Tokenized stocks · Bullish BLSH
BLSH
Bullish ordinary shares, tokenized (Equiniti transfer agent) · Stock
What you own
- Claim depth
- rung 4 of 4 — registered share
- Legal form
- Registered share
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confirmedThese tokens are issuer-sponsored and recorded at the registry level, giving holders direct share ownership…
www.sec.gov ·Form 6-K Exhibit 99.1 furnished 2026-08-13…· read - What the holder owns
- The holder owns the actual ordinary share of the listed company. The 2026-08-12 press release furnished on…
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confirmedThe ordinary shares are issued in registered form, and are issued when registered in our register of members…
www.sec.gov ·p. 222, Description of Share Capital and…· read - Issuing entity
- Bullish (Cayman Islands company; principal executive office Office 101, 103, 105 Suite 70202, Unit 7A-2B, 2nd…
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confirmedBullish was incorporated on June 22, 2021 under the laws of the Cayman Islands (including the Companies Act…
www.sec.gov ·p. 43, Item 4.A History and Development of the…· read - Jurisdiction
- Cayman Islands (issuer, incorporation state code 'E9' in EDGAR). Transfer…
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confirmedWe are a Cayman Islands exempted company incorporated with limited liability and our affairs are governed by…
www.sec.gov ·p. 74, Item 10.B Memorandum and Articles of…· read - Governing law
- Cayman Islands companies law governs the ordinary shares and the share…
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confirmeda member registered in the register of members is deemed as a matter of the Companies Act to have legal title…
www.sec.gov ·p. 226, Description of Share Capital and…· read - Regulatory status
- Regulated US/Cayman/Gibraltar path with a documentary hole in the middle. The underlying security is the…
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confirmed"name":"Equiniti Trust Company, LLC /TA","tickers":[],"exchanges":[],"ein":"133439945","lei":null,"description…
data.sec.gov ·data.sec.gov submissions for CIK 0000005876…· read - Redemption
- yes — Registered shareholders with an EQ Shareholder Central account, and -… · rails: Bidirectional conversion between book-entry and token form via EQ's… · fees: unknown — no fee schedule for tokenization, de-tokenization or wallet…
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confirmedShareholders can withdraw, hold, and return tokens through EQ's Shareholder Central portal.
www.bullish.com ·Bullish launch release 2026-05-05, paragraph 7· readconfirmedTo withdraw BLSH tokens, all shareholders must complete identity verification requirements.
investors.bullish.com ·Investor FAQ / withdrawal process, step 2…· readconfirmedShareholders can withdraw, hold, and return tokens through EQ's Shareholder Central portal.
www.bullish.com ·Bullish launch release 2026-05-05, paragraph 7…· readunverified"unknown" is correct: no fee schedule of any kind for the tokenized form…no URL recorded ·searched: launch release, 2026-08-13 6-K…· read - Transfer restrictions
- allowlist yes · KYC to hold yes · US persons excluded no · mechanism program-mediated — Token-2022 DefaultAccountState=Frozen (verified on-chain 2026-09-16), so every newly created BLSH token account is born frozen and unusable until the freeze authority (single wallet 4Be7JXd6JaiXd6KkSMBEya5yt19gq1d11NEWTZC6Bsgk) thaws it. The issuer describes the effect exactly: 'Transfers of onchain BLSH today move bilaterally between EQ-whitelisted wallet addresses; AMM and DEX trading are not yet enabled. Any attempt to send BLSH tokens to a non-whitelisted address will fail at the smart-contract level, maintaining compliance with U.S. securities laws and anti-money-laundering rules.' Note a structural oddity: the mint carries an initialized TransferHook extension whose programId is null — the hook slot is reserved and its authority is the permanent-delegate wallet, but no hook program is set, so no per-transfer hook logic runs today. The gate is default-frozen accounts plus an off-chain-controlled freeze key, and the hook could be switched on later without redeploying the mint.
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confirmedHolders may be required to comply with transfer restrictions, investor eligibility requirements, sanctions…
investors.bullish.com ·Risk factor "The regulatory status of tokenized…· readconfirmedwill fail at the smart-contract level, maintaining compliance with U.S. securities laws and…
www.bullish.com ·Bullish launch release 2026-05-05, paragraph 6…· readconfirmedAs of December 31, 2025, 150,833,916 of our Ordinary Shares were issued and outstanding. To our knowledge…
www.sec.gov ·p. 72, Item 9 / Major Shareholders· readconfirmedtransferHook: authority DPT54eBQJf7ghEQTzX7vjAb8WaDRMJFQchX6MKm3dFcD, programId null; defaultAccountState…
no URL recorded ·rpc:getAccountInfo 6d5zakCaxjjRALNRyudC6ArivxeBG…· read - Dividends
- none
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confirmedwe have never declared or paid any cash dividends on our share capital, and we do not expect to pay dividends…
www.sec.gov ·p. 41, risk factor on holding-company structure…· read - Voting
- full
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confirmedThe holders of ordinary shares are entitled to one vote per share on all matters to be voted on by such…
www.sec.gov ·p. 222, Description of Share Capital and…· read - Ledger maturity
- Level 0 · score -4
Reference & premium
- Reference source
- ondo-implied
- Reference price
- $38.35
- Underlying market
- closed
- How the reference is derived
- marketCap / sharesOutstanding from the Ondo asset registry; no publish…
After-hours premium
No session split yet — this needs a full session of tape on both sides of the underlying market's open.
Depth, volume, activity
- Venues
- 0 DEX pair(s) · 0 exchange market(s)
Holder concentration
- Top 1 / 5 / 20, unlabelled owners only
- 100.0% / 100.0% / 100.0%
- Top 1 / 5 / 20, raw
- 100.0% / 100.0% / 100.0%
- Distinct owners in the top 20
- 20
- Frozen accounts in the top 20
- 3
- Supply
- 151,810,000.00
| Owner | Share |
|---|---|
Gcougk…4nxr | 99.98% |
Bc5bth…nXHf | 0.02% |
5MRZBA…dpgn | 0.00% |
5Gxia7…CoWP | 0.00% |
Hcq9Jt…hwwe | 0.00% |
Control surface & key governance
- Clawback
- yes
- Freeze authority
4Be7JX…Bsgk- Pausable
- yes
- Paused right now
- no
- Allowlist
- yes
- Transfer hook
- no
- Mint authority
- Hot key
§
contradicted-correctedowner 11111111111111111111111111111111, lamports 441652787, space 0, executable false
no URL recorded ·rpc:getAccountInfo 4Be7JXd6JaiXd6KkSMBEya5yt19gq…· read - Freeze authority held by
- Hot key
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confirmedfreezeAuthority: 4Be7JXd6JaiXd6KkSMBEya5yt19gq1d11NEWTZC6Bsgk; mintAuthority…
no URL recorded ·rpc:getAccountInfo 6d5zakCaxjjRALNRyudC6ArivxeBG…· read - Permanent delegate
- Hot key
§
contradicted-correctedowner 11111111111111111111111111111111, lamports 607693876, space 0, executable false
no URL recorded ·rpc:getAccountInfo DPT54eBQJf7ghEQTzX7vjAb8WaDRM…· read - Rebase authority
- Hot key
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confirmed"extension":"scaledUiAmountConfig","state":{"authority":"DPT54eBQJf7ghEQTzX7vjAb8WaDRMJFQchX6MKm3dFcD","multip…
api.mainnet-beta.solana.com ·rpc:getAccountInfo 6d5zakCaxjjRALNRyudC6ArivxeBG…· read - Evidence
- RPC getAccountInfo, 2026-09-16 (stocks/findings.md, Bullish entry): mint and freeze authority…
Verification
- Strength
- 5 of 5 — register
- Type
- Transfer agent register
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confirmedEQ maintains the official record of ownership whether shares are held in book-entry form or token form
www.bullish.com ·Bullish launch release 2026-05-05, paragraph 5· read - Agent
- Equiniti Trust Company, LLC (SEC-registered transfer agent, File No…
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confirmedThe launch is administered by Equiniti (EQ), Bullish's SEC-registered transfer agent, and was demonstrated…
www.bullish.com ·Bullish launch release 2026-05-05, opening…· read - Frequency
- claimed continuous — 'Shareholder records are maintained in real-time…
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confirmedThe register of members maintained by Bullish under applicable corporate law is the definitive record of…
investors.bullish.com ·Risk factor "Holders of tokenized ordinary…· read - Machine-readable
- no
- Evidence
- www.bullish.com/us/news-insights/bullish-tokenizes-its-shares-bringing-blsh-onchain
Venues
DEX pools
No DEX pool reported.
Exchange markets
No exchange market reported.
Trust chain
Thirteen actors stand between you and the company, and nine rights flows run between them. A lane’s colour is how well the link is evidenced and its line style is how it was verified; neither is typed by hand. An actor nobody fills keeps its seat, because an empty one is the finding.
Colour — who said so
- documented — the source’s own words, read and quoted
- inferred — our reading of the structure, not the source’s words
- asserted — written down, nobody has checked since
- unknown — nothing found for the fields this link rests on
Line — how it was checked
- onchain — read off the ledger
- attested — a third party vouches for it
- self-reported — only the issuer says so
- none — not verifiable from where we stand
Ownership of the underlyingdocumented · attested
Ownership of the underlying: Underlying company → Custodian or prime broker → Token issuer → Token program and keys → Holder. legalForm=registered-share…
legalFormconfirmedholderClaimconfirmedunderlyingCustodianconfirmedcollateral.ratioinferencecollateral.compositionconfirmed
Security interestasserted · attested
Security interest: Token issuer → Security agent or trustee → Holder. securityInterest.exists=no; securityInterest.priority=none; bankruptcyRemote=no
securityInterest.existsunverifiedsecurityInterest.holderunverifiedsecurityInterest.priorityunverifiedbankruptcyRemotecontradicted-corrected
Issuance and redemptiondocumented · self-reported
Issuance and redemption: Holder → Tokenization provider → Token issuer. redemption.available=yes; redemption.eligibility=Registered shareholders with an EQ…
redemption.availableconfirmedredemption.eligibilityconfirmedredemption.railsconfirmedredemption.feesunverifiedredemption.kycconfirmedredemption.minimumunverified
Transfer and controldocumented · onchain
Transfer and control: Holder → Token program and keys → Tokenization provider. transferRestrictions.allowlist=yes; transferRestrictions.kycToHold=yes…
transferRestrictions.allowlistconfirmedtransferRestrictions.kycToHoldconfirmedtransferRestrictions.mechanismconfirmedkeyGovernance.freezeconfirmedkeyGovernance.delegatecontradicted-correctedknownExtensionsno claim
Dividends and cash entitlementsdocumented · onchain
Dividends and cash entitlements: Underlying company → Custodian or prime broker → Token issuer → Token program and keys → Holder. dividends=none…
dividendsconfirmedcorporateActionsconfirmedkeyGovernance.rebaseconfirmed
Voting and information rightsdocumented · attested
Voting and information rights: Underlying company → Custodian or prime broker → Token issuer → Transfer agent → Holder. voting=full
votingconfirmed
Corporate actionsdocumented · onchain
Corporate actions: Underlying company → Custodian or prime broker → Token issuer → Token program and keys → Holder. corporateActions=Largely aspirational and…
corporateActionsconfirmedkeyGovernance.rebaseconfirmed
Price and reserve verificationdocumented · attested
Price and reserve verification: Reference market → Attestor or oracle → Wallet or venue → Holder. pricing.referenceMarket=exchange-nbbo…
pricing.referenceMarketconfirmedpricing.arbitrageableconfirmedcustodyVerification.typeconfirmedcustodyVerification.agentconfirmedcustodyVerification.frequencyconfirmed
Regulatory permission and disclosuredocumented · attested
Regulatory permission and disclosure: Law, regulator and courts → Token issuer → Tokenization provider → Holder. regulatoryStatus=Regulated US/Cayman/Gibraltar…
regulatoryStatusconfirmedgoverningLawconfirmedtransferRestrictions.usPersonsExcludedconfirmeddocumentsno claim
The fields behind each grade, with their values, on the issuer panel
What if…
29 documented5 inferred1 litigated3 n/a
The same 38 questions are put to every issuer, so a gap is visible as a gap. An outcome is never invented. The quote behind each answer, the cases and where we looked are on the issuer panel.
Holder
documentedMy private keys are stolen and the tokens are moved. Can they be recovered, frozen or reissued?
Bullish disclaims recovery in its own words: lost keys, a compromised wallet or a send to a wrong address may mean the tokens are "permanently lost with no…
documentedI still hold my keys but was defrauded: a fake token, a fake redemption site, a social-engineered transfer. Does the issuer or venue offer any recourse?
Before the fact you are well served and after it you are not. Bullish publishes the one canonical mint and says tokens from any other contract "are…
inferredI die. Can my heirs claim the tokens, transfer them or redeem them? Is a probate process recognised?
Nothing Bullish or EQ publishes mentions death, probate, heirs or a beneficiary designation. Structurally your estate inherits a registered share standing in…
documentedA court orders my tokens transferred, frozen or seized (divorce, judgment, bankruptcy of the holder). Can the issuer comply, and will it?
Yes, and Bullish says so in writing: it reserves the right, and may be required, to redeem or cancel your tokens, restrict transfer or block your wallet…
documentedI move to a jurisdiction where the token is not offered (for example I become a US person). Can I keep it, sell it, redeem it?
Eligibility does not stop at purchase. Bullish states it may, at its discretion or under legal compulsion, impose further transfer restrictions, freeze wallets…
documentedI am in, or become subject to, a sanctioned jurisdiction or list. Are my tokens frozen, seized, redeemable?
Sanctions screening is the gate: Bullish's own FAQ says people on OFAC or similar deny lists, and addresses flagged as sanctioned or high-risk, cannot be…
Wallet or venue
documentedThe venue or broker where I hold the tokens goes bankrupt. Are the tokens mine or the venue's estate?
On Bullish Exchange you are the beneficial owner and Bullish holds as custodian and bare trustee in segregated omnibus wallets, so the tokens are not meant to…
documentedThe venue delists the token or halts trading. Where can I sell, and can I withdraw to self-custody?
The token's only venue can drop it on broad grounds, listed in the exchange's own rules: the underlying being delisted anywhere, issuer non-compliance, an…
Token program and keys
documentedMy token account is frozen by the issuer. On what grounds can that happen, with what notice, and is there an appeal?
Frozen is the default state, not the exception: every BLSH token account is created frozen on-chain and only EQ's whitelisting thaws it, and Bullish reserves…
documentedThe issuer uses the permanent delegate or a clawback to move or burn my tokens without my signature. When may it, and what do I get?
Bullish says plainly that it may redeem or cancel tokenized shares and take other unilateral action without the consent of affected holders, and that its…
litigatedThe mint, freeze or delegate authority key is compromised or lost. Can tokens be minted without backing, frozen en masse, or seized? Is there a recovery path?
No decision exists about a compromised Solana authority key, but a regulator has already decided the register-layer version of this failure against the very…
Decided:
- In the Matter of Equiniti Trust Company, LLC f/k/a American Stock Transfer & Trust Company, LLC — U.S. Securities and Exchange Commission (administrative and cease-and-desist proceeding), Exchange Act Release No. 100780, File No. 3-22024, 2024-08-20
documentedThe token program, a transfer hook or the allowlist program has a bug or is upgraded. Who controls upgrades, and is a migration to a new mint foreseen?
Bullish discloses the whole shape of this risk: smart contracts "may contain coding errors, logic vulnerabilities, or design flaws that could be exploited to…
inferredThe multiplier or supply adjustment is set wrongly (too high, too low, late). Who corrects it, and who bears the trades made in between?
Nothing published says who corrects a wrong multiplier or who bears the trades made against it. Structurally the split authority is the same single plain…
Token issuer
documentedThe token issuer goes bankrupt. Is the underlying segregated from its estate, who enforces my claim, and roughly how long until I see anything?
There is no interposed token issuer to fail: the token is the listed company's own ordinary share, so nothing is segregated and nothing needs to be. On a…
documentedThe issuer decides to stop (as Remora did). What notice do I get, how do I redeem, and what if I miss the window?
Bullish has reserved the right to end the token form unilaterally: it may redeem or cancel tokenized ordinary shares and restrict their transfer in response to…
inferredThe issuer is acquired or its control changes (as Backed was by Kraken). Do my terms change, and can I redeem at that point?
Nothing published gives a token holder any right on a change of control, and the change that matters here is already scheduled: Bullish is acquiring Equiniti…
documentedThe backing turns out to be short (as with the SpaceX xStocks unwind). Who bears the loss, and how is it allocated among holders?
There is no reserve to fall short — the token is the share — so the equivalent failure is the chain and the register disagreeing, and Bullish has now published…
documentedI ask to redeem and the issuer refuses or delays (KYC not accepted, minimum not met, gate). What are my rights?
Conversion is gated at three points that Bullish now documents: your shares must be on EQ's register (a DRS transfer from your broker if they are not), you…
documentedThe issuer changes the terms after I bought. Can it, unilaterally? With what notice? Do I get to exit first?
The share's terms are protected in the ordinary way: the memorandum and articles can be changed only by special resolution, which needs two-thirds of the votes…
Tokenization provider
documentedThe platform operator (the tokenization provider under its services agreement) fails or terminates. Can the issuer operate without it, and can I still redeem?
There is no third-party tokenization vendor to fail — Bullish runs its own blockchain infrastructure and holds the on-chain authorities — but it discloses the…
Transfer agent
documentedThe transfer agent stops or loses its registration. Is my share still recorded, and can I convert to book-entry form?
Your share stays recorded, because the register — not the chain and not the agent's systems — is the definitive record of ownership, and Cayman statute puts…
Security agent or trustee
n/aThe security agent or trustee resigns, fails or is conflicted. Who enforces the pledge for holders?
There is no security agent, trustee or pledge in this structure, so none can fail. You own the registered ordinary share itself rather than a claim secured…
Custodian or prime broker
documentedThe custodian or prime broker holding the shares goes bankrupt. Are the shares client property, insured (SIPC or equivalent), or part of the estate?
In self-custody no custodian holds these shares at all: the token sits in your own whitelisted wallet, the share stands in your name on the register, and the…
inferredThe underlying is lent out or rehypothecated and the borrower defaults. What backs my token then?
There is no separable underlying to lend: the token is the share, the register records one class in two forms, and no document discloses any pledge, loan or…
Attestor or oracle
n/aThe proof-of-reserve or attestation is wrong, stale or stops. Who is liable, and what does the issuer do?
There is no proof-of-reserve, auditor attestation or reserve feed for onchain BLSH, and structurally none is needed — the token is the share, not a claim on a…
Underlying company
documentedThe company is acquired or merged, for cash or for shares. What do I receive, and when?
You are an ordinary shareholder of the target, so you get what the deal gives that class — but the Cayman route matters. In a statutory merger, approval needs…
documentedThe company is delisted or goes private. Does the token terminate, and at what value?
A NYSE delisting does not terminate the token — there is no maturity, valuation date or cash-out mechanism, because the token is the share — but it removes the…
documentedThe company goes bankrupt. Do I take part in the shareholder recovery, or does the token just go to zero?
You take part in the shareholder recovery exactly as any other ordinary shareholder, because it is the same share and the same register: on a winding-up…
inferredA split, reverse split, spin-off or rights issue happens. How is it mirrored on-chain, and what happens to the parts that cannot be (a spun-off share, a right)?
The mint is built for a split and has never done one: Token-2022's scaled UI amount sits at multiplier 1, so a ratio change could be applied at the mint…
documentedThe company pays a dividend and I do not receive it, or receive less than a shareholder would. Where does it go, and can I claim it?
The question has never been tested, because Bullish has never paid a dividend on its ordinary shares and does not expect to, and its own annual report puts the…
documentedWho withholds tax on dividends, at what rate, and can I reclaim under a treaty? Who reports my holding to tax authorities?
Nobody withholds at source: the Cayman Islands impose no tax on dividends or capital paid on the ordinary shares and require no withholding, and have no…
n/aFor a private company: the IPO or liquidity event happens, or never happens. What do I receive, and what if the issuer never receives proceeds?
There is no private-company case here: BLSH is a registered class of a NYSE-listed SEC-reporting company, already liquid on its primary exchange, so there is…
documentedCan I vote the shares, and if not, who does? Do I receive shareholder information?
The vote is yours in principle — one vote per ordinary share, and the tokenized form is the same class on the same register — but exercising it in tokenized…
Reference market
documentedThe reference market is closed, halted or the oracle is stale. What price applies to trading, redemption and margin?
Two prices exist and neither is guaranteed to track the other. The token trades 24/7 on Bullish Exchange, including when NYSE is closed, and the exchange's…
Law, regulator and courts
documentedA regulator acts against the issuer, the provider or a venue (licence revoked, cease-and-desist, enforcement). What happens to my holding?
Bullish frames regulatory change as a live risk to holders, warning that evolving frameworks "could materially affect the rights of holders, the value…
documentedThe law changes: the token is reclassified, banned in my jurisdiction or the issuer's exemption ends. What happens to my holding?
Bullish discloses this as the central uncertainty of the product: jurisdictions may not recognise the tokenized shares as securities at all, in which case…
documentedI have a dispute. Where do I sue or arbitrate, under which law, and can I join others (class action, collective redress)?
It depends which link you are fighting, and no document covers the token itself. A dispute about who owns the share is a register dispute: Cayman statute sends…
Solana network
documentedSolana halts or forks. What happens to a redemption request, a corporate action or a deadline that falls in the outage?
Your share survives a Solana halt; your ability to move the token does not. Bullish discloses that network failures and forks "could cause a loss of access to…
Sources
- https://investors.bullish.com/risk-factors-relating-tokenized-blsh-shares
- https://www.bullish.com/us/news-insights/bullish-tokenizes-its-shares-bringing-blsh-onchain · archived copy
- https://www.sec.gov/Archives/edgar/data/1872195/000110465925077583/tm2421409-32_424b4.htm
- https://investors.bullish.com/stock/tokenized-blsh-shares · archived copy
- https://cdn.prod.website-files.com/67e428d18ac85216b5a9d0e4/6a3a7d07b9945c427cbafc9c_Bullish%20GI%20Exchange%20Terms%20of%20Service%20(23%20…
- https://www.sec.gov/files/litigation/admin/2024/34-100780.pdf
- https://www.sec.gov/Archives/edgar/data/1872195/000143774926014727/blsh20260505_6k.htm · archived copy
- https://www.sec.gov/Archives/edgar/data/1872195/000143774926007417/blsh20251231_20f.htm · archived copy
- https://api.mainnet-beta.solana.com
Full answers, with the quotes, the notes and where we looked, on the issuer panel
Health rules
| Check | Status | Value | Thresholds | Inputs | What it says |
|---|---|---|---|---|---|
| Price tracking | not measured | — | ≤ 1 % good · ≤ 3 % caution · > 3 % warning | reference source: ondo-implied · reference price: 38.3 · age seconds: — · market open: no · usd price: — | no reference price for the underlying share, so the premium cannot be measured |
| Pool liquidity | not measured | — | ≥ $100,000 good · ≥ $10,000 caution · < $10,000 warning | liquidity usd: — · dex pairs: 0 | no venue reports liquidity |
| Organic flow | not measured | — | ≥ 10 % organic and ≤ 25 trades/trader good · one of the two fails caution · both fail warning | organic share pct: — · trades per trader: — · trades24: — | no 24 h trade count reported, so there is no flow to judge |
| Failed swaps | not measured | — | ≤ 20 % good · ≤ 50 % caution · > 50 % warning | pools: — · pools counted: 0 · signatures seen: — · failed tx: — | no swap pool was sampled for this mint |
| Holder concentration | warning | 100 | ≤ 25 % good · ≤ 50 % caution · > 50 % warning | top1 share pct excluding labels: 100 · top5 share pct excluding labels: 100 · top20 share pct excluding labels: 100 · top1 share pct: 100 · excluded: — · distinct owners top20: 20 | the largest unlabelled wallet holds 99.98 % of supply |
| Reserve verification | good | 5 | strength ≥ 3 good · strength 1–2 caution · strength 0 warning | custody type: transfer-agent-register · machine readable: no · verification label: register | verification strength 5/5 — register |
| Authority keys | caution | — | a multisig or a program good · a hot key caution | mint: hot-key · freeze: hot-key · delegate: hot-key · rebase: hot-key | mint, freeze, delegate, rebase authority held by a hot key |
| Trading pause | good | — | not paused good · paused warning | control paused: no · issuer api paused: — | not paused |
| Frozen accounts | caution | 3 | none in the top 20 good · ≥ 1 in the top 20 caution | frozen accounts top20: 3 · top20 count: 20 | 3 of the top 20 accounts are frozen |
| Venue spread | not measured | — | ≤ 2 % good · ≤ 5 % caution · > 5 % warning | venue spread pct: — · venue spread low: — · venue spread high: — · venues priced: 0 | only 0 venue prices this token, so there is no spread to measure |