Where the Gate Sits

5 November 2026. Figures and platform data are as of the dates stated in the text.

Interest disclosure: T-OpenAI and T-Kalshi are tokenized loan participation rights providing economic exposure linked to those companies' pre-IPO valuations, each issued through a dedicated issuing subsidiary. T-SpaceX, issued through its own dedicated issuing subsidiary, provides economic exposure linked to SpaceX; following the SpaceX listing, the investment underlying T-SpaceX is being divested. Redemption opens only once a Redemption Start Date is announced, and as of 5 November 2026 none has been. Tessera is exploring a structure of the kind this piece discusses, a permissionless token that references a permissioned fund, and is in early discussions with RWA platforms and DeFi protocols about it; none of them is named here. So Tessera has a commercial interest in the case for it. Tessera has no arrangement with Sky, Grove, Janus Henderson, Anemoy or Centrifuge. Tessera, and entities under its control, hold related exposures. Read what follows with that in mind.

The Token Chose the Gate examined a tokenized credit fund whose token came with a private-placement gate. In his LinkedIn version of that piece, on 28 October, Chan Ahn called the gate "a choice of legal route, not a property of tokens", and he set a limit on what any wrapper could do: "A wrapper can promise a faster exit than the fund only by putting a buffer or a buyer between holder and fund, which moves the mismatch rather than removing it." We still think that holds. The wrapper in question here is a different one. It is issued around a fund's token, and anyone can hold it. This piece asks what such a wrapper can do, what it costs, and when it is worth having, and our answer is narrower than we expected.

Allow-Lists Confine Direct Holding

Tokenized money-market funds rely on allow-listing of wallets to keep peer-to-peer trading of their tokens within the rules, according to the authors of a BIS Bulletin, whose views are not necessarily the BIS's. They continue: "However, such allow lists only constrain direct holding of TMMFs." (BIS Bulletin No 115, 26 November 2025.)

An allow-list has two jobs. Through the AML/CFT checks the Bulletin describes, it tells a fund who its holders are, and it enforces the fund's eligibility rules. Its reach stops at direct holding. The Bulletin describes these funds' tokens used as collateral on DeFi platforms, held by funds that invest in other such funds, and packaged "as reserve assets to back stablecoins, which are more widely accessible." Some of those intermediaries have gates of their own. Stablecoin holders have none, but they typically hold a claim at par, and the fund's return and losses stay on the issuer's balance sheet. The Bulletin counts wrapping into stablecoins as one way investors can "bypass allow-lists in practice".

Re-Plumbed, published on 27 October, put tokens like these on the side of tokenization where tokens can move. They can, within the allow-list: RWA.xyz's framework counts tokens that move between whitelisted wallets as distributed (21 November 2025). The harder case is a token that passes the fund's own return and losses to whoever holds it, with no gate behind it at all.

What a Wrapper Is and What Exists

A wrapper of this kind leaves the fund's token where it is. A holder the fund has onboarded keeps that token and issues a separate one linked to it, which can be transferred freely.

Something close to this exists, though it stops short. Grove, a Sky Prime Agent (Grove documentation, read 28 October 2026), said in July 2025 that a wholly owned subsidiary would subscribe to the Janus Henderson Anemoy AAA CLO Fund, JAAA (Sky forum, 16 July 2025). Its legal overview says: "Transfers are permitted only between whitelisted wallets." That leaves a gated token sitting inside another protocol.

Two direct wrappers of these funds do exist, one of JAAA and one of the Treasury fund JTRSY, within a family of at least five tokens on the same note series. RWA.xyz lists deJTRSY and deJAAA as offered by Centrifuge, which also offers the fund tokens. It labels them "Issuer-Sponsored", a field it defines by whether a security is tokenized by or on behalf of its issuer or by an unaffiliated third party. That is the split Going Public by Degrees, first published on 29 July (republished here on 30 July), drew for a company's own shares. Here the label appears to treat the note's issuer as the issuer of its own token, so it says nothing about the fund's sponsor and is no evidence of approval. RWA.xyz describes deJTRSY as "a freely transferable, fully onchain wrapper of JTRSY, composable across DeFi use cases such as trading on DEXes and integrating with lending markets."

JTRSY stands at $114.0 million across 32 holder addresses and deJTRSY at $22.1 million across 300. JAAA stands at $569.9 million across 33 and deJAAA at $18.7 million across 356 (RWA.xyz asset pages, displayed values, read 4 November 2026, data dated 3 or 4 November). Those wrapper totals appear to count much of the supply twice. RWA.xyz adds supply on Stellar to supply on Ethereum, and most of the Ethereum supply sits in addresses Centrifuge labels as Stellar escrows. On Centrifuge's own issuance figures the wrappers are about $11.1 million and $9.6 million (read 4 November 2026), or about 10% and 2% of their funds, with about ten times the holder addresses. That is a snapshot of something moving quickly. JTRSY showed $294.7 million in data of 28 October, and its page now shows it down 67% in 30 days while its value per token rose, so the fall came from tokens outstanding rather than from price. deJTRSY's holder addresses are down 32% over the same 30 days. These figures also say little about reach. Addresses are not holders, and in tokenized money-market funds generally the Bulletin found "a high concentration of holdings by a small number of investors and limited trading activity".

RWA.xyz tags both wrappers "Non-U.S. Professional Investor", the group the funds are open to (for JAAA, Grove's legal overview). Centrifuge's own metadata is wider, giving eligibility for both wrappers as "Non-US Persons and Entities". We have not read the wrappers' own terms. Whatever those terms say, a token built to trade on DEXes is bound by any such rule after the first sale, if at all, only through terms.

Centrifuge's metadata names Open Market Factory Limited as the issuer of both wrappers and describes each as a debt product linked to its fund, issued as tokenized notes. So the holder's claim appears to be on a note. The metadata lists no note documents, and we could not establish from public documents where Open Market Factory is registered or whether the fund's manager approved the wrappers. We have not found a wrapper we can show is issued by an unaffiliated onboarded holder with the sponsor's approval. In that form the structure is untested. There is no record of it under stress, and that absence should not be read as an opening.

What a Wrapper Could Buy

The first benefit is transfer with no gate behind it. The Bulletin says the current allow-listing approach "is impractical for funds with a large investor base and restricts TMMF liquidity, limiting their wider use for margining." It argues that peer-to-peer trading could promote these funds' use for margin calls and reduce the need for investors to redeem, and a wrapper could carry that use to wallets and venues no fund has onboarded. The only figures we have found for how much of either wrapper is posted as collateral are tiny: Morpho's API shows two deJAAA/USDC markets on Base with about $15 of collateral between them and none for deJTRSY, and we did not check other venues (read 4 November 2026). We can describe this only as something a wrapper could do.

The Bulletin's own answer is a different one: "Trusted wallet ID systems, shared across funds and supported by sound AML/CFT checks and ongoing compliance monitoring (eg Aldasoro et al (2025c)) could mitigate associated risks." That widens the gate, where a wrapper would step around it, and where such a system exists we think it is the better route. We have not found one in use across funds today, so this condition rules out little for now.

This sits uneasily with something Tessera has said before. Something That Moves, first published on 28 September (republished here on 10 October), said: "The remedy is a label where the holder already is, rather than a gate they will not walk through." That passage concerned labels. The question here is who may hold at all, and on that question we think a shared gate is better than none, though less convenient. If holders will not walk through it, that counts against this piece. If they do, it counts against the earlier one.

The second benefit is smaller holdings. Where a fund's minimum keeps a holder out, and its eligibility rule does not, a wrapper can be bought in smaller amounts. In Centrifuge's pool metadata (read 4 November 2026), both funds show a $500,000 minimum subscription and the wrappers 10,000 USD, and those are subscription minimums, which we would not expect to apply to a purchase on a DEX. Where the bar is eligibility, as it is for a professional fund, this benefit becomes one of the risks the FSB lists, discussed below.

The third is that the sponsor keeps its register. The shares behind the wrapper sit with an intermediary the sponsor has onboarded, so the sponsor still decides who holds them. The register now shows the intermediary, however, and the people with the exposure do not appear on it; knowing the holder passes to the wrapper's own checks. With approval, the sponsor can also confirm on its register what the intermediary holds, which lets the backing be checked. Approval leaves the category where it was. SEC staff separate securities tokenized by or on behalf of their issuers from those tokenized by unaffiliated third parties (Statement on Tokenized Securities, 28 January 2026), and on our reading a wrapper issued by an onboarded holder is the second kind, approved or not. Approval also says nothing about who should bear the exposure, and it is not one of the conditions set out below.

What a Wrapper Costs

The liquidity mismatch moves to a new place and stays in force. A wrapper that trades around the clock sits on a fund that redeems on its own cycle. For JAAA, Grove's 2025 overview says proceeds are "typically delivered to the investor's designated wallet within three Business Days, though the Fund may extend this timeline in the event of market disruptions or other exceptional conditions." Centrifuge's current fund metadata describes faster settlement, T+0 or T+1 depending on the cutoff, which still falls short of a market that never closes. Whoever makes the wrapper liquid in between, by holding inventory or making a market, carries that gap until the buffer runs out, and after that the holders carry it as a discount or a wait. In the Bulletin's words: "At the heart of these risks lies the liquidity mismatch between the daily redemption capabilities of the tokenised shares and the underlying assets, which remain subject to traditional settlement cycles." That passage concerns tokenized money-market funds, and JAAA is a credit fund, so applying it here is our extension. The Bulletin adds that because redemptions are immediately visible to all market participants, the risk of runs may grow as confidence wanes, and that repackaging these funds' shares into other tokens can carry stress from one fund to others. A wrapper is that kind of repackaging. Its issuer is also one more large holder, and in stress its redemption arrives as a single tender.

The wrapper also adds a counterparty. Where it evidences an interest in fund shares held in custody, that interest may still run through the third party; where it does not, the holder's claim is against the wrapper's issuer. SEC staff distinguish a third party's token that "evidences the holder's ownership interest (whether direct or indirect) in the underlying security being held in custody" from one "representing its own security that provides synthetic exposure to the underlying security ..." Holders of a third party's token, they note, may face risks such as its bankruptcy that a holder of the underlying would not necessarily face. Under the synthetic model, depending on the facts, the third party may be deemed an investment company, and under certain circumstances a token may be a security-based swap, which may not be offered or sold to persons who are not eligible contract participants unless it is registered and traded on a national securities exchange. The statement "has no legal force or effect ..." In the US, at least, the wrapper's issuer may have a gate of its own to pass.

A token anyone can hold is also a token anyone can take. In the Binance theft of 29 October, the assets that could be stopped were almost all stablecoins, frozen by their issuers, while about $2.4 billion the attacker held in ether and bitcoin was "beyond any issuer's reach" (TRM Labs, figures as of 30 October 2026). Whether a wrapper's issuer can freeze, cancel and reissue, and who holds those keys, has to travel with the token.

Leverage and pricing deserve the same sober treatment. The Bulletin warns: "Leveraged borrowing strategies (so-called looping), where TMMFs are pledged as collateral to borrow stablecoins to buy more TMMFs, could worsen market dislocations by triggering deleveraging spirals." A wrapper used as collateral is priced off a fund value struck off-chain, and the FSB warns that an accurate picture of the price and quality of tokens "may be hindered by reliance on unregulated or non-compliant oracles for pricing and valuation." A wrapper makes leverage easier, and nothing about it makes leverage safer.

The Eligibility Question

Eligibility is the hardest cost, and it is the Bulletin's bypass point again. The FSB wrote: "Fractionalisation, lack of transparency, and resulting challenges in asset valuation could also lead to excessive risk taking by investors that are not qualified to assess and hold exposure to risks stemming from some tokenised assets." (22 October 2024.) The smaller holdings listed above as a benefit come first on that list. Commissioner Peirce has said that a token which "does not provide the holder with legal and beneficial ownership of the underlying security could be a 'security-based swap' that cannot be traded off exchange by retail persons." (9 July 2025.) On that reading, a wrapper of this kind could be off limits to US retail off exchange, though she notes a token could instead, depending on the facts, be a receipt for a security, which is itself a security.

Chan Ahn's LinkedIn version of The Token Chose the Gate said of the private route: "What it generally buys is a lighter regime; what it costs is the gate." Where a fund's lighter regime depends on its gate, we think passing the exposure around the gate is arbitrage, with or without the sponsor, and the honest route is a registered share class. JTRSY and JAAA are BVI professional funds, open to non-US professional investors (RWA.xyz for JTRSY; Grove's legal overview and Centrifuge for JAAA), so a freely transferable wrapper of them is the case this test exists for. Centrifuge has described the wrappers' audience more widely: a capture of its deRWA page from May 2026 speaks of "delivering institutional-grade yields to retail users without minimums or onboarding friction." Whether deJTRSY or deJAAA passes turns on three things. We could not find in public whether the professional-fund regime depends on who ends up with the exposure, or what the wrappers' terms say about later holders. The third is whether any check runs on transfer. Centrifuge's public FreelyTransferable hook, which Yearn's report on JAAA and a Centrifuge governance post name for these tokens, "Allows any non-frozen account to receive tokens and transfer tokens", which would leave a freeze list as the only check, though we have not confirmed the deployed contracts or who holds the freeze role. Until a wrapper publishes its terms, the test cannot be passed from outside, and that counts against it.

If the sponsor agrees, the cleaner answer is usually for the sponsor to issue the open class itself. An intermediary earns its place only by doing something the fund does not: holding a liquidity buffer the fund does not hold, of a size it publishes, or being permitted to offer the exposure in a place where the fund, whose own regime does not depend on its gate, is simply not registered. Even then, the law of each place the wrapper is sold must allow it, the fund's regime must not depend on who ends up with the exposure, and the checks must reach every holder beyond the first. A token that moves freely meets that last condition only through its terms, which leaves the decision with the issuer. We do not think terms alone answer it. That condition is the hard one, and it may mean the answer is usually no. The issuer profits from the answer, so it should not be the only judge; the regulator of each place the wrapper is sold, or a published legal opinion, should be. "Permissionless" describes the token. Who may lawfully hold it is a separate question.

The Case Against This Reading

The two direct wrappers are small and come from the platform side. They show that a wrapper can be built and run in calm conditions. They do not show that the structure discussed here works under stress or that anyone wants it at scale, and we have not seen either go through a redemption run. The FSB's reassurance also cuts both ways. In 2024 it wrote that tokenization "does not currently pose a material risk to financial stability, mostly due to its small scale", and among the additional factors limiting concern it named "the current focus on permissioned (rather than permissionless) platforms ..." (22 October 2024). A permissionless wrapper moves away from that second factor, at the level of the token if not the chain, and growth would remove the first.

The claim here is therefore narrow. A wrapper buys reach beyond the gate at the costs above, and it is worth having only where the intermediary does something the fund does not, no shared wallet-identity system is available instead, the fund's regime does not depend on the gate, the law of each place it is sold allows it, and the checks reach every holder. Sponsor approval is not one of these conditions. Where those conditions are not met, we think it is arbitrage, and a registered class is the honest route.

Where Tessera Sits

T-Tokens are tokenized loan participation rights providing economic exposure, issued under their own terms; they do not provide equity ownership, voting rights or direct shareholder status. They are not made with the approval of OpenAI, Kalshi or SpaceX, T-OpenAI and T-Kalshi provide economic exposure linked to the valuations of companies whose own shares are gated, and T-SpaceX provides economic exposure linked to SpaceX, whose shares have since listed, so a reader may ask whether the arbitrage point applies to them. They are not tokens of those companies' shares. Tessera's terms exclude persons in the US and other excluded jurisdictions, and T-Tokens are not available to them on any venue, but that exclusion sits in the terms and not in the code, and by the test above terms alone do not settle whether every holder is eligible. Whether either answer is enough is not Tessera's to judge.

T-Tokens are not redeemable before a Liquidity Event. After one, a holder can redeem only during a 90-day Redemption Period that starts on a Redemption Start Date announced by Tessera Works Foundation; if tokens are not redeemed by the end of that period, the issuer is discharged and the holder has no further claim. A holder's recourse is limited to the proceeds of the issuer's investment that the issuer actually receives (Tessera Terms and Conditions, tessera.pe/terms, last revised 29 October 2026). No Tessera product is in any of the figures above. Tessera is exploring a structure of the same kind as the two wrappers discussed here, so Tessera is not a neutral judge of them or of this argument, and this piece should be weighed accordingly.

Sources: BIS Bulletin No 115, "The rise of tokenised money market funds", 26 November 2025 (the authors' views); RWA.xyz (Bryan Choe), "A New Framework for Tokenized Assets: Distributed & Represented", 21 November 2025; RWA.xyz, Treasuries page and the asset pages for JTRSY, JAAA, deJTRSY and deJAAA, app.rwa.xyz, read 28 October and 4 November 2026, displayed values, data dated 28 October and 3-4 November 2026 (RWA.xyz gives no time zone); TRM Labs, "North Korea Steals USD 6.36 Billion From Binance in the Largest Hack in History", 29 October 2026, figures as of 30 October 2026; Grove documentation, docs.grove.finance, read 28 October 2026; Grove, "Grove - Legal Overview of JAAA", Sky forum, 16 July 2025; Centrifuge pool metadata and issuance API for deJTRSY and deJAAA, read 4 November 2026; Ethereum balances of the two Stellar escrow addresses, read 4 November 2026; Centrifuge, deRWA tokens page, Internet Archive capture of 11 May 2026; Centrifuge, FreelyTransferable.sol, protocol repository, read 4 November 2026; Yearn, report on Centrifuge JAAA, updated 20 August 2026; Centrifuge governance forum, community research post on JTRSY holder distribution and deRWA adoption; Morpho API, read 4 November 2026; SEC Divisions of Corporation Finance, Investment Management, and Trading and Markets, "Statement on Tokenized Securities", 28 January 2026; Commissioner Hester M. Peirce, "Enchanting, but Not Magical: A Statement on the Tokenization of Securities", 9 July 2025; Financial Stability Board, The Financial Stability Implications of Tokenisation, 22 October 2024; Tessera Terms and Conditions, tessera.pe/terms, Date Last Revised 29 October 2026, read 4 November 2026. Chan Ahn, "The Token Chose the Gate", LinkedIn, 28 October 2026. Tessera, "Going Public by Degrees" (first published 29 July 2026, republished at blog.tessera.pe on 30 July 2026), "Something That Moves" (first published 28 September 2026, republished at blog.tessera.pe on 10 October 2026), "Nine Said No" (first published 19 October 2026, republished at blog.tessera.pe on 20 October 2026) and "Re-Plumbed" (dated 26 October 2026, published 27 October 2026).

This is market commentary, not investment advice. It is not a recommendation to acquire, hold or redeem any Tessera product, to use any platform mentioned, or to take or avoid exposure to any asset mentioned.

T-Tokens are tokenized loan participation rights, not equity. High risk. DYOR. Not financial advice. Not available in the US or other restricted territories. tessera.pe/terms