BVI structured note with collateral security-agent structure

What this analysis covers

262 current token addresses across 262 underlyings inherit this analysis.

• AAONonAAON
• AAPLonAAPL
• ABBVonABBV
• ABNBonABNB
• ABTonABT
• ADBEonADBE
• AGGonAGG
• AGonAG
• AIQonAIQ
• ALABonALAB
• AMATonAMAT
• AMConAMC
• AMDonAMD
• AMZNonAMZN
• APLDonAPLD
• ARGTonARGT
• ARMonARM
• ASMLonASML
• ASTSonASTS
• AVGOonAVGO
• AXPonAXP
• BABAonBABA
• BAConBAC
• BAIonBAI
• BAonBA
• BEonBE
• BIDUonBIDU
• BILonBIL
• BINConBINC
• BKCHonBKCH
• BLCRonBLCR
• BLKonBLK
• BMNRonBMNR
• BNOonBNO
• BOTonBOT
• BOTZonBOTZ
• BRHYonBRHY
• BRTRonBRTR
• BTDRonBTDR
• BTGonBTG

222 more inherit the same template; use the app’s issuer filter for the complete mint list.

Exceptions: none recorded. An asset-specific conclusion must be shown here before it overrides the inherited template.

Traceable conclusions

Each conclusion carries its classification, exact supporting words, source authority, location, governing law, holder scope and review date. A document saying something is not the same as an independently observed outcome.

Evidence confidence

Confidence is stated per conclusion type. It is not collapsed into one score.

Complete claim chain

Possessing the token is only the first link. Each intermediary can add a separate contract, governing law and failure dependency.

Parties that can interrupt or enforce the chain

Jurisdiction and holder eligibility

A wallet may be technically able to receive a token while its owner is contractually ineligible, unable to redeem, or excluded from rights under the governing documents.

Insolvency and enforcement

Bankruptcy remote

yes

Security interest

yes

Security holder

Ankura Trust Company, LLC as Security Agent, for the benefit of the Secured Parties (tokenholders)

Recorded priority

first

Collateral ratio

1:1+buffer

Collateral composition

may-include-other

Rehypothecation

prohibited

On-loan amount disclosed

—

Segregation / trust evidence

—

Omnibus / commingling evidence

—

Perfection / priority evidence

The holder has a put option to redeem for cash/stablecoin at the tracked value, plus the benefit of a first-priority perfected security interest in the collateral held by Ankura Trust Company as Security Agent; the holder has no shareholder voting or information rights.

Custodian lien / set-off evidence

—

Who can enforce

Ankura Trust Company, LLC as Security Agent, for the benefit of the Secured Parties (tokenholders) is the recorded security holder or enforcement representative; the tokenholder depends on that agent and the operative security documents.

Holder standing

The holder owns an unsecured-in-form but collateral-secured debt claim on Ondo Global Markets (BVI) Limited — a blockchain-based tracker certificate / structured note whose redemption amount tracks the total return of the referenced share or ETF. The holder has a put option to redeem for cash/stablecoin at the tracked value, plus the benefit of a first-priority perfected security interest in the collateral held by Ankura Trust Company as Security Agent; the holder has no shareholder voting or information rights. Physical delivery of the underlying is excluded under the Sales Terms and no party may demand conversion into certificated, uncertificated or book-entry securities — with one documented exception outside the Sales Terms: authorized participants with a linked Alpaca brokerage account can redeem Ondo Stocks for the underlying securities through Alpaca's Instant Tokenization Network (ITN) on Ethereum and BNB Chain.

A contractual label such as “segregated”, “trust” or “first priority” is not treated as a court-tested insolvency result unless the dossier records that authority.

Corporate actions

Issuer or contract mediated

Dividends

reinvested

Voting

preference-passthrough

Other corporate actions

Voting: since 2026-04-28, via a Broadridge integration, tokenholders can express non-binding voting PREFERENCES to the issuer regarding the shares the issuer beneficially owns; the issuer has no legal obligation to follow them, and the holder has no shareholder voting right. Dividends are reinvested into the referenced stock net of withholding tax and expressed as an increase in the 'shares per token' multiplier; on Solana this is surfaced through the Token-2022 ScaledUiAmount extension, so the displayed balance grows rather than the price (NVDAon multiplier 1.0017152487959897, AAPLon 1.003376073740221, SPYon 1.0077209101501272, TSLAon 1.0 as read on-chain 2026-09-16). Stock splits are handled the same way. Trading is paused around ex-dividend dates (roughly 7:50-8:10pm ET the day before the ex-date) and halted for ETF distributions until the amount is known; assets enter a reduced-size 'limited' state around earnings. Halts are listed at status.ondo.finance. The issuer may replace the Underlying held as collateral, and may exercise an Issuer Call Option to terminate and redeem all (not part) of a token series after a Termination Notice.

Economic equivalence may be delivered by cash, balance adjustment or issuer calculation; it is not assumed to reproduce the underlying shareholder right.

Redemption path

Available

yes

Eligibility

Only 'Onboarded Purchasers' who have completed the issuer's full KYC and satisfy the eligibility criteria (non-US person, not a Prohibited Person, and in several jurisdictions professional/accredited-investor status). KYC is an express condition precedent to redemption, so a secondary-market buyer may hold a token it cannot redeem. Onboarding was institutional-only at the time of the Solana launch, with retail 'coming soon'.

Route

On-chain atomic mint/redeem against USDon (the platform stablecoin), with USDC atomically swapped 1:1 to/from USDon via a stablecoin swapper (users are not whitelisted for that swap by default). Requires an off-chain signed attestation (secp256k1) from the Ondo GM API quoting price and amount, submitted to the on-chain program by a whitelisted address. For an ordinary Onboarded Purchaser redemption is for cash/stablecoin only, and the Sales Terms exclude physical delivery and bar any conversion into certificated, uncertificated or book-entry securities. Separately, Alpaca's Instant Tokenization Network lets authorized participants mint from, and redeem into, the underlying securities in a linked Alpaca brokerage account on Ethereum and BNB Chain (no Ondo fee for ITN mint/redeem). Bank wire redemption not supported.

KYC

yes

Minimum

$1.00 USD to invest or redeem

Fees

Sales Terms define Purchaser Fees owed to the Issuer for issuance AND redemption of up to 0.1% of the market price of the Underlyings; no separate redemption fee is advertised in the docs, and Ondo also retains the spread between the quoted token price and the price at which it trades the underlying. Ondo charges no fee for mint/redeem through Alpaca's ITN channel. Investor pays gas. Dividends are reinvested net of 30% US withholding tax on the BVI issuer.

Timing / SLA

—

Notes

—

Source authority and precedence

The conclusion follows the highest-authority source applicable to the specific product, holder and issue. A technical capability cannot create a legal right, and marketing cannot override operative terms.

1. 1
   Mandatory law, court orders and official registers

   These can override private terms and determine legal title, perfection, insolvency priority or eligibility.

2. 2
   Product-specific final terms and operative agreements

   The document governing this product or series controls over a general description, subject to mandatory law.

3. 3
   Base prospectus and binding programme terms

   These govern the programme except where valid product-specific terms supplement or disapply them.

4. 4
   On-chain state

   Authoritative for what the program and current keys can technically do, but not by itself for legal ownership or enforceability.

5. 5
   Official operating documentation and attestations

   Evidence of process or reserves; it cannot silently enlarge rights excluded by the controlling legal documents.

6. 6
   Marketing, press and third-party descriptions

   Useful context only. A conflict is resolved in favour of the higher-authority source and remains visibly recorded.

Recorded conflicts and corrections

• holderClaim · contradicted-corrected

  CORRECTION: the dossier said the holder has 'no right ever to demand delivery of the actual shares'. That is the Sales Terms position (p. 74, p. 108, p. 111) and remains true for an ordinary Onboarded Purchaser, but Ondo documents an in-kind channel: authorized participants with a linked Alpaca brokerage account can redeem Ondo Stocks for the underlying securities on Ethereum and BNB Chain. holderClaim now says so.

  source ↗
• custodyVerification.frequency · contradicted-corrected

  CORRECTION: the dossier implied a next-day report ('due to the issuer by 4:30pm GMT on the next calendar day after the Issuer Report Day'). The full chain is longer: the Issuer's data is due on the THIRD business day after the Calculation Day, and only then is Ankura's report due by 4:30 pm GMT the next calendar day — so a publication lag of several business days is what the contract provides for, not a lapse.

  source ↗
• redemption.rails · contradicted-corrected

  CORRECTION: the dossier said redemption is 'for cash/stablecoin only — never for the underlying shares'. True of the Sales Terms put option, but Ondo's own docs describe an in-kind redemption for authorized participants on Ethereum and BNB Chain that delivers the underlying shares into a linked Alpaca account (no Ondo fee). redemption.rails now records both paths.

  source ↗
• redemption.fees · contradicted-corrected

  CORRECTION: the dossier said 'No explicit redemption fee'. The Sales Terms define a contractual Purchaser Fee of up to 0.1% of the market price of the Underlyings, owed for issuance AND redemption. The field now states the 0.1% cap alongside the retained spread.

  source ↗
• pricing.arbitrageable · contradicted-corrected

  CORRECTION of this claim's own earlier note, which recorded the Pyth sanity-check mechanism as unverified because it is absent from the docs corpus. It is documented — just not in the docs: the Solana program README states the Pyth integration in its Overview and gives the two checks (maximum deviation from the last known good price, maximum staleness) their own section, and lists 'Oracle sanity check configuration' among the administrative operations. What stands from the earlier note is the DISCREPANCY: Ondo's own docs and price API still say 'An official oracle is in development and will be documented when available' and warn against using the display feeds as an oracle, so a holder reading the documentation would conclude no oracle exists while the program they transact with validates against one. Two price layers, documented in two different places: the mint/redeem price is a signed off-chain attestation from Ondo's API, and the on-chain program checks it against Pyth.

  source ↗

Document register

“Not structured” is a visible evidence gap: a date in a title is not silently promoted into metadata.

Open questions

• What is the numeric overcollateralisation factor for 'Other Collateral' per asset type? The Sales Terms say it is defined therein and varies, but the value was not located in the public text, and the daily report gives only a pooled Asset-to-Obligation Ratio (108.02% on 2026-09-10).
• How much of the collateral is actually the underlying shares versus permitted substitutes (cash, unlisted instruments, crypto assets)? The daily report shows a large stablecoin and cash component (~$66m USDC/USDT plus ~$35m Alpaca cash) but does not label any of it as Standard vs Other Collateral for a given series.
• Why are the Ankura reports not published at https://ondo.finance/global-markets as Sales Terms s.8.1(b) requires, and is the Dropbox folder considered contractual compliance? Also: is the 2-4 business day publication lag a process issue or a change in practice?
• Will a TransferHook program be installed on the Solana mints, and if so what will it enforce? The hook authority is set and press describes hooks as the compliance mechanism, but programId is null today — installing one would silently convert unconditionalTransfers from yes to no.
• Who controls the freeze authority key 51QVCuHfL1FeNjd8BDeffCKhCcAYoULnVB3yjNhShiuK and the mint/scaled-UI/pause authority 9foMHsSDq7nMg4WPusSz9eY7tyxyukqborA8GyU5cUxD — single signer or multisig, and with what timelock? The Solana program README describes role-based access control but the on-chain authorities were not resolved to multisigs.
• The NVDAon Final Terms (11.11.2025) name Ethereum Mainnet only as the Blockchain. Have FMA-filed Final Terms been supplemented to cover the Solana issuance (Jan 2026), and does the Base Prospectus Supplement of 04.05.2026 do that?
• ANSWERED (2026-09-18): yes, published and dated, and the Solana program is covered — by three reports, none of them the Spearbit or Cyfrin ones. https://docs.ondo.finance/audits lists TEN reports under 'Ondo Stocks': February 2026 Cantina, December 2025 Zellic, two December 2025 Cantina, November 2025 Cantina, November 2025 FYEO, October 2025 Cantina, September 2025 FYEO, July 2025 Cyfrin and June 2025 Spearbit. Three carry Solana-specific reports: GM-Solana-Zellic-12-29-2025.pdf, GM-Solana-FYEO-11-05-2025.pdf and GM-Solana-FEYO-09-08-2025.pdf (the last filename misspells FYEO). The Zellic report was read for this pass: 'Ondo Global Markets Solana Application Security Assessment', dated December 29, 2025, target 'gm-solana', 94 pages, 2.4 person-weeks over 1.2 calendar weeks, program 'ondo-gm', version 77fb5bdd0d192c3e0849ed331d9c2228b5eaa202. One loose end: the repository it names, github.com/ondoprotocol/gm-solana, returns 404 from the GitHub API today, while the public github.com/ondoprotocol/global-markets-solana was created 2025-12-29 — the same date the report carries — so the audited tree and the published tree are not demonstrably the same code.
• Is there an annual audited financial statement for Ondo Global Markets (BVI) Limited? The docs promise annual independent audits 'made available to investors' but none was found published.
• Practical effect of the Prohibited-Persons clause: a secondary buyer can receive the token but 'shall have no rights under any Offering Documents'. Does the issuer track and act on this, and how would it treat a chain of transfers through an ineligible holder?
• The 2026-04-13 SEC no-action request would put the collateral security entitlements on Ethereum via Oasis Pro TA. Has the SEC responded, and would that change the OGM holder's claim?
• Broadridge voting-preference passthrough (live 2026-04-28): does it require KYC/onboarding, a minimum holding, or an Ondo account, and is it available to Solana holders? The issuer's discretion to disregard preferences is not quantified or reported on.