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RWA: Past, Present and FutureChapter 3 of 12

Anatomy of a tokenized fund: the stack and what it costs

A tokenized fund looks like one product with one fee, but it is eight separate jobs, each done by a different firm that wants to be paid. This chapter takes BUIDL apart layer by layer, names who does each job, and shows where the money goes. The short answer: the token is the cheap part, custody is the expensive part, and the arithmetic leaves room only for large funds run by firms that already own most of the machine.

What you'll learn

  • Name the eight layers of a tokenized fund and the firm that runs each one in BUIDL.
  • Tell custody of the asset from custody of the token, and explain why the second costs more.
  • Split a fund's fee by who takes what, and spot the one layer that tokenization adds.
  • Work out why a tokenized fund needs tens of millions of dollars before it pays for itself.
  • Name the three sources that subsidize the prices investors see today.
In this chapter

Eight jobs, eight firms

The idea is simple: a fund is a bundle of jobs. Someone must own the assets, someone must choose them, someone must count their value, someone must keep them safe, someone must record who owns the fund, and someone must find buyers. Tokenization changes how two of these jobs are done and leaves the rest alone.

BUIDL shows it clearly, because BlackRock rented almost everything. When the fund launched on 20 March 2024, BlackRock contributed the portfolio and the brand. BNY Mellon took custody and administration, Securitize took the shareholder register and the token, Securitize Markets took distribution, and PwC took the audit. That rent-a-stack model is what most of the institutional wave copied afterwards.

Eight jobs inside one tokenized fundEight layers from the underlying asset to distribution and DeFi. The first six sit off the chain: the Treasury bills, the British Virgin Islands fund company that owns them, BlackRock as investment manager, BNY Mellon as administrator that computes the NAV, BNY Mellon again as custodian of the bills, and Securitize as the SEC-registered transfer agent that keeps the shareholder list and issues the tokens. The last two sit on the chain: the permissioned token deployed on several blockchains, and distribution through Securitize Markets and DeFi protocols. BlackRock itself runs only the portfolio.Eight jobs inside one tokenized fundwho does each job in BUIDL, and who else does itIn BUIDL1 Underlying asset: T-bills, gold, loans · US Treasury bills1 Underlying assetT-bills, gold, loansUS Treasury bills2 Legal wrapper: fund company, SPV, trust · BVI fund company2 Legal wrapperfund company, SPV, trustBVI fund company3 Investment manager: Franklin Templeton, Ondo, Superstate · BlackRock3 Investment managerFranklin Templeton, Ondo, SuperstateBlackRock4 Administrator and NAV: fund administrators · BNY Mellon4 Administrator and NAVfund administratorsBNY Mellon5 Custodian of the asset: custody banks · BNY Mellon5 Custodian of the assetcustody banksBNY Mellon6 Transfer agent and token issuance: Franklin (Benji), Tokeny, Centrifuge · Securitize6 Transfer agent and token issuanceFranklin (Benji), Tokeny, CentrifugeSecuritize7 Token and chains: Ethereum, Solana, Stellar · permissioned token7 Token and chainsEthereum, Solana, Stellarpermissioned token8 Distribution and DeFi: Aave Horizon, Sky / Spark, wallet custodians · Securitize Markets8 Distribution and DeFiAave Horizon, Sky / Spark, wallet custodiansSecuritize Marketsoff-chain above · on-chain belowRoles per the BUIDL launch release, 20 Mar 2024; other firms named as examples
The eight layers of a tokenized fund, with the firm that does each job in BUIDL on the right and other firms that do the same job in the middle; roles as announced on 20 Mar 2024.

The table below is the map for the rest of the chapter.

Layer The job In BUIDL Others doing it
1 Underlying asset What the fund actually owns US Treasury bills and cash gold, loans, stocks
2 Legal wrapper The entity that owns the assets a British Virgin Islands fund company SPVs, trusts
3 Investment manager Chooses and manages the assets BlackRock Franklin Templeton, Ondo, Superstate
4 Administrator and NAV Keeps the books, prices the fund daily BNY Mellon independent fund administrators
5 Custodian of the asset Holds the assets apart from its own BNY Mellon custody banks
6 Transfer agent Keeps the owner list, issues tokens Securitize Franklin Templeton's Benji platform, Centrifuge
7 Token and chains The permissioned token on each blockchain eight chains, from Ethereum to Solana Stellar, Avalanche, Polygon
8 Distribution and DeFi Finds buyers, connects to DeFi Securitize Markets Aave Horizon, Sky and Spark, wallet custodians

The off-chain half: owning, managing and counting

The first five layers existed long before blockchains, and they carry every legal promise a holder has.

A legal wrapper is the entity that legally owns the assets, so that the investor owns a piece of the entity rather than the bills directly. BUIDL's wrapper is a fund company. Ondo's USDY uses a special-purpose vehicle, a company created only to hold the collateral and issue notes against it, and Paxos holds the gold behind PAXG in a trust. Chapter 4 shows why the choice decides what happens in a bankruptcy.

The manager picks the assets and takes the largest share of the fee. In a Treasury fund the job is narrow, since short government bills leave little to decide.

The administrator keeps the fund's accounts and calculates its NAV, the net asset value: everything the fund owns minus what it owes, divided by the number of shares. For BUIDL, BNY Mellon does both the administration and the custody. The NAV is a number produced off the chain, once a day, by a bank. Getting it onto the chain without delay or error is the subject of chapter 5.

The custodian holds the actual Treasury bills and may not use them as its own. The price of that job has been driven down over decades. A traditional fund custody agreement charges around 1 basis point a year on the first billion dollars, and less above that.

The on-chain half: registering, tokenizing and selling

The last three layers are where tokenization acts, and they bring one new job and one new cost.

The transfer agent keeps the official list of who owns the fund. In BUIDL, Securitize, a transfer agent registered with the SEC, mints a token for every share an investor buys and burns it on redemption. Each token can move only between wallets on an allow-list, a list of addresses whose owners have passed identity and eligibility checks. Securitize keeps that list, so every transfer checks it first.

That check has a price you can measure. On 4 September 2026 I read the gas used by ordinary transfer calls on Ethereum. A BUIDL transfer used about four times the gas of a plain USDC transfer, because it has to consult the compliance contracts before moving.

The token also brings a second kind of custody. Token custody means holding the private keys to the wallet in which the tokens sit, a separate contract with a separate firm such as Anchorage, BitGo or Fireblocks. This job is young and priced accordingly: digital custody is quoted at 10 to 60 bps of the assets held, many times the traditional rate for the same bills.

Distribution closes the stack. Securitize Markets acted as BUIDL's placement agent. The largest single buyers have been DeFi protocols. In 2025 Sky, the successor of MakerDAO, put 500 mn USD into BUIDL as part of a competition to allocate its reserves to tokenized Treasuries. Chapter 8 follows that money.

What it costs to run

No RWA infrastructure provider publishes a price list, so the cost of a stack has to be modelled from public benchmarks. One such model, for a tokenized Treasury fund with 100 mn USD of assets on one chain, comes to about 435,000 USD a year once the fund is running, an estimate built on 2026 market rates.

The surprise is where that money goes. Digital custody, priced in the model at a negotiated 25 bps, accounts for about 250,000 USD, or 57% of the total. Lawyers, auditors and the blockchain itself are small lines next to it.

Annual running cost of a tokenized Treasury fund at 100 mn USD of AUMDigital custody at a negotiated 25 bps is 250,000 USD, which is 57% of about 434,500 USD in total annual cost. The next largest lines are the fund audit and administration at 60,000 USD and the ATS listing plus market maker at 50,000 USD. Gas is 20,000 USD, the digital transfer agent 15,000 USD, custody of the underlying Treasury bills 10,000 USD at 1 bps, offering legal counsel 10,000 USD, the contract configuration audit 10,000 USD, KYC and accreditation checks 5,000 USD, tax and K-1 filings 4,000 USD, and fund maintenance 500 USD. The oracle line is zero because chains and DeFi protocols pay for it.Annual running cost of a tokenized Treasury fund at 100 mn USD of AUMUSD per year050,000100,000150,000200,000250,000Digital custody: 250,000 USD per year250,000Digital custodyFund audit and admin: 60,000 USD per yearFund audit and adminATS and market maker: 50,000 USD per yearATS and market makerGas: 20,000 USD per yearGasDigital transfer agent: 15,000 USD per yearDigital transfer agentCustody of the T-bills: 10,000 USD per yearCustody of the T-billsOffering legal counsel: 10,000 USD per yearOffering legal counselContract audit: 10,000 USD per yearContract auditKYC and accreditation: 5,000 USD per yearKYC and accreditationTax and K-1: 4,000 USD per yearTax and K-1Fund maintenance: 500 USD per year500Fund maintenanceAuthor's model on public 2026 cost benchmarks; the 25 bps custody rate is an estimate, not an invoice, 4 Sep 2026
In a modelled tokenized Treasury fund with 100 mn USD of assets, digital custody is the largest running cost by far, about 250,000 USD of roughly 434,500 USD a year; an estimate at 2026 benchmark rates, 4 Sep 2026.

One layer does get cheaper. A classic transfer agent charges per account, historically around 12 USD per open account a year, so a fund with a hundred thousand small investors pays over a million dollars a year just for its shareholder list. A digital transfer agent charges roughly the same flat fee however many holders there are. For a fund with many small investors that saving is decisive. For BUIDL, which had 89 investors on Ethereum when I read its compliance contract on 4 September 2026, it barely matters.

Who takes the fee

A basis point (bps) is one hundredth of a percentage point, so a 50 bps fee is 0.50% of the assets a year. Fund fees come out of the fund's value daily, so the investor never sees a bill, only a slightly lower yield.

A fee can be split by layer in a model. For a 500 mn USD fund charging an all-in 100 bps, built on public market rates, the manager keeps about 35 bps, distribution takes about 15, and the platform and transfer agent take about 12. Administration, compliance, custody, audit and on-chain infrastructure share most of the rest. The issuer is left with about 5 bps.

Who takes the fee in a 100 bps RWA productA modelled all-in fee of 100 basis points on a 500 mn USD fund trading on an ATS, split nine ways. The manager keeps 35 bps, distribution and placement 15, the platform and transfer agent layer 12, fund administration and NAV 10, compliance and KYC 8, custody and depositary 6, audit and legal 6, on-chain infrastructure and oracle 3, leaving the issuer 5 bps of net margin. The platform and transfer agent layer is the one that does not exist in a fund that was never tokenized.Who takes the fee in a 100 bps RWA productbps out of 100bpsAsset management: BlackRock, Franklin Templeton, Ondo · 35Asset managementBlackRock, Franklin Templeton, Ondo35Distribution and placement: broker-dealer, ATS, exchange · 15Distribution and placementbroker-dealer, ATS, exchange15Platform and transfer agent: Securitize, Tokeny, Centrifuge · 12Platform and transfer agentSecuritize, Tokeny, Centrifuge12Fund administration and NAV: fund administrator · 10Fund administration and NAVfund administrator10Compliance, KYC, reporting: in-house and vendors · 8Compliance, KYC, reportingin-house and vendors8Custody and depositary: BNY Mellon, Anchorage, EU depositary · 6Custody and depositaryBNY Mellon, Anchorage, EU depositary6Audit and legal, amortized: auditor, law firm · 6Audit and legal, amortizedauditor, law firm6On-chain infrastructure, oracle, gas: Chainlink, RedStone, the chain · 3On-chain infrastructure, oracle, gasChainlink, RedStone, the chain3Issuer net margin: the issuer, residual · 5Issuer net marginthe issuer, residual5Author's model on public 2026 cost benchmarks and Securitize SEC filings; estimate, not an invoice, 4 Sep 2026
A modelled 100 bps fee on a 500 mn USD fund splits nine ways: the manager keeps about 35 bps, the platform and transfer agent layer that a classic fund does not have takes about 12, and about 5 bps is left for the issuer; an estimate, not an invoice, 4 Sep 2026.

The platform and transfer agent line is the one layer a traditional fund does not pay for in this form. It is the direct price of being on a chain. How BlackRock actually divides BUIDL's fee among Securitize, BNY Mellon, PwC and itself is not public.

The prices investors see today are also subsidized, from three pockets.

  1. Blockchain foundations. Since 13 November 2024, BUIDL has charged 50 bps on Ethereum, Arbitrum and Optimism but 20 bps on Aptos, Avalanche and Polygon. The foundations behind those three chains pay BlackRock the difference to attract the fund.
  2. Fee waivers. Issuers switch off their own fees to gather assets. Ondo's OUSG earns Ondo no management fee while its waiver runs, because all the yield flows into the fund's value.
  3. Investors' capital. Securitize, now a public company, reported net losses of about 8 mn USD in the first quarter of 2026 and about 22 mn USD in the second, in its SEC filings of 12 August 2026.

None of the three is permanent, so today's fees are not a stable price.

Break-even: why there are no small tokenized funds

Break-even is the fund size at which fee income covers running costs. The idea is simple, but one detail matters. Some costs are fixed: legal work, audits, the transfer agent and gas cost about the same whether the fund holds 10 mn or 1 bn USD. Others are variable: custody is charged as a percentage of assets, so it grows with the fund.

Splitting the modelled budget this way gives roughly 175,000 USD of fixed cost plus about 26 bps of variable cost on every dollar, almost all of it custody. A fund charging 50 bps keeps 24 bps per dollar after those variable costs, and those 24 bps cover the fixed cost at about 73 mn USD of assets. A fund charging 15 bps never breaks even under these assumptions, because its fee is lower than its variable costs.

Where fee revenue overtakes cost, and where it never doesAnnual cost modelled as an estimated 174,500 USD that stays fixed plus 26 bps of assets, against fee revenue at 50 bps and at 15 bps. The 50 bps revenue line crosses the cost line at about 73 mn USD of assets. The 15 bps line never crosses it, because a 15 bps fee is below the 26 bps the model charges for custody, so the gap widens as assets grow.Where fee revenue overtakes cost, and where it never doesmn USD per year, against assets under management in mn USD00.511.522.5Annual cost, 174,500 USD + 26 bps: 1.47 mn USD / yearAnnual cost, 174,500 USD + 26 bpsFee revenue at 50 bps: 2.5 mn USD / yearFee revenue at 50 bpsFee revenue at 15 bps: 0.75 mn USD / yearFee revenue at 15 bps0100200300400500break-even at 50 bps, about 73 mn USD (estimate)Annual cost, 174,500 USD + 26 bpsFee revenue at 50 bpsFee revenue at 15 bpsAuthor's model on public 2026 cost benchmarks; estimate, not a reported figure, 4 Sep 2026
Modelled annual cost against fee income as a fund grows, on an estimated 174,500 USD fixed cost plus 26 bps of assets: at 50 bps income overtakes cost at about 73 mn USD, at 15 bps it never does; an estimate, 4 Sep 2026.

That arithmetic sorts the market. Tokenized Treasury funds charge between 15 and 50 bps, and a newcomer paying list prices for custody has a hard time surviving at the low end. The funds that thrive belong to firms whose custody and administration cost them far less, because they already run them at scale. BUIDL held about 2.8 bn USD on 4 September 2026, according to DefiLlama, which at up to 50 bps is up to about 14 mn USD a year of fees for a fund that runs on infrastructure its partners already own.

The scarce resource is not software either. RWA.xyz counted more than 200 tokenization platforms in September 2026. What is scarce is licences: Securitize operates through separate US entities registered as broker-dealer, trading venue operator, transfer agent and fund administrator, and those registrations take years to assemble.

What to watch next

  • Custody pricing: digital custody is the largest cost in the stack. Published or sharply negotiated rates would lower break-even for everyone and open room for smaller issuers.
  • Foundation subsidy deals: the payments that cut BUIDL's fee on some chains are commercial agreements. When they end or change, the fee on those chains should move.
  • Securitize's quarterly results: as the one pure tokenization firm that reports publicly, its split between issuance revenue and servicing revenue shows whether the platform layer can make money.
  • Incumbents taking layers in-house: a BlackRock fund filing from May 2026 names BNY Mellon, not a crypto-native firm, as transfer agent for an on-chain share class whose official register is the chain plus BNY's off-chain identity file. If large banks absorb the transfer agent layer, the independent platforms lose their core job.

Key takeaways

  1. A tokenized fund is a bundle of eight jobs done by different firms, and tokenization changes only the register and the token.
  2. BlackRock built almost nothing for BUIDL; it rented custody, administration, the register and distribution, and that rental model became the template for institutional funds.
  3. Custody of the asset and custody of the token are separate jobs, and the new one, token custody, is by far the most expensive line in the stack.
  4. The digital register is the one layer that gets clearly cheaper, which matters most for funds with many small holders.
  5. Today's low fees are partly paid by blockchain foundations, fee waivers and investors' capital, so they are not settled prices.
  6. Fixed costs plus custody charged on assets mean a fund must be large, or run by a firm that already owns the infrastructure, before it pays for itself.

Glossary

Legal wrapper
the entity, such as a fund company, SPV or trust, that legally owns the assets behind a token.
NAV
net asset value, what a fund owns minus what it owes, per share. Calculated off the chain by the administrator.
Administrator
the firm that keeps a fund's accounts and calculates its NAV. BNY Mellon does this for BUIDL.
Allow-list
the list of wallet addresses permitted to hold and receive a permissioned token.
Token custody
holding the private keys to the wallets that contain tokens, separate from holding the underlying assets.
Basis point (bps)
one hundredth of a percentage point; 50 bps is 0.50% a year.
Fixed cost
a cost that stays about the same whatever the fund's size, such as legal work or audits.
Variable cost
a cost that grows with the fund, such as custody charged as a percentage of assets.
Break-even
the fund size at which fee income covers running costs.
Fee waiver
a temporary decision by an issuer not to charge part of its fee, usually to attract assets.

Go deeper

Sources

🟢 primary · 🟡 credible secondary · 🔴 tertiary (never used to cite a number)

  • 🟢 BlackRock and Securitize, "BlackRock Launches Its First Tokenized Fund, BUIDL, on the Ethereum Network", Business Wire, 20 Mar 2024, https://www.businesswire.com/news/home/20240320771318/en/BlackRock-Launches-Its-First-Tokenized-Fund-BUIDL-on-the-Ethereum-Network
  • 🟢 PR Newswire, "BlackRock Launches New BUIDL Share Classes Across Multiple Blockchains", 13 Nov 2024: 50 bps on Ethereum, Arbitrum and Optimism, 20 bps on Aptos, Avalanche and Polygon, with the foundations paying the difference.
  • 🟢 Author's on-chain read, Ethereum mainnet, 4 Sep 2026: median gas for transfer calls on USDC, OUSG and BUIDL; BUIDL compliance contract investor count.
  • 🟢 SEC EDGAR, Securitize Holdings, Inc., Forms 8-K and 8-K/A, 12 Aug 2026: net loss for Q1 and Q2 2026.
  • 🟢 Securitize, company release, Jul 2026: the four US affiliates and their registrations.
  • 🟢 DefiLlama, BUIDL value, read 4 Sep 2026, https://defillama.com/stablecoins
  • 🟢 Ondo Finance, "Fees & Taxes" documentation for OUSG, https://docs.ondo.finance/
  • 🟡 LawInsider, Safekeeping Charges clause (Sound Shore Fund): traditional custody at 1.00 bps up to 1 bn USD and less above.
  • 🟡 LawInsider, Transfer Agent Fees clause (IDEX II Series Fund): 12.00 USD per open account per year.
  • 🟡 Digital custody market rates, 2026 custodian comparisons: 10 to 60 bps of assets under custody.
  • 🟡 Sky and Spark, "Tokenization Grand Prix" allocation, Apr to May 2025: 500 mn USD to BUIDL in the first tranche.
  • 🟡 RWA.xyz, platforms page, count of tokenization platforms, Sep 2026, https://app.rwa.xyz/
  • 🟢 SEC EDGAR, BlackRock Liquidity Funds, Form 485APOS (OnChain Shares), 8 May 2026: BNY Mellon Investment Servicing as transfer agent, https://www.sec.gov/Archives/edgar/data/97098/000119312526214958/d45978d485apos.htm

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