On January 21, 2026, F/m Investments LLC and The RBB Fund, Inc., on behalf of the F/m US Treasury 3 Month Bill ETF (ticker: TBIL), filed an application with the U.S. Securities and Exchange Commission (SEC). The request is narrow: it asks the SEC to allow TBIL to use a permissioned distributed ledger as an additional way to record and transfer ETF shares—without changing what TBIL owns, how it is managed, or how it trades on Nasdaq. TBIL would remain the same ETF investors use today; the “upgrade” is to the recordkeeping and settlement rails underneath it. The proposal keeps TBIL the same U.S. Treasury ETF investors know today, while adding an optional, permissioned ledger as a new way for regulated institutions to hold and move shares.
"Tokenization is coming to securities markets whether we file this application or not. The question is whether it happens inside the regulatory framework investors have relied on for 85 years, or without that set of protections for investors."
— Alexander Morris, CEO, F/m Investments
What is ETF share "tokenization”?
For TBIL’s SEC application, tokenization means representing ownership of an ordinary ETF share in a digital format on a distributed ledger (a blockchain-style record). The investor still owns a share of TBIL, backed by short-term U.S. Treasury bills. The token is simply a new way to record and move that same share through a controlled, permissioned ledger. It does not turn TBIL into a new crypto asset or currency, and it does not change what TBIL owns.
What is TBIL proposing—at a high level?
TBIL is asking the SEC to allow it to maintain a permissioned distributed ledger as an additional official record of who owns TBIL shares and to use that ledger as a controlled transfer mechanism for moving those shares among approved intermediaries. Traditional DTCC, brokerage, and transfer-agent paths stay in place. The ledger would sit alongside today’s infrastructure as extra plumbing, not a replacement. The infographic below illustrates the proposed upgraded infrastructure.
Source: Perry Woodin, “F/m Investments: A 1940 Act ETF, but with tokenized shares on a permissioned blockchain (TBIL),” LinkedIn post, January 2026. Used for illustrative purposes only.
Does this change the ETF investors know today?
No. The application is designed so that TBIL remains the same ETF investors already use: same investment objective and underlying exposure; same Nasdaq-listed ETF with the same ticker, CUSIP, fees, and portfolio management; and the same primary-market creation/redemption mechanics that help keep market price in line with NAV. From the ETF market’s perspective, TBIL stays TBIL. The change is in how certain intermediaries may hold and move shares behind the scenes, while allowing them to integrate ETF positions into more digital-native workflows if and as they choose to do so.
Who is the tokenized "plumbing" for?
The primary users are expected to be regulated intermediaries and institutions, such as broker-dealers, custodians, banks, trust companies, and other qualified custodians, as well as institutional investors that want TBIL exposure integrated into token-aware collateral, cash-sweep, or settlement workflows. For most individual investors, access would still be through the same brokers and platforms they use for TBIL today; any digital-native account options would depend on what those firms choose to offer.
What investor problem is this trying to solve?
The goal is to modernize how ETF positions can be held and moved without weakening the protections that make ETFs work. Potential benefits, especially for institutional use cases, include faster and more programmable settlement for certain transfers and collateral movements, operational efficiency from reducing manual reconciliation between multiple recordkeeping systems, better integration with digital-native and token-aware infrastructures, and clear, audit-ready ownership records on a shared ledger. In other words, this is a proposed plumbing upgrade for a live ETF, not a redesign of the ETF itself. Any future use of tokenized rails may also involve operational and technology risks that would be evaluated and described at the time they are implemented.
Does this mean TBIL will trade 24/7?
Not by itself. TBIL would continue to trade on Nasdaq during normal market hours, with price discovery on the exchange and through traditional market-making and arbitrage. The application does not ask to change exchange trading hours, create a new trading venue, or move price formation onto a blockchain. Over time, if exchanges or alternative trading systems offer token-aware rails under their own rules, TBIL’s structure is meant to be compatible, but those developments would be governed by separate regulations.
Why a permissioned ledger instead of a public, permissionless chain?
ETFs already sit inside a mature framework for investor protection, market integrity, and compliance. A permissioned design helps restrict participation to approved and whitelisted entities, support familiar anti-money laundering, know your customer procedures, and sanctions controls at the intermediary level, and keep the official share register under the transfer agent’s oversight, so the ledger functions as a controlled recordkeeping component rather than an uncontrolled public network. This is intended as a careful first-step design, not a statement that public or hybrid models will never be appropriate.
How is this different from stablecoins or other "unregistered tokens"?
TBIL remains a registered U.S. Treasury ETF. The tokenized representation is simply another way to hold the same share, with the same CUSIP, rights, and fees. TBIL continues to operate under the same ETF framework, with board oversight, daily portfolio transparency, independent custody, and extensive disclosure. Investors are not buying a separate unregistered token that only references a fund or basket; they are holding the actual ETF share through a different tokenized recordkeeping channel.
How does this proposal compare to other tokenized fund structures in the market?
Many early tokenization efforts have focused on creating new token-native funds, such as institutional liquidity or money-market-style vehicles and private funds that are available only through digital-asset platforms. In those models, investors typically buy a new token that represents an interest in a separate fund designed from the ground up for digital rails.
TBIL’s proposal takes a different approach. It starts with an existing U.S. Treasury ETF that is already listed on an exchange and widely held in brokerage accounts, and then treats tokenization as an additional recordkeeping and settlement rail for that same ETF share. The investment objective, portfolio, ticker, CUSIP, and ETF market structure remain unchanged. The permissioned ledger is designed as back-end infrastructure for regulated intermediaries, not as a separate fund, product, or trading venue.
How does this relate to exchange and platform "tokenized rails" initiatives (NYSE, Nasdaq, Coinbase, etc.)?
Exchange and venue initiatives generally focus on how trading venues and post-trade systems might evolve under securities and commodities laws. TBIL’s application is focused instead at the fund and transfer-agent layer. It does not seek to pre-approve any particular exchange or ATS design. It aims to ensure that, as venues introduce token-aware infrastructure, TBIL can plug into those rails using a single, regulated share class.
Will this change TBIL’s risk profile or investor protections?
The proposal is designed so that TBIL’s existing investor protections remain in place, including investment in short-term U.S. Treasury bills subject to the fund’s investment strategy and risks, independent board oversight and daily portfolio transparency, third-party custody and safekeeping of assets, and comprehensive regulatory compliance, reporting, and auditing.
The transfer agent would remain the authoritative recordkeeper of share ownership, tokenized positions could be converted back to traditional book-entry records on a 1:1 basis, and retail investors would continue to access TBIL through brokers and platforms rather than being asked to self-custody tokens or interact directly with experimental decentralized-finance protocols. Any future use of tokenized rails may also introduce new operational or technology risks, which would be evaluated and described at the time they are implemented. Investors should continue to review TBIL’s prospectus and other filings for a full description of risks.
What happens next?
The SEC will review the application, ask questions, and may request changes. No tokenized path will be implemented unless and until the SEC grants appropriate relief and the necessary intermediaries build compliant workflows. Until then, nothing changes for existing TBIL shareholders: TBIL continues to trade and operate as it does today. F/m Investments expects that this process, and the public dialogue around it, may help inform future approaches to tokenized ETF shares. If tokenized rails are implemented in the future, they may introduce additional operational and technology risks that will be considered by the fund’s service providers and disclosed as appropriate.”
Does this FAQ change or replace TBIL’s official disclosures?
No. This FAQ is educational and is meant to help investors and industry participants understand the high-level goals of the application and how tokenized ETF shares might work in practice. It should be read together with TBIL’s prospectus, Statement of Additional Information, shareholder reports, and other public filings. Investors should always review those official documents and consult their financial or tax advisers before making investment decisions.
Meet TBIL
Investors should consider the investment objectives, risks, charges, and expenses before investing. For a prospectus or summary prospectus with this and other information about the Fund, please call 1-800-617-0004 or visit our website at www.fminvest.com. Read the prospectus or summary prospectus carefully before investing.
As with all ETFs, Shares may be bought and sold in the secondary market at market prices. Interest rate risk is the risk of losses attributable to changes in interest rates. In general, if prevailing interest rates rise, the values of debt instruments tend to fall, and if interest rates fall, the values of debt instruments tend to rise.
Fund Risks: The UST 3 Month Bill Fund may be susceptible to an increased risk of loss, including losses due to adverse events that affect the UST 3 Month Bill Fund’s investments more than the market as a whole, to the extent that the UST 3 Month Bill Fund’s investments are concentrated in a particular issue, issuer or issuers, country, market segment, or asset class. While U.S. Treasury obligations are backed by the “full faith and credit” of the U.S. Government, such securities are nonetheless subject to credit risk (i.e., the risk that the U.S. Government may be, or be perceived to be, unable or unwilling to honor its financial obligations, such as making payments).
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