The holder owns the actual registered common share of the listed company — not a derivative, receipt or SPV claim.
Understand ownership →Issuer programme dossier
Opening Bell by Superstate
The holder owns the actual registered common share of the listed company — not a derivative, receipt or SPV claim.
The short answer
Any allowlisted holder with an approved Superstate account.
Understand redemption →Control is reported as observed powers, not collapsed into a score.
Understand issuer powers →SYSTEMATIC RECONCILIATION BREAK FOUND (2026-09-16, all four Solana equities compared): Superstate's public API circulating-supply exceeds the on-chain Token-2022 mint supply by exactly 0.1 shares on FWDI (api 7,280,819.200000 vs chain 7,280,819.100000) and on GLXY (api 13,399.282876 vs chain 13,399.182876), and matc…
Understand insolvency protection →Published claim ≠ observed reality
These are changes or conflicts in the outside world—not a history of edits to RWA Sonar’s own research.
Terms say the shares are unrestricted; the governing agreement and chain enforce an allowlist
Superstate’s Transfer Agent and Terms of Service Agreement states: “These shares are not subject to transfer restrictions.”
The filed Digital Transfer Agency Agreement requires tokens to be held and transferred only by allowlisted wallets or pools. All four Solana equity mints use DefaultAccountState=Frozen, and the Allowlist programme must thaw an account before it can transact.
Why it matters: A buyer cannot infer free transferability from the terms. The restriction is operationally enforced by code even though another issuer document says the opposite.
Technology + legal templates
These conclusions apply only to the exact programme and observed control recipe shown.
Current Solana assets
4 exact token addresses currently inherit this issuer-level analysis unless an asset card records an exception.
Legal claim and issuing chain
- Issuing entity
- Superstate Services LLC (Delaware LLC, 205 W 28th Street Floor 8, New York, NY 10001) acting as 'Digital Transfer Agent'; SEC Transfer Agent File No. 84-06972, registered under Section 17A(c)(2) of the Exchange Act. Shares are issued by the public company; Superstate mints the token representing its book-entry shares.
- Entity jurisdiction
- Delaware LLC, principal offices New York, NY, USA. Issuers are US-incorporated SEC reporting companies (Forward Industries, Inc. — Delaware/NY; Solana Company (HSDT) — Delaware; Exodus Movement, Inc. — Delaware; Galaxy Digital Inc. — Delaware).
- Governing law
- New York law (Superstate Transfer Agent & Terms of Service Agreement §12; Digital Transfer Agency Agreement §16.2). US federal securities law: Securities Act 1933 registration, Exchange Act 1934 §17A and Rules 17Ad-1 to 17Ad-21, Rule 17Ad-17 lost-shareholder rule. Disputes: mandatory arbitration in New York (JAMS for investor terms; AAA for the issuer agreement), class-action waiver.
- Regulatory status
- Fully regulated US path. The underlying security is registered common stock of an SEC-reporting, exchange-listed company (Nasdaq/NYSE American). Superstate Services LLC is an SEC-registered transfer agent (File No. 84-06972; TA-1 filed 2025-02-03, amended 2025-05-05 and 2026-03-25; EFFECT 2025-03-05; TA-2 filed 2026-03-26) operating as a co-/digital transfer agent alongside the issuer's Recordkeeping Transfer Agent (for FWDI: Equity Stock Transfer). Superstate Advisers LLC is a separate SEC-registered investment adviser (funds business, not Opening Bell). No exemptive relief or no-action letter located; issuers' own filings say the application of securities laws to trading tokenized shares 'remains uncertain'.
- Holder claim
- The holder owns the actual registered common share of the listed company — not a derivative, receipt or SPV claim. The Digital Transfer Agency Agreement defines 'Tokenized Shares' as 'Issuer's Book-Entry Shares represented by digital tokens recorded on the Solana blockchain', and the holder is a holder of record in their own name (Superstate maintains name, physical address and taxpayer ID per Schedule A §3.1) — there is no Superstate nominee, street-name or custodian layer. Forward Industries' 10-K: 'All issued shares, regardless of form, represent identical rights.' Schedule B of the Exodus agreement lists the in-scope security as the same class with the same CUSIP (30209R106, NYSE American) as the listed stock; Superstate's own instrument API publishes the ordinary CUSIP for each tokenized equity.
- Underlying custodian
- None interposed. The token is the share itself, held in the investor's own name and in the investor's own wallet; the Recordkeeping Transfer Agent (Equity Stock Transfer for FWDI) maintains the issuer's Master Securityholder File and an 'On chain Eligible Shares Record' that Superstate debits/credits. Superstate maintains the 'Subsidiary Securityholder Records'. Superstate's own private-key management (for its admin keys) is via Turnkey.
Redemption and holder eligibility
- Available
- Yes
- Eligibility
- Any allowlisted holder with an approved Superstate account. 'Burn to book-entry' converts tokens back to book-entry shares; those can then be DRS-transferred to a traditional brokerage and sold on Nasdaq. Available to eligible investors globally ('Global*', excluding jurisdictions subject to US sanctions); accredited-investor status is NOT required.
- Route / rails
- Send tokens to the published equity burn address on Solana (2u8YwJTykTreziHBN5QwE7Bi2SyN8M2MicCscthtph9E — the same burn address for all Solana equities), then the book-entry balance updates in the Superstate portal; a transfer authorization form plus a DRS transfer moves the shares to a broker. Note: burning equity tokens does NOT trigger a cash payout (unlike the funds) — you must sell on a DEX or move the shares to a broker to realise value.
- KYC
- Yes
- Minimum
- unknown
- Fees
- Superstate charges no processing fee for burn/transfer; the holder pays Solana network fees and any fees charged by the Recordkeeping Transfer Agent or the receiving broker-dealer (Terms §4.2, §4.3).
- Timing
- Not established
- Transfer mechanism
- program-mediated
- US persons excluded
- No
Backing, custody and insolvency
- Collateral ratio
- 1:1
- Composition
- shares
- Rehypothecation
- undisclosed
- Bankruptcy remote
- Yes
- Security interest
- No
- Verification type
- transfer-agent-register
- Verification agent
- Superstate Services LLC (SEC-registered digital transfer agent, File No. 84-06972) in coordination with the issuer's Recordkeeping Transfer Agent (Equity Stock Transfer for FWDI)
- Verification frequency
- continuous / real-time (the on-chain mint supply is the tokenized portion of the register; the public instruments API is refreshed continuously)
- Verification notes
- SYSTEMATIC RECONCILIATION BREAK FOUND (2026-09-16, all four Solana equities compared): Superstate's public API circulating-supply exceeds the on-chain Token-2022 mint supply by exactly 0.1 shares on FWDI (api 7,280,819.200000 vs chain 7,280,819.100000) and on GLXY (api 13,399.282876 vs chain 13,399.182876), and matches exactly on EXOD (60.000000) and HSDT (0). The +0.1 appears on precisely the two tickers with a DeFi integration, and the FWDI asset page exposes an 'AdminSeed-Kamino-SolMainnet-900' position worth 0.607498 notional = 0.1 share at $6.07 — so the most likely reading is an admin seed counted in the register figure but absent from the mint supply, not random drift. Superstate's own rendered FWDI asset page shows 7,280,819.10 on Solana, agreeing with the chain and disagreeing with its own API. Economically trivial (~$0.61) but structurally the point: the chain is a mirror of the register, the mirror is measurably and repeatably off, two Superstate surfaces disagree with each other, and no published reconciliation would have caught it. There are FOUR machine-readable verification surfaces, all public and unauthenticated: (1) https://api.superstate.com/v2/instruments returns, per ticker, the CUSIP, the per-chain mint address, total_supply, circulating_supply, the equity burn address and the split multiplier — verified 2026-09-16: FWDI total_supply 8,723,436.10 , circulating (tokenized) 7,280,819.20; (2) per-ticker scalar endpoints https://api.superstate.com/v1/instruments/FWDI/total-supply and /circulating-supply (plain numbers, no auth); (3) the Token-2022 mint itself via getTokenSupply — FWDI 7,280,819.100000 at slot 447531447; (4) the Allowlist program HFkKyweJDUuGer5KaCst5qZSYD5aapKaD7xzdNaoRtfA is publicly enumerable — getProgramAccounts returned 827 accounts (698 of 32 bytes, 129 of 64 bytes) on 2026-09-16, and Superstate publishes a Rust SDK (crates.io superstate-allowlist-interface) and TS SDK (@superstateinc/allowlist) to read its state. 481 Token-2022 accounts exist for the FWDI mint. What is NOT public: the register itself (holder identities, name/address/TIN), which sits in Superstate's Subsidiary Securityholder Records and the RTA's Master Securityholder File. Superstate's /v1/balances and /v2/transactions APIs require an API key scoped to your own entity; the issuer sees a private 'Issuance dashboard'. No auditor attestation, no Chainlink Proof-of-Reserve and no reconciliation report on the equities is published. Reserve-style verification is structurally unnecessary — the token is the share, not a claim on a reserve.
Corporate actions and economics
- Dividends
- cash
- Voting
- full
- Corporate actions
- Dividends: on Board declaration the issuer instructs the RTA with declaration/ex/record/payment dates and amount per share; payment is 'in cash or additional Shares (or other agreed to form, such as stablecoins, in the future), at the election of each shareholder' and Superstate coordinates with the RTA to process dividends, payments and tax forms (Digital Transfer Agency Agreement Schedule A §4). Note that FWDI, GLXY, EXOD and HSDT do not currently pay dividends, so the pathway is untested in practice. Voting/proxy: the tokenized holder is a holder of record, and Superstate 'will coordinate with the RTA to enable shareholder communication and proxy material distribution' (Schedule A §3.3); there is no on-chain voting. Splits: applied at the mint via the Token-2022 ScaledUiAmount multiplier, and exposed publicly as equity_info.current_split_multiplier in the instruments API. Lost shareholders: Superstate performs Rule 17Ad-17 services; escheat stays with the issuer/RTA (Schedule A §5).
- Pricing
- reference market: exchange-nbbo · arbitrageable: true · notes: The underlying class trades on Nasdaq, so an exchange price exists, but the TOKEN has no exchange venue. Forward Industries' own 10-K warns that 'there are no current trading venues for the tokenized shares' and holders 'may face potential illiquidity, trading volatility and/or pricing discrepancies when compared to shares of common stock which trade on Nasdaq. These discrepancies may be substantial.' Arbitrage exists but is slow and one-way-ish: conversion of tokens back to Nasdaq-tradeable book-entry shares 'could take up to multiple weeks' (10-K), which is far too slow to hold the peg intraday. Solana Company's 10-K makes the same point: 'prolonged price discrepancies between Tokenized and Traditional HSDT — especially where arbitrage is limited by operational or regulatory constraints.' Superstate publishes two Pyth feeds per equity: a Nasdaq feed (Equity.US.FWDI/USD) and a Superstate index feed used by DeFi protocols (Crypto.Index.FWDI/USD); the Direct Issuance Program prices new shares off a Pyth oracle at or below the Nasdaq/NYSE price with a configured discount, circuit breakers and slippage bounds.
Primary documents and evidence
- Digital Transfer Agency Agreement, Exodus Movement, Inc. / Superstate Services LLC, dated 2025-08-08 (EX-10.7 to EXOD 10-K) — THE definitive primary document
- Superstate Services LLC Transfer Agent and Terms of Service Agreement (Sept 2025), SEC TA File No. 84-06972
- Forward Industries 10-K FY2025 (filed 2025-12-11) — 'Our shares of common stock are available in tokenized form on the Solana blockchain' risk factor and 'Tokenization of Common Stock' note
- Solana Company (HSDT) 10-K FY2025 (filed 2026-03-31) — Digital Transfer Agency Agreement dated 2025-10-17, Tokenized HSDT risk factors
- Galaxy Digital 8-K EX-99.1, 2025-09-03 — 'Galaxy and Superstate Launch GLXY Tokenized Public Shares on Solana'; publishes the GLXY mint address
- Superstate Services LLC SEC transfer-agent registration filings (TA-1 2025-02-03, EFFECT 2025-03-05, TA-1/A 2025-05-05, TA-1/A 2026-03-25, TA-2 2026-03-26), CIK 0002054806
- Superstate docs — Smart contracts (SVM contract addresses, Token-2022 extension list, Allowlist design, SDK links, audits)
- Superstate docs — Tokenized equities (allowlist, transferring/tokenizing existing shares, DeFi, burn to book-entry)
- Superstate docs — Opening Bell (issuer onboarding, tokenizing, trading, tracking, Direct Issuance)
- Superstate docs — Direct Issuance Program (architecture, EquityToken/DIP contracts, buyTheDip, KYC providers)
- Superstate docs — Onboarding API (POST /v1/accounts/onboard/svm/add-allowlist; partners submit KYC-verified data to be added to the on-chain allowlist)
- Public, unauthenticated instruments feed — CUSIP, per-chain mint, total/circulating supply, burn address, split multiplier
- Superstate Allowlist audit — 0xMacro superstate-7
- Forward Industries / Superstate launch release, 2025-12-18 — 'not representations, they are Forward Industries' Class A Common Stock'; ex-US holders only for Kamino collateral
- FWDI public asset page — live token/book-entry split and DeFi holdings
- Superstate letter to the SEC Crypto Task Force, 2025-06-17, 'Digital Transfer Agent -- Moving Securities and Markets from Analog to Digital' — the only place the token-loss reconstitution mechanism is described (§II.f: the digital transfer agent burns the original tokens and credits new ones once lost access and identity are confirmed, modelled on UCC 8-405 at its footnote 38), and the only place Superstate states its own view that Securities Investor Protection Act protections 'should attach' — but only to a broker holding on the investor's behalf (footnote 36, citing 15 U.S.C. 78aaa), i.e. never to a self-custodied holder
- Superstate written input to the SEC Crypto Task Force, 2026-07-31, 'Tokenization; Project Crypto at One' — Superstate's own reading of what the staff has conceded: 'a transfer agent may use a blockchain as its official master securityholder file without keeping a duplicate "digital twin" off-chain', which is the premise that makes the on-chain register authoritative rather than a mirror
- SEC Division of Trading and Markets FAQ, Crypto Asset Activities and Distributed Ledger Technology — Q11 is the regulator's own statement of that position: a registered transfer agent may use DLT as its official Master Securityholder File under Exchange Act Rule 17Ad-9(b) and 'would not need to maintain a duplicate or "digital twin" of its master securityholder file exclusively off-chain', provided the records stay secure, accurate, current and producible to regulators
Open research questions (11)
- Is the FWDI/HSDT Solana equity token program the same code as the audited Superstate token programs, and has the EQUITY-specific program (and the EVM EquityToken/DIP contracts) had an independent security audit? The published 0xMacro/ChainSecurity audits cover USTB/USCC and the Allowlist; no equity-token audit was located.
- Governance of the admin keys. The Solana Allowlist upgrade authority (2ccHdavxJ3eZ4aUy39sHmykFhiKkuvtomyRLRULrwkMA) and each mint authority are on-curve, system-owned addresses with no multisig program account. Turnkey may enforce an off-chain N-of-M policy, but no threshold, quorum or timelock is disclosed anywhere. Single-key compromise would reach mint, freeze, forced-burn and allowlist writes.
- Which register wins in a dispute? The DTAA makes the RTA's off-chain Master Securityholder File authoritative and Superstate's record 'subsidiary', while the SEC-filed Galaxy 8-K says Superstate 'records legal ownership onchain in real time' and 'the registered shareholder list of Galaxy updates in real-time'. If the chain and the RTA's file disagree, no document located says which controls, or who bears the loss.
- RESOLVED for FWDI and EXOD, open for the rest: FWDI's published CUSIP 349862409 is the ordinary Nasdaq-listed common-stock CUSIP, assigned by Nasdaq when the 1-for-10 reverse split took effect 2024-06-18 (nasdaqtrader.com Equity Corporate Actions Alert #2024-287) — so no separate tokenized tranche. EXOD's 30209R106 is confirmed by Schedule B of the signed agreement. GLXY (36317J209), HSDT (42328V876) and SBET (820014405) were taken from Superstate's own API and not cross-checked against an independent CUSIP source.
- Is there a dividend precedent? DTAA Schedule A §4 sets out a full cash/shares/(future stablecoin) dividend path, but FWDI, GLXY, EXOD and HSDT do not pay dividends, so the path has never been exercised. Likewise no split has occurred (multiplier still 1), so the ScaledUiAmount corporate-action mechanism is untested in production.
- Has proxy voting actually been exercised by a tokenized holder? Schedule A §3.3 only commits Superstate to 'coordinate with the RTA to enable shareholder communication and proxy material distribution' — no record of a tokenized holder voting at a meeting was found.
- Why is HSDT (Solana Company) still at zero supply? The token was deployed 2025-11-14 and the Digital Transfer Agency Agreement is dated 2025-10-17, but the mint supply was 0 on 2026-09-16. Announced but effectively not live; treat HSDT as non-operational for grading.
- What is the real ownership dispersion? 481 Token-2022 accounts exist for the FWDI mint, but ~43% of tokenized supply (3,156,493 FWDI, $19.2M) sits in Kamino, and the public asset page shows an 'AdminSeed-Kamino' label — so the holder count overstates independent economic holders.
- Why is the public API's circulating-supply exactly 0.1 shares above the on-chain mint supply on FWDI and GLXY but exact on EXOD and HSDT? The 0.1 'AdminSeed-Kamino' position on the FWDI asset page is the likely cause, but nothing states whether that 0.1 is a real share in the register with no token, a display artefact, or an unminted placeholder — and no published reconciliation would reveal which.
- RESOLVED: the freeze-authority/permanent-delegate address 2Yq4T3mPNfjtEyTxSbRjRKqLf1pwbTasuCQrWe6QpM7x is controlled by the Allowlist program, proven on-chain rather than taken from the docs. Transaction 2hYLRFwbxU7DcMxGudfJopFdCT1txbsi4eLa8zAPo47Enp8hyPhLKK6XDbdUFtuHnWFxTuBxYoN1Z3si2dSZFbDy (blockTime 1789052737, i.e. live activity on 2026-09-16) invokes the Allowlist program HFkKyweJDUuGer5KaCst5qZSYD5aapKaD7xzdNaoRtfA, whose inner instructions are Token-2022 getAccountDataSize, System createAccount, initializeImmutableOwner, initializeAccount3 and thawAccount — i.e. the program creates the associated token account with the ImmutableOwner extension and thaws it in one shot, signing as freeze authority via that PDA. Confirms the documented design and confirms ImmutableOwner is applied at the token-account level. What remains open is only the seed derivation (common single seeds did not reproduce the address) and, separately, who controls the program's upgrade authority.
- Superstate's fee to the issuer is $1 per year (DTAA §3.1). Is the commercial arrangement documented elsewhere (equity, warrants, platform fees), and does it create an incentive misalignment for a party that also holds forced-burn authority?