has in working with decentralized organizational structures

Matrixdock has strong involvement in the DeFi ecosystem, and some dApps that we work with have a DAO structure such as T-protocol. We are continuously engaging with partners, many of which are in various stages of decentralization. Additionally, our Transparency Panel consists of several key industry players, some of whom had past and current experiences working in DAO structures.

10. What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?

$49.3M on 1 May 2024

Historical:

Highest TVL $123.6M on 22 Aug 2023

11. How many of these assets held are present on Arbitrum One, if any?

$10,000 by first week of May (following our recent integration with Chainlink CCIP bridge) as a start, with plans to scale up size with more partnerships

Plan design

1. 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.

Short-term Treasury Bill Token (STBT) is designed for accredited investors seeking US treasury yields with their stablecoin holdings. STBT currently yields approximately 4.8-4.9% APY on average (as of Apr 2024). Each STBT is pegged to 1 USD and backed by US treasury securities with maturities within 6 months, reverse repurchase agreements collateralized by US treasury securities and cash not exceeding 5% of NAV.

T-bills will be bought with the highest yield in tranches, laddering maturity dates such that there will be access to potential liquidity to support any redemptions without selling any T-bills.

Matrixdock will distribute yield daily through the rebase of STBT in holders token balances. The total STBT supply is equivalent to the Net Asset Value (NAV) of the underlying asset portfolio, which equates to the sum of the market value of US T-bills, Repos (overnight loans fully-backed by T-bills) and cash.

Do investors have any shareholder, investor, creditor or similar rights?

1. 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.

Please refer to the email.

2. 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. 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.)?

This orphan trust structure effectively removed the STBT entities (token issuer and asset holder) from the balance sheet of Matrixdock, and the STBT entities would not be subject to any claims from Matrixdock creditors even in the unlikely event that Matrixdock is insolvent. Given that the STBT entities are special purpose vehicles that only conduct the STBT program, these entities incur no liabilities other than those obligations toward the STBT token holders, which are the only obligations of the STBT entities. As described above, the number of STBT tokens issued will always be less than the dollar value of the underlying reserves held by the STBT entities. With these factors combined, the STBT entities are bankruptcy remote. Details of the entities can be shared via email.

Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?

Currently, Matrixdock is offering STBT as its only product.

1. 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.

The flow of funds for conversion from USDC to STBT and back can be seen in the diagram below. Since Matrixdock does not accept ARB directly for minting STBT, there will be an additional process of converting ARB to USDC, which can be done either through our own OTC desk or through other channels.

Minting STBT

  • Investor can initiate minting by depositing eligible ERC20 stablecoin on Matrixport APP, calling Minter contract(function:mint) or if through OTC, sending eligible ERC20 stablecoin to the designated official address
  • STBT issuer converts stablecoin into USD and transfer USD to custodian bank / broker account;
  • T-bill subscription completed / repo order confirmed;
  • STBT minted (up to T+4 New York banking days) and sent to the investor’s whitelisted address.

Redemption

  • Investor can initiate redemption by sending redemption calling Minter contract(function:redeem) or if through OTC, sending STBT to the designated official address;
  • Once issuer receives redemption request from investor, the settlement of T-bill / Repos will be initiated;
  • The settled USD will be converted back to ERC20 stablecoin;
  • STBT burned and the stablecoin settled to the investor’s whitelisted address.

The exact entities and their jurisdictions involved in the flow of funds can be provided by email.

2. Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.

This would depend on the holder’s jurisdiction, and users should consult their tax advisors based on their specific circumstances. Matrixdock and the STBT team will be available for any clarifications required during the process.

3. Describe the process and expected timeline for liquidation of assets, if given instructions to do so by Arbitrum governance.

Upon redeeming STBT tokens, USDC can be received by the user within 4 business days. This redemption process can be found in the cash flow diagram in the previous section.

Alternatively, if the redemption amount is within the capacity of Curve.fi STBT/3CRV pool, instant swap of STBT into other stablecoins can be executed with low slippage. This pool is currently one of the largest liquidity pools for RWA tokens.

4. 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?

STBT currently has an over-collateralization of approximately 100k USD, where the net-asset value of underlying assets is larger than the total supply of STBT. The source of capital is from Matrixdock.

5. 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.

Upon redeeming STBT tokens, USDC can usually be received by the user within 4 business days. The sale of underlying T-Bill assets can be executed within T+0 or T+1 days, and conversion of fiat USD to USDC will be processed next T+1 day. Once the USDC is received, we will be able to proceed with the trade of USDC into ARB either via our trading desk or any agreed channel.

STBT holders on Ethereum can also easily access instant liquidity with low slippage on Curve.fi by using the STBT/3CRV pool. This pool is currently one of the largest liquidity pools for RWA tokens.

6. If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.

STBT mitigates contract and operational risks through the implementation of a whitelist mechanism, time-lock contracts, and an independent real-time monitoring system, ensuring the highest level of safety and security.

In order to further prevent operational and hacking risks, Matrixdock has implemented two separated sets of monitoring systems:

A. The first system monitors the difference between the business order data and the contract activity data to detect any unauthorized minting of STBT tokens. Any suspicious activity can be immediately canceled, and emergency plans activated.

B. The second system monitors the difference between the confirmation fiat wiring amount and the contract activity data. This monitoring service is independently maintained and monitored to identify any anomaly.

The STBT minter contract only allows whitelisted wallets to call this contract directly and mint/redeem STBT. In this way, all key actions initiated through the minter contract, such as Mint, Burn, Settle, will be transparently tracked on-chain, ensuring full transparency and allowing for the tracking of all capital flows and information related to the transactions.

7. Does the product rely on any derivative product (swaps, OTC agreements)?

No, STBT does not rely on any derivative products.

8. 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

Please refer to the email.

9. Can you explain how is risk management (inv and operational) being done? Can you provide a copy of your risk management policy?

Matrixdock team strictly adheres to standard operating procedures (SOPs) for daily operations and ensures that the net asset value (NAV) of underlying assets is always no less than the total supply of STBT. These reports are uploaded on-chain daily, which allows for complete transparency and minimizes operational risks. The STBT contract has included Chainlink PoR verification logic to ensure STBT underlying reserve is greater than or equal to the total supply at all time.(Chainlink Onchain Verification )

STBT is issued under an orphan SPV structure commonly adopted in asset-backed securities issuance by traditional financial organizations, which has the highest degree of credit enhancement. In this legal set-up, Matrixdock plays the role of a service provider and Matrixdock counterparty risk is fully removed because both the token issuance/redemption and the underlying asset management are conducted from this Orphan SPV which itself is a bankruptcy-remote trust.

Operationally, the STBT minter contract provides enhanced transparency DeFi ecosystem partners where all key actions initiated through the minter contract, such as Mint, Burn, Settle, will be transparently tracked on-chain, ensuring full transparency and allowing for the tracking of all capital flows and information related to the transactions. (Minter.sol)

Performance reporting

1. What are your proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.

Currently STBT is yielding approximately 5.1% APY, which performs closely to the federal funds rate and T-bill/repo markets. The yield that is generated from underlying assets are fully and directly distributed to STBT holders (less of fees). There is no substantial difference.

2. Describe the content, format, preparation process, and cadence of performance reports. This should include proof of reserves, if appropriate. Please include a sample report.

Daily underlying asset reports are made available for download on the STBT Underlying Assets website. It is a PDF document that combines the daily statements of bank and broker statements, which represent the net-asset value of all assets backing STBT.

STBT is the first RWA tokenization project integrated with Chainlink’s PoR service, with Chainlink’s best in class real-time oracle feed, the integration ensures that STBT is sufficiently backed by US Treasury securities and verifiable 24/7. The STBT contract even included Chainlink PoR verification logic to ensure STBT underlying reserve is greater than or equal to the total supply at all time.(Chainlink Onchain Verification ) STBT PoR Feed

3. Who provides the performance reports in respect of the underlying assets?

STBT team provides a daily performance report of all underlying assets, which includes statements from our custodians, broker and bank partners. Additionally, the Chainlink Proof of Reserve serves as verification of these reports.

4. Describe any formal audit process and timing of such audits.

On a daily basis, the Chainlink Proof of Reserve feed is verified through third-party auditors for the accuracy of statements reflecting STBT’s underlying assets. Additionally, we provide financial year statements.

Pricing

Provide a copy of your standard contract, or one similar to what is being proposed here.

Terms of Use can be found on our website stbt.matrixdock.com.

Fee summary: Inclusive of the full scope of services requested. Product Fee schedule If asset based Fee calculation for our plan if asset based Annual fee if flat fee Any other fees (including redemption or minting fees)

There is a daily prorated 0.2% annual custodian fee and 0.1% annual management fee. These are automatically subtracted from the daily yield distribution that STBT holders receive.

Flat fee of 0.1% is applicable for redemptions. There is no minting fee.

Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)

Smart Contract/Architecture

1. How many audits have you had and name of auditors? Please provide a copy of reports.

STBT’s smart contract has been audited by BlockSec and Zellic.io. Audit Report

2. Is the project permissioned? If so, how are you managing user identities? Any blacklisting/whitelisting features?

Whitelist mechanism: The STBT Token can only be minted/redeemed/transferred/held solely by account-holders that have been pre-approved by Matrixdock to satisfy KYC/AML/Accredited Investor requirements.

Whiteslited users can issue a request to whitelist additional addresses via the STBT website by signing a on-chain transaction using the new address or conduct a satoshi test.

3. Is the product present on several chains? Are there any cross chain interactions?

wSTBT is present on Ethereum mainnet and Arbitrum One. Currently, there is a bridge contract between the two chains that uses Chainlink CCIP technology to execute cross-chain transfers of wSTBT.

The contracts have been audited by Blocksec. Contract address: WSTBTBridge | Address 0xC6C1706bF9b034FA8FE5591769261A8b19edeD06 | Etherscan

4. Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem

STBT has been used in various DeFi protocols in several functions, including being the underlying assets for stablecoins, yield-generating products and collateral for loans.

At Verified USD foundation, USDV stablecoin is minted using STBT as the underlying RWA token, providing yield to ecosystem participants. At T-Protocol and Term Finance, STBT has also been used in collateralized loans, enabling capital efficiency through its strong composability with lending platforms.

5. How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?

The permission framework of the STBT contract is broadly classified into three distinct roles: ControllerRole, IssuerRole, ModeratorRole. The proposal is to designate a single smart contract with a timelock function as the controller contract for all three roles. All STBT administrator activities are carried out via this controller contract, with each operation subject to two stages of proposing and executing, and the execution must conform to the delay specified by the timelock. The overall structure is as follows:

Timelock contract: There is a single external control smart contract with a timelock function as the controller contract, through which all STBT administrator activities are carried out. Each operation must go through two stages of proposing and executing, with execution conforming to the 4-hour delay specified by the timelock.

The timelock contract is the only admin, and the security of the STBT contract is normalized to the security of each role involved in the timelock controller: proposer, executor, and canceller. The canceller is one self-hosted hardware wallet that is authorized to cancel an operation scheduled during the timelock period by calling the timelock controller.

6. Is there any custom logic required for your RWA token? If so please give any details.

ERC1400 standard is split into several modular sub-standards:

  • ERC1410 defines partially fungible tokens where balances of tokens can have an associated metadata

  • ERC1594 defines transfer restrictions and core security token functionality

  • ERC1643 defines document management functionality.

  • ERC1644 defines controller operation functionality

In particular, the STBT token contract implements the ERC1594 transfer restrictions specs, and the ERC1644 controller operations specs. STBT utilizes the whitelist mechanism to determine whether transmission and reception of addresses are authorized.

Supplementary

Transparency Panel of STBT is the first in the industry to leverage on recognized third-party independent oversight to enhance greater transparency. The panel consists of reputable members from Verified USD Foundation, LayerZero Labs and Curve Finance. Panel members provide third-party verification of off-chain assets through direct view-only access of STBT’s bank and broker accounts. Monthly updates are published on the STBT website transparency page.

Should STBT be a successful inclusion to STEP, it would be possible for an appointed member of Arbitrum DAO or STEP’s program manager to potentially join the Transparency Panel.

STEP 2 APPLICATION: TABLE OF CHANGES

Topic BEFORE (STEP 1) NEW (STEP 2)
Underlying asset T-bills, Repos, Cash (0-5%) Each STBT is pegged to 1 USD and is collateralized by a combination of the following instruments:

Short term US Treasury bills (with maturities of 3 months or less)

Reverse Repurchase Agreements collateralized with US Treasuries

BlackRock USD Institutional Digital Liquidity Fund (BUIDL)
Min redemption $10,000 $5,000
Redemption time T+4 T+0: <=$500K
T+2: No cap
Deep liquidity assurance NA Over the past 12 months, Matrixdock has seamlessly processed up to $50M in redemptions within the T+2 period. 100% on-time fulfilment rate. Zero redemption delays or faults since inception.
Fees Standard terms of use can be found on our website. 0.2% custodian fee + 0.1% management fee, pro-rated daily.

These are automatically subtracted from the daily yield distribution that STBT holders receive. Flat fee of 0.1% is applicable for redemptions. There is no minting fee.
15 bps fees all inclusive. Management fees are waived. This fee is annual, prorated and charged on a daily basis. There are no minting or redemption fees.
Counterparties and legal framework NA The product is structured through a trust and asset management framework involving multiple entities across jurisdictions.

Trust: Prometheus Solutions Purpose Trust (Seychelles)

Issuer: Prometheus Solutions Ltd (Seychelles)

Custodian: Epimetheus Technologies SPC (Cayman)

Enforcer/Protector: Hamilton Services Limited (United Kingdom)

Trustee: Appleby Global Services (Seychelles)

Sourcing:
T-bill and Repos: StoneX, UBS
BUIDL: Securitize

The structure complies with Seychelles’ regulatory framework for token issuance and excludes U.S. entities or users. Matrixport, Matrixdock’s parent company, holds licenses such as TCSP (Hong Kong), MSB (U.S.), and SRO (Switzerland), enabling global compliance.
Asset reporting Matrixdock provides a daily performance report of all underlying assets, which includes statements from our custodians, broker and bank partners. Additionally, performance reports are audited by Harris & Trotter.
Impact on Arbitrum RWA STBT is able to be bridged between Ethereum mainnet and Arbitrum One through its integration with Chainlink CCIP. By allocating part of STEP to STBT, the amount can be kept on Arbitrum chain’s TVL. It also serves as an excellent example of RWA tokens that are secured on Ethereum mainnet through minting and redeeming, but interoperable with Arbitrum to have greater transactional efficiency with cheaper gas. The inclusion of STBT can expand the user reach of Arbitrum’s RWA ecosystem to a larger audience, especially in the Asia Pacific region where Matrixdock has a strong presence and is well-connected to institutional clients.

This will also demonstrate the composability of T-bill tokens on Arbitrum, where more protocols will be encouraged to incorporate yield-generating RWA tokens as part of their strategies or underlying collateral for DeFi operations.
Additionally, Matrixdock is actively expanding its suite of RWA products - most notably XAUm, its tokenized gold product. With a successful allocation, Matrixdock commits to bringing XAUm to Arbitrum’s ecosystem - unlocking new streams of TradFi liquidity seeking crypto utility and yield opportunities.
RWA utility NA STBT is designed with secure interoperability in mind, and it is already integrated into different DeFi verticals such as

DEX for swaps and liquidity provisioning ie Curve

Collateral for stablecoins ie USDV Verified USD

Collateral for borrowing/lending ie Term Finance

Multi-chain mobility ie CCIP including Ethereum and Arbitrum

[STEP 2 Application]

Applicant information

Name: Matrixdock

Address (Headquarters): 8 Kallang Avenue, 17-01/03, Aperia Tower 1, Singapore, 339509

Country: Singapore

Website: https://www.matrixdock.com/stbt

Primary contact

Name: Josh

Title: Head of BD, RWA

Country: Hong Kong

Email, Telegram, Forum, & other methods of contact:

Email: josh.ng@matrixport.com

Telegram: @mrjoshwu

Key Information

Expected Yield

Currently ~3.9% APY net (30 day average after fees, as of Mar 19 2025). Subject to T-bill and repo rate market conditions.

Expected Maturity

Only T-bills with less than or equal to six months maturities are sourced

Underlying asset

Each STBT is pegged to 1 USD and is collateralized by a combination of the following instruments

  • Short term US Treasury bills (with maturities of 3 months or less)
  • Reverse Repurchase Agreements collateralized with US Treasuries
  • BlackRock USD Institutional Digital Liquidity Fund (BUIDL)

Minimum/Maximum transaction size

Mint: Min: $100,000 USDC

Redeem: Min $5,000 USDC, no cap

Current AUM for product

$9.4M as of 19 Mar 2024 (historical high at $123.6M on 22 Aug 2023).

Current AUM for issuer

As of Mar 19 2025, Matrixdock has $9.4M in STBT TVL. Additionally, Matrixdock has $17.2M in XAUm TVL (tokenized gold).

Volume of transactions LTM

$400M in last 12 months (including deposits, redemptions and on-chain transactions)

Source of first-loss capital

Surplus of assets above STBT supply, currently approximately $100k USD, supplied by Matrixdock

Basics and background

How will this investment improve Arbitrum’s RWA ecosystem?

STBT is able to be bridged between Ethereum mainnet and Arbitrum One through its integration with Chainlink CCIP. By allocating part of STEP to STBT, the amount can be kept on Arbitrum chain’s TVL. It also serves as an excellent example of RWA tokens that are secured on Ethereum mainnet through minting and redeeming, but interoperable with Arbitrum to have greater transactional efficiency with cheaper gas. The inclusion of STBT can expand the user reach of Arbitrum’s RWA ecosystem to a larger audience, especially in the Asia Pacific region where Matrixdock has a strong presence and is well-connected to institutional clients.

This will also demonstrate the composability of T-bill tokens on Arbitrum, where more protocols will be encouraged to incorporate yield-generating RWA tokens as part of their strategies or underlying collateral for DeFi operations.

Additionally, Matrixdock is actively expanding its suite of RWA products - most notably XAUm, its tokenized gold product. With a successful allocation, Matrixdock commits to bringing more RWA products to Arbitrum’s ecosystem.

Identify key management personnel and individual experience. Also include third parties utilized for managing assets and their qualifications.

Eva Meng, Head of Matrixdock

Eva is a seasoned blockchain expert with extensive experience, having served as the Director of Bitdeer Group (NASDAQ: BTDR) and CEO of BTC.COM, a subsidiary of BIT Mining Group (NYSE: BTCM). She has played a key role in advancing blockchain infrastructure and mining technologies on a global scale.

Since 2022, Eva has been at the forefront of innovation in Real World Assets (RWA), pioneering PoR-backed tokenized treasuries and multi-chain stablecoins. Prior to Matrixdock, Eva has 10+ years of experience leading operations at top Internet and Gaming companies.

Seth Yan, Head of Strategy (Matrixdock)

Seth has extensive experiences in bridging digital currencies with real world goods and services across APAC. Previously, he was EVP leading Digital Financial Services and Innovation at a leading Consumer Internet platform in Southeast Asia. Seth holds a PhD in Information Engineering from Nanyang Technological University of Singapore.

Christopher Liu, Chief Compliance Officer and Head of Regulatory

Chris has over 20 years of experience in financial services, fintech and blockchain securities. Chris leads Matrixport Group’s global regulatory and compliance practice, notably working closely with Hong Kong and Singapore regulators to secure virtual asset licensing in both markets.

Previously, Chris was Head of Compliance at Razer (e-Money & Payments), Wallex (Payments), and led Citibank’s Asia and EMEA AML programs for its Consumer Group.

Rohit Apte, Head of Trading

As Head of Trading, Rohit leads the trade desk with focus on Matrixport’s tokenized U.S. Treasury Bills offering – the Short-term Treasury Bill Token (STBT). Rohit has over 18 years of experience in trading across TradFi and cryptocurrency markets. Prior to venturing into crypto, Rohit was APAC Co-Head of G10 rates trading at HSBC.

Dr. Kyle Wang, Technical Lead

Dr. Wang leads Matrixport’s blockchain research and engineering teams, bringing extensive experience in blockchain development. As one of Bitcoin mining and crypto’s OGs, he was CTO for SmartBCH, a sidechain of Bitcoin Cash (FDV $6.7B) - he also held key technical roles at Bitmain (2016-2019) and CoinEx Chain (2019-2020). He attained his Ph.D. in Computer Architecture from Peking University in 2009.

Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.

Matrixdock is a digital asset platform that provides access to Real World Assets (RWA) through tokenization. It is a brand fully owned by Matrixport, an all-in-one crypto financial service platform that offers custody, asset management, brokerage and RWA tokenization services. Matrixport currently custodies and manages approximately USD 4 billion of crypto assets. Its client base includes more than 5000+ miners, high-networth individuals, family offices, hedge funds, ventures, protocols and foundations across Asia, Europe, Australia and offshore countries.

With its vast product portfolio and geographic reach, Matrixport can help bootstrap the adoption of STBT by providing support including custody, DeFi asset management products with respect to STBT, trading liquidity and lending etc.

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

Describe any conflicts of interest for your entity and key personnel.

None

Insurance coverages, guarantees, and backstops

STBT currently does not have any additional insurance coverage. However, our stringent choice of trusted custodians ensures that client securities are segregated, and cannot be commingled by law.

Additionally, our bankruptcy remoteness structure provides a strong safeguard of funds in the unlikely event of incidents and creditors do not have any claims to underlying assets.

Historical tracking error in your proposed product, or similar to that being proposed

There is no historical tracking error between STBT and the underlying assets, as the increase in NAV is directly reflected in the increase in total STBT supply during business days. STBT is crypto-native and distributes yield during non-business days using an automated formula. The STBT supply is reconciled with the NAV of underlying assets on the next business day, ensuring the accuracy of yield.

Brief reason for above tracking error

Not applicable

Please describe any experience your firm has in working with decentralized organizational structures

Matrixdock has experience working with DAOs, including MakerDAO’s Grand Prix and Arbitrum’s STEP program. For example, we were recipients of Arbitrum’s LTIPP grant for USDV.

Matrixdock’s team has experience working with other DeFi protocols such as Morpho, Avalon, Curve, Kinza, Stargate and more.

What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?

$9.4M as of 19 Mar 2024 (historical high at $123.6M on 22 Aug 2023).

How many of these assets held are present on Arbitrum One, if any?

$10,000 as a start, with plans to scale up with more partnerships.

Plan design

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.

Matrixdock Short-term Treasury Bill Token (STBT) is the first tokenized T-bill token issued in Asia, designed for accredited investors seeking exposure to US treasury yields on-chain.

STBT is an ERC-1400 token that distributes yield on a daily basis through the rebase of STBT in holders token balances. STBT is pegged to 1 USD, and total STBT supply is increased to reflect increasing NAV.

Matrixdock works closely with Chainlink on three levels

  • Proof of Reserves: STBT is the market’s first tokenized treasury token adopting Chainlink’s Proof of Reserves, enforcing the number of tokens minted is always less than or equal to the underlying NAV by smart contract, assuring investor confidence on-chain.
  • Data feed: STBT NAV data is recorded publicly on-chain and verified by Chainlink’s decentralized oracle network
  • CCIP: STBT is multi-chain enabled, available on Ethereum and Arbitrum.

Product Website: https://www.matrixdock.com/stbt

Please refer to STBT Dune Dashboard for more details.

Do investors have any shareholder, investor, creditor or similar rights?

Holders of STBT tokens have a right to a debt obligation from the token issuer. Each STBT token is redeemable for an amount equivalent to one U.S. dollar, minus any applicable fees, trading losses, or transactional costs. The redemption value reflects the pro rata value of the underlying assets at the time of redemption.

When you redeem your STBT tokens, the amount you receive will be based on the value of the underlying assets at that time, after accounting for any necessary fees and costs associated with the sale of these assets. Please note that there may be additional redemption restrictions that apply.

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.

Legal Structure Schematic

The product is structured through a trust and asset management framework involving multiple entities across jurisdictions.

  • Trust: Prometheus Solutions Purpose Trust (Seychelles)
  • Issuer: Prometheus Solutions Ltd (Seychelles)
  • Custodian: Epimetheus Technologies SPC (Cayman)
  • Enforcer/Protector: Hamilton Services Limited (United Kingdom)
  • Trustee: Appleby Global Services (Seychelles)

The structure complies with Seychelles’ regulatory framework for token issuance and excludes U.S. entities or users. Matrixport, Matrixdock’s parent company, holds licenses such as TCSP (Hong Kong), MSB (U.S.), and SRO (Switzerland), enabling global compliance.

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. 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.)?

Yes - the orphan trust structure ensures STBT entities (token issuer and asset holder) are separate from Matrixdock’s balance sheet and its officers/key contributors, making them bankruptcy remote. In the event of Matrixdock’s insolvency, STBT assets remain protected from creditors.

The STBT entities operate as special purpose vehicles (SPVs) with no liabilities beyond obligations to token holders. The number of STBT tokens issued is always less than the value of the underlying reserves, ensuring robust protection for token holders. This structure isolates STBT assets from Matrixdock’s financial risks.

Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?

Matrixdock issues STBT and XAUm. The two assets are issued via separate SPV structures. There is no relationship per se between the two asset classes.

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.

Please refer to the graphic below for fund flow. Matrixdock does not accept ARB directly for minting STBT, there will be an additional process of converting ARB to USDC, which can be done either through Matrixport’s licensed OTC desk or through other channels.

Minting process

There are multiple routes for minting STBT. The user can either;

  1. Submit OTC request and send stablecoins to designated deposit address
  2. Deposit eligible ERC20 stablecoin on Matrixdock Web App
  3. Swap on STBT Curve-3pool

For large quantities ($1M+), we recommend option 1. After receiving the deposit, the STBT Issuer converts stablecoin into USD and transfers it to the Custodian’s bank / broker account. Once the T-bill order is confirmed, STBT NAV is updated, concurrently STBT is minted and sent to the user’s whitelisted wallet address.

USDT, USDC and DAI are accepted by Matrixdock.

Redemption process

Similarly, the user has multiple routes for redeeming STBT.

  1. Submit OTC request
  2. Use the swap widget on Matrixdock Web App
  3. Swap on STBT Curve-3pool

Once the Issuer receives the redemption request from the user, open T-bill / repo positions are closed and settled. After bank/broker confirmation, the settled USD is converted into eligible ERC 20 stablecoins. STBT is burned and stablecoins are transferred to the user’s whitelisted address.

Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.

STBT is subject to taxation at the user’s applicable tax rate, which depends on the user’s jurisdiction and legal setup. Primary tax consequences originate from redemption.

Users are responsible for fulfilling their tax obligations and advised to consult a tax advisor. Matrixdock may assist in connecting relevant tax advisors if needed.

Describe the process and expected timeline for liquidation of assets, if given instructions to do so by Arbitrum governance.

Matrixdock has always prioritized enhancing the user experience while adapting to the evolving needs of the DeFi community. We recognize the need for instant redemption in DeFi treasury management.

STBT supports T+0 redemption for moderate amounts (<= $500K) and T+2 for any larger amount (no cap). This marks a significant progression from our last proposal, where we proposed T+4 redemption.

Deep Liquidity Assurance

Over the past 12 months, Matrixdock has seamlessly processed up to $50M in redemptions within the T+2 period.

100% on-time fulfilment rate. Zero redemption delays or faults since inception.

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?

STBT currently has an over-collateralization of approximately 100K USD, where the net-asset value of underlying assets is larger than the total supply of STBT. The source of capital is from Matrixdock.

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.

STBT is built upon a basket of on-chain and off-chain instruments, which include

  • Short term US Treasury bills (with maturities of 3 months or less)
  • Reverse Repurchase Agreements collateralized with US Treasuries
  • BlackRock USD Institutional Digital Liquidity Fund (BUIDL)

The inclusion of on-chain assets is designed to enhance liquidity and provide added flexibility to the portfolio, complementing the stability of off-chain assets.

Up to 20% of STBT is allocated with the BlackRock USD Institutional Digital Liquidity Fund (BUIDL) to enhance redemption and subscription efficiency - supporting T+0 redemptions. With this pathway, redeemed STBT is swapped into the BlackRock USD Institutional Digital Liquidity Fund (BUIDL) on-chain then into USDC (rather than settled off-chain from T-bills).

Alternatively, Matrixdock works with its established network of relationships with liquidity providers, market makers and institutions to sell underlying T-bills, settling in USDC within T+2. Matrixdock has a proven track record of supporting significant single day redemptions of up to $50M even outside market hours.

Based on Matrixdock’s professional asset management experience, allocations are made dynamically to optimize for product yield, stability and liquidity. A small amount of cash is kept to facilitate basic liquidity needs.

Secondary liquidity

Matrixdock also supports a $580K STBT-3pool on Curve to facilitate immediate swaps.

If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.

STBT mitigates contract and operational risks through the implementation of a whitelist mechanism, time-lock contracts, and an independent real-time monitoring system, ensuring the highest level of safety and security.

In order to further prevent operational and hacking risks, Matrixdock has implemented two separated sets of monitoring systems:

A. The first system monitors the difference between the business order data and the contract activity data to detect any unauthorized minting of STBT tokens. Any suspicious activity can be immediately canceled, and emergency plans activated.

B. The second system monitors the difference between the confirmation fiat wiring amount and the contract activity data. This monitoring service is independently maintained and monitored to identify any anomaly.

The STBT minter contract only allows whitelisted wallets to call this contract directly and mint/redeem STBT. In this way, all key actions initiated through the minter contract, such as Mint, Burn, Settle, will be transparently tracked on-chain, ensuring full transparency and allowing for the tracking of all capital flows and information related to the transactions.

Does the product rely on any derivative product (swaps, OTC agreements)?

No, STBT does not rely on any derivative products.

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

The product is structured through a trust and asset management framework involving multiple entities across jurisdictions.

  • Trust: Prometheus Solutions Purpose Trust (Seychelles)
  • Issuer: Prometheus Solutions Ltd (British Virgin Islands)
  • Custodian: Epimetheus Technologies SPC (Cayman)
  • Enforcer/Protector: Hamilton Services Limited (United Kingdom)
  • Trustee: Appleby Global Services (Seychelles)
  • T-bill and repos: StoneX, UBS
  • BUIDL: Securitize

Can you explain how is risk management (inv and operational) being done? Can you provide a copy of your risk management policy?

Matrixdock team strictly adheres to standard operating procedures (SOPs) for daily operations and ensures that the net asset value (NAV) of underlying assets is always no less than the total supply of STBT. These reports are uploaded on-chain daily, which allows for complete transparency and minimizes operational risks. The STBT contract has included Chainlink PoR verification logic to ensure STBT underlying reserve is greater than or equal to the total supply at all time. (Chainlink Onchain Verification)

STBT is issued under an orphan SPV structure commonly adopted in asset-backed securities issuance by traditional financial organizations, which has the highest degree of credit enhancement. In this legal set-up, Matrixdock plays the role of a service provider and Matrixdock counterparty risk is fully removed because both the token issuance/redemption and the underlying asset management are conducted from this Orphan SPV which itself is a bankruptcy-remote trust.

Operationally, the STBT minter contract provides enhanced transparency DeFi ecosystem partners where all key actions initiated through the minter contract, such as Mint, Burn, Settle, will be transparently tracked on-chain, ensuring full transparency and allowing for the tracking of all capital flows and information related to the transactions. (Minter.sol)

Performance reporting

What are your proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.

STBT currently yields ~3.9% APY post fees, or 4.3% pre fees. Our performance tracks closely with the Federal Funds Rate with little to no deviation.

Describe the content, format, preparation process, and cadence of performance reports. This should include proof of reserves, if appropriate. Please include a sample report.

Daily underlying asset reports are made available for download on the STBT Underlying Assets website.

It is a PDF document that combines the daily statements of bank and broker statements, which represent the net-asset value of all assets backing STBT.

STBT is the first RWA tokenization project integrated with Chainlink’s PoR service, with Chainlink’s best in class real-time oracle feed, the integration ensures that STBT is sufficiently backed by US Treasury securities and verifiable 24/7. The STBT contract even included Chainlink PoR verification logic to ensure STBT underlying reserve is greater than or equal to the total supply at all times.

Who provides the performance reports in respect of the underlying assets?

Matrixdock provides a daily performance report of all underlying assets, which includes statements from our custodians, broker and bank partners. This is audited by Harris & Trotter.

Additionally, the Chainlink Proof of Reserve serves as verification of these reports.

Describe any formal audit process and timing of such audits.

On a daily basis, the Chainlink Proof of Reserve feed is verified through third-party auditors for the accuracy of statements reflecting STBT’s underlying assets. Additionally, Matrixdock provides financial year statements.

Pricing

Provide a copy of your standard contract, or one similar to what is being proposed here.

Standard terms of use can be found on our website. 35 bps custodian and management fees.

Fee summary: Inclusive of the full scope of services requested. Product Fee schedule If asset based, Fee calculation for our plan if asset based, Annual fee if flat fee. Any other fees (including redemption or minting fees)

15 bps fees all inclusive. Management fees are waived. This fee is annual, prorated and charged on a daily basis. No minting or redemption fees.

Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)

Fees are automatically subtracted from the daily yield distribution that STBT holders receive.

Smart Contract/Architecture

How many audits have you had and name of auditors? Please provide a copy of reports.

STBT’s smart contract has been audited by BlockSec (Jan 2023) and Zellic.io (Feb 2023). Audit reports can be found here.

Is the project permissioned? If so how are you managing user identities? Any blacklisting/whitelisting features?

STBT is an ERC-1400 token, designed to represent security tokens for compliant and legal transactions. To ensure regulatory compliance, the U.S. market is not open for this product.

STBT uses a whitelisting mechanism where all users must pass Matrixdock’s Accredited Investor KYC process to become eligible. Only whitelisted addresses and users can mint, redeem, transfer, and hold the STBT token. Whitelisted users can also add additional wallet addresses via the STBT website by signing an on-chain transaction or conducting a satoshi test.

Is the product present on several chains? Are there any cross chain interactions?

Yes, STBT is available on Ethereum and Arbitrum. This is enabled by Chainlink CCIP.

Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem

STBT is designed with secure interoperability in mind, and it is already integrated into different DeFi verticals such as

  • DEX for swaps and liquidity provisioning ie Curve
  • Collateral for stablecoins ie Verified USD
  • Collateral for borrowing/lending ie Term Finance
  • Multi-chain mobility ie CCIP including Ethereum and Arbitrum

How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?

Trusted roles in the STBT contract are managed through a timelock-controlled smart contract, serving as the sole administrator for ControllerRole, IssuerRole, and ModeratorRole.

All administrative actions require a two-stage process of proposal and execution, enforced by a 4-hour timelock delay to ensure security and transparency.

Is there any custom logic required for your RWA token? If so please give any details.

STBT is an ERC 1400 re-basing token. No custom logic is required. However, wrapping is required for bridging to Arbitrum.