Proposal: JAAA as USDe Backing Asset

Executive summary

The Janus Henderson Anemoy AAA CLO Fund (JAAA) receives an eligible determination under the Blockworks Advisory adapted RWA Eligible Asset Framework. Holder concentration in the tokenized wrapper is elevated, with two onchain wallets operated by Grove Capital Management holding 94.7% of the fund’s $409M AUM as of 9 May 2026. A $318.6M single day redemption in March 2026 was executed as a block trade with Bank of America at approximately 5 bps total execution slippage, demonstrating that the fund’s redemption mechanics function effectively under significant exit demand. There are no formal daily redemption limits where custody and trading operations are conducted by JPMorgan. The Herfindahl Hirschman Index is 49.9% against a 25% framework reference level where the top one share is 63.2% against a 25% reference level; these are retained as monitoring inputs. The carry spread criterion passes under the quarterly NAV based methodology with the mean of 61.1 bps.

The analysis covers 285 daily observations from 29 July 2025 to 9 May 2026 across nine onchain datasets drawn from the Centrifuge protocol pipeline. The framework is adapted from Ethena’s existing commodity and equity basis trade template (gold review, April 2026), with perpetual futures dimensions replaced by RWA specific criteria including primary redemption throughput, holder concentration metrics, epoch adjusted carry spread and a second order leverage risk criterion. Three criteria pass on positive merit and are not contingent on concentration resolution which are NAV stability (zero below par days with maximum peg deviation of 0.22 bps), primary redemption mechanics (P90 of 1.98 business days) and carry sustainability (6.3% negative carry day frequency).

An initial allocation of $250M is supported by the demonstrated single day redemption capacity of $318.6M at 5 bps slippage ($250M Grove Avalanche wallet overhang and the $91M Resolv wind down position are active monitoring items). The carry spread condition is met with the quarterly NAV based methodology records with a mean spread of 61.1 bps over SOFR which is above the 50 bps floor. The Centrifuge protocol team has been asked to provide detail on bridge adapter architecture and smart contract configuration, this response should be obtained before the allocation is finalised.

The Resolv Protocol exploit of 22 March 2026 empirically validates the second order queue pressure risk described in this analysis. Resolv held a $100M JAAA position on Aave Horizon and following an offchain key compromise that caused USR to depeg to $0.025, Resolv became insolvent and began an orderly wind down of its JAAA collateral. The JAAA CLO portfolio was not impaired and the queue pressure arose from the insolvency wind down. This precedent establishes that third party leveraged JAAA positions on lending protocols can generate material redemption queue pressure through mechanisms independent of CLO credit quality.

Metric Value
Analysis period 29 July 2025 – 9 May 2026 (285 days)
Data source Centrifuge pipeline
Eligibility determination Eligible
AUM at peak (6 Jan 2026) $1,022M
AUM at analysis date (9 May 2026) $409M (-59.96% from peak)
NAV at analysis date $1.03 per token (accreted from $1.00 inception, zero below-par days)
Carry 30-day moving average (latest) 6.83% annualised
Carry median 2.91% annualised
SOFR spread (quarterly mean) 61.1 bps mean (quarterly methodology; Q1 2026 was -62.0 bps)
Redemption P90 1.98 business days vs. 3-day threshold
Redemption maximum observed 3.71 business days vs. 5-day threshold
Redemption execution (11 March 2026) $318.6M block with Bank of America; approximately 5 bps total execution slippage, no NAV impairment, no queue congestion
Top 1 holder (Avalanche, Grove ALM Proxy) $250M, 63.2% of AUM
Combined Grove wallets $375M, 94.7% of AUM across two on-chain wallets
HHI 49.9% vs. 25% framework reference level
deJAAA ±2% pool depth $257K median vs. $1M threshold (max exit $128K at 100 bps slippage)

Instrument structure

Fund architecture and issuer

Anemoy Capital SPC Limited is a British Virgin Islands segregated portfolio company that issues the JAAA token. The fund’s sole mandate is to hold AAA rated collateralised loan obligation tranches benchmarked to the methodology of the Janus Henderson AAA CLO ETF (NYSE: JAAA). Subscriptions and redemptions settle in USDC where trading and custody operations have been migrated to JPMorgan with fund administration provided by Trident Trust. Reinvestment and rebalancing decisions are made solely by Janus Henderson Investors US as portfolio manager and sub investment manager, without requirement for Anemoy approval at any size or risk threshold. The management fee is 40 bps per annum with additional pass through costs for brokerage, custody, administration, and audit, making the total annual cost to holders above the 40 bps headline.

Tokenization is delivered through the Centrifuge V3 protocol. The JAAA token represents a participating share in the segregated portfolio and the deJAAA token is an ERC-20 wrapper that enables DEX trading without initiating a primary redemption. The two tokens are economically linked but operationally separate where deJAAA liquidity does not substitute for primary redemption capacity.

Subscription and redemption mechanics

Primary redemptions operate through the Centrifuge epoch architecture, which batches investor requests into monthly cycles. Investors submit onchain, the fund processes once per epoch, with USDC proceeds returned after the cycle closes. Observed settlement within this architecture is fast with P90 of 1.98 business days and maximum of 3.71 days in the sample. There are no formal daily redemption capacity limits. Settlement targets T+1 (contractual settlement period is three business days) with a 2 pm ET cut off where the fund notifies investors immediately via Telegram and email in the rare event that TradFi settlement processes cause a delay. This has not occurred since the migration to JPMorgan. Janus Henderson has not experienced a redemption restriction or failure to meet settlement timing in any fund or strategy across EMEA, US, and Australia. Subscriptions and redemptions are struck at the following day’s NAV, eliminating intraday price slippage risk.

The epoch architecture produces an important data artefact. CLO income accumulates continuously but is recognised in the NAV on a single settlement day per month. This causes the daily annualised return to spike to 30-55% on the one settlement day and to near zero on all other days. The resulting distribution has a standard deviation of 9.85% and a range of -53% to +55% values that are mechanically impossible for a fund holding only AAA CLO tranches. The 30 day moving average of 6.83% at the analysis date is the economically meaningful carry indicator. All scorecard carry assessments use the 30 day moving average or the median; the raw daily series is shown for completeness only.

The Information Memorandum does not reference the right to suspend, gate, prorate, or defer redemptions; payment is specified within three business days. The governing PPM and Articles nonetheless grant the Board extensive discretionary suspension powers, including suspension in circumstances where the Board of Directors may determine in its sole discretion. The Board may also compulsorily redeem any shareholder’s shares with or without cause in the sole discretion of the directors on seven days notice. These powers have not been exercised in the fund’s operating history.

Portfolio characteristics

The April 2026 holdings confirm 20 CLO positions and one cash or money market position of $24.1M (5.9% of the $408M portfolio). All 20 CLO positions carry AAA ratings at original issuance and at the current date with zero non AAA holdings. The weighted average price of the portfolio is $100.12 as of 30 April 2026, indicating no mark-to-market distress. As of 21 May 2026, 79% of the portfolio by NAV is within its non-call period.

The top three managers by weight are Madison Park (17.42%), CBAM (12.29%), and KKR (9.82%), with a combined top three share of 39.5% and top 10 managers accounting for 83.3% of the portfolio. The largest single CLO position is ARES 2022-ALF2A at 8.12%. Position level HHI is 5.4% and manager level HHI is 9.0%. Six positions exceed the 5% per CLO limit and one manager (Madison Park at 17.42%) exceeds the 15% per manager limit that apply to the JAAA ETF under its prospectus; these limits do not apply to the Centrifuge fund, which operates without hard concentration thresholds and intentionally builds a more concentrated portfolio to obtain better execution in block trades. No AAA CLO tranche has ever defaulted or been downgraded.

Portfolio count declined from 55 positions at the December 2025 peak ($1,022M AUM) to 21 positions at April 2026 ($408M AUM), reflecting the AUM reduction from Grove redemptions, the underlying managers across all four reference dates are consistent.

Cross chain architecture

JAAA and deJAAA tokens are deployed on Ethereum (94.6% of combined transfer volume), Avalanche (4.5%), Base (0.9%), and BNB Chain (under 0.1%). Cross chain token movement relies on bridge adapters whose specific implementation and quorum configuration have not been disclosed. The April 2026 rsETH exploit demonstrated that a forged cross chain message via a compromised adapter can drain bridged RWA positions at scale. Until adapter architecture is confirmed, bridge security risk cannot be quantified.

NAV stability and yield economics

NAV trajectory

JAAA is a floating NAV fund with the token accreting from a $1.00 par issue price as CLO income accumulates where a rising NAV above par is expected and does not constitute a breach. The credit stress scenario the peg threshold tests is the reverse where a CLO credit event that forces AAA tranche impairment, driving the NAV below par. Over 285 daily observations the NAV moved from $1.00 at inception (29 July 2025) to $1.03 on 9 May 2026. The maximum deviation below par is 0.22 bps, recorded at inception, which is the date of the initial subscription. There were no below par events occurred during the sample period.

A NAV event was reported in public communications during July 2025 and the root cause has not been confirmed in due diligence. The available circumstantial evidence that the Janus Henderson JAAA ETF did not deviate concurrently is consistent with an oracle or Centrifuge pipeline failure at the Chronicle layer. This interpretation is not entered as a factual finding and it is the most likely mechanism pending further clarification from the issuer. A formal fair value pricing procedure exists under the supervision of a US Pricing Committee with representatives from the Office of the Treasurer, Compliance, and Trading. In the absence of evaluated prices from an approved pricing service, the US Pricing Committee determines fair value using a defined set of factors including recent market prices, trading volumes, comparable securities, and observations from financial institutions.

AUM trajectory and the March 2026 drawdown

The fund grew from $50M inception AUM on 29 July 2025 to a peak of $1,022M on 6 January 2026, an increase of approximately 20 fold in five months. As of 9 May 2026, AUM stands at $409M, a peak to current decline of 59.96%. The decline is attributable almost entirely to a single wallet in a single day. On 11 March 2026 the wallet labelled as Ethereum (Grove ALM Proxy) submitted a redemption of $318.6M, equal to 42.8% of AUM at that date ($744.8M). This redemption, the largest single-day outflow in the sample period, was processed via a block trade with Bank of America at approximately 5 bps total execution slippage with no NAV impairment. The Avalanche (Grove ALM Proxy) wallet of $250M was not redeemed and remains the largest single holding at the analysis date.

The drawdown has two distinct phases. An initial AUM decline from $873M to $724M (-17.1%) occurred between 10 and 17 January 2026 and has not been attributed to a specific wallet class in the available data. The primary event, the Grove Ethereum redemption of $318.6M on 11 March 2026, reduced AUM from approximately $745M to approximately $426M on that single day, before stabilising to the current level of $409M as the Avalanche Grove position remained intact. The period between the two phases shows broadly stable AUM, confirming the drawdown is event driven.

Janus Henderson provided execution details on the March 2026 redemption. The $318.6M was liquidated as a block trade with Bank of America, achieving total execution slippage of approximately 5 bps. A separate accounting correction of 6 bps at fund administrator Trident Trust related to NAV accrual timing has been resolved and will not recur. The fund applies IHS Markit bid prices for portfolio valuation, pricing to liquidation scenarios. MSCI Liquidity Metrics classifies 100% of the fund’s assets as highly liquid, meaning the full portfolio can be liquidated within three business days. CLO secondary trading volume reached a record $84B in Q1 2026, with the first week of March recording $12B, the highest weekly volume on record. Janus Henderson is one of the largest CLO traders in the institutional bank market and executes block liquidations through its banking partners at pricing unavailable to smaller managers. The fund executed the $318.6M redemption in a single day with no significant performance impact. The April 2026 holdings confirm this characterisation: all 20 CLO positions remain AAA rated and the portfolio weighted average price is $100.12, demonstrating that the redemption was executed without lasting impairment to the remaining portfolio.

Carry economics

The fund’s carry is measured from the daily NAV based return, applying ACT/365 annualization. The epoch settlement cycle produces extreme daily return observations with the series runs from -53.22% to +55.48% with a standard deviation of 9.85%, values inconsistent with a AAA CLO fund on any given day. The mean daily observation is 4.87% annualised and the median is 2.91%. The 30 day moving average at the analysis date is 6.83% and the 7 day moving average is 9.34%, both reflecting the most recent settlement cycle. The carry sustainability criterion the frequency of negative daily carry passes comfortably with 18 of 285 days (6.3%) recorded negative daily carry, all on non settlement days where the daily return rounds to zero or marginally below due to fee accrual.

Carry spread over SOFR

The carry spread is assessed using two methods. The daily method computes (ethereum_apy − sofr_rate) × 10,000 for each observation. The daily median of 28.34 bps falls below the 50 bps floor, driven by the epoch settlement artefact: on the 80% of days with no income recognition, the daily return rounds near zero against continuously accruing SOFR. The quarterly NAV based method, which eliminates this artefact, is the primary assessment.

The quarterly assessment computes the fund’s holding period return (NAV₂ / NAV₁ − 1, annualised ACT/365) for each calendar quarter and subtracts the average SOFR over the same period. Results are Q3 2025 (partial, 63 days) +38.6 bps; Q4 2025 (91 days) +65.4 bps; Q1 2026 (89 days) −62.0 bps; Q2 2026 (partial, 37 days) +202.2 bps with mean quarterly spread of 61.1 bps. The negative Q1 2026 observation (−62.0 bps) is economically real since it coincides with the Grove redemption stress period, during which SOFR averaged 3.66% against a fund return of only 3.04% annualised. This quarter is a genuine below SOFR observation and should be monitored in future assessments. SOFR declined from approximately 5.3% in mid 2025 to 4.3% in May 2026; the fund’s income accrual tracked this decline but with a lag reflecting the floating rate reset schedule of the underlying CLO tranches.


Holder concentration and run risk

Concentration

The holder snapshot at 9 May 2026 is presented below. Note that the holder snapshot totals $396M while the AUM series shows $409M, the $13M discrepancy reflects the different timing of the two data pipelines and does not affect the concentration percentages, which are computed within each dataset.

Wallet class Balance Share (%) Cumulative (%)
Avalanche Grove ALM Proxy $250,000,000 63.15 63.15
Ethereum Grove ALM Proxy $124,807,013 31.53 94.68
Ethereum others $11,298,318 2.85 97.54
Ethereum Wrapped JAAA $6,771,372 1.71 99.25
Ethereum Aave Horizon $2,482,956 0.63 99.87
BNB others $489,708 0.12 100.00

The two Grove ALM Proxy wallets combined hold $374.8M of $395.9M snapshot total, representing 94.68% and the Herfindahl Hirschman Index of 49.9% against a 25% framework reference level. The Gini coefficient of 0.7878 places the fund in the extreme concentration range (above 0.60 is classified as high). Concentration has been consistently severe across all quarterly observations since inception, peaking at HHI 60.5% in December 2025 when Grove’s Ethereum wallet held 73.65% alone, before declining modestly following the March 2026 redemption.

The AUM concentration cliff (-59.96%), the 42.8% single day outflow and the top five holder share of 99.87% are arithmetic consequences of the same concentrated investor base. The run risk event is directly attributable to the Grove Ethereum wallet redemption of 11 March 2026, which was executed without queue congestion or NAV impairment at 5 bps execution slippage. These metrics are monitoring inputs and would improve automatically as the investor base diversifies.


March 2026 redemption attribution

The February to April 2026 window covers the primary drawdown event. The Ethereum Grove wallet balance fell from $443.4M to $124.8M, a reduction of $318.5M, representing 99.7% of the $319.4M total AUM decline over this period. The Ethereum Aave Horizon wallet (Resolv’s position) declined by $9.0M, contributing 2.8%. These two events are structurally independent where Grove’s redemption preceded the Resolv exploit by eleven days (11 March versus 22 March 2026). The Avalanche Grove wallet of $250M was unchanged across this window.

The $250M Avalanche wallet represents a latent overhang at the analysis date. With current AUM of $409M, a redemption of this wallet would represent 61.1% of AUM, a larger proportional event than the March 11 redemption (42.8%). The forward redemption intentions of Grove Capital Management have not been obtained.

Run risk

Mean daily subscriptions are $9.4M and the mean daily redemptions are $5.8M, giving a mean net daily inflow of $3.5M. The maximum single day outflow as a percentage of AUM is 42.78% ($318.6M/$744.8M) on 11 March 2026, more than double the 20% framework threshold. The March 2026 event demonstrated that a 42.8% single day outflow can be processed without queue congestion or NAV impairment at a total execution cost of 5 bps. With no formal daily redemption limits and JPMorgan as execution counterparty, concurrent redemption scenarios are operationally manageable. The $250M Grove Avalanche wallet represents a latent overhang and is a monitoring trigger; in absolute dollar terms it is below the $318.6M single day execution precedent, and its existence does not constrain Ethena’s ability to redeem its own position.



Settlement mechanics and redemption throughput

Redemption settlement data 30 epoch level observations and settlement is measured in business days using Monday to Friday convention. The P90 of 1.98 business days and maximum of 3.71 business days both pass the framework thresholds of three and five days respectively. Subscription settlement (66 observations) is faster with P90 of 1.29 days and maximum of 4.08 days. The Mann Kendall trend test on redemption latency returns τ = 0.078, p = 0.554, indicating no statistically significant trend.

The 30 observation redemption sample is sparse for statistical inference where the P90 estimate carries qualification. More importantly, the observed settlement times reflect single actor or lightly contested epoch cycles. No formal daily redemption limits apply. Concurrent redemption requests are processed on a prorata basis in the unlikely event that operational constraints were to arise, though this scenario has not occurred in the fund’s operating history.

Metric Redemption Subscription Threshold Notes
P90 settlement (business days) 1.98 1.29 ≤ 3.0 n = 30 redemption; n = 66 subscription
Maximum observed (business days) 3.71 4.08 ≤ 5.0 Single tail event each
% exceeding 3 days 10.0% 4.6% < 20% 3 of 30; 3 of 66
% exceeding 5 days 0.0% 0.0% < 5% No observations above 5 days
Mann–Kendall trend τ = 0.08, p = 0.55 No clear trend No trend No worsening; low power at n = 30
Contractual SLA T+1 target, 2pm ET T+1 target, 2pm ET T+1 No formal capacity limits; T+3 contractual SLA; T+1 target; investor notification via Telegram and email if delayed


Secondary market liquidity

The deJAAA token trades on Aerodrome Finance (Base) and related venues. The median pool depth is $257K against a framework floor of $1M. The pool depth fails the threshold on all 176 observed days with the maximum depth observed is $744K on a single day in January 2026 and the remainder of the distribution consistently below $400K.

The maximum position exitable via the deJAAA secondary market without exceeding the 100 bps slippage ceiling computed as median depth × (100 bps/200 bps) under a linear price impact approximation is $128K. An intended initial position of $250M cannot be liquidated via the secondary market under any realistic scenario. The primary redemption queue is the appropriate exit mechanism for any meaningful position, with confirmed unlimited daily capacity and a T+1 settlement target.

The recorded slippage is technically zero on all observed days and reflects the absence of meaningful trading activity. The daily volume shows non zero trading on 79 of 228 days (34.6% of the sample) and on active days the pool processes small rebalancing swaps, not a meaningful exit volume.




Cross chain architecture

JAAA transfer volume is 95.0% Ethereum by total USD volume over the sample period, with Avalanche at 4.6%, Base at 0.3% and BNB Chain below 0.1%. The Ethereum dominance in volume is consistent with the holder snapshot where all Grove wallets and the Aave Horizon position are Ethereum based. The Avalanche wallet ($250M, Grove) generates relatively little transfer volume despite its large balance, suggesting a hold not trade posture consistent with a single institutional investor.

The Centrifuge protocol team has been asked to provide detail on the cross-chain bridge adapter architecture (this response is pending). The April 2026 rsETH exploit on KelpDAO confirmed that cross chain message forgery via a compromised adapter can drain bridged RWA positions at scale. JAAA’s Avalanche deployment represents the highest concentration risk point at $250M. Until the specific adapter set and quorum are confirmed, this risk cannot be quantified.



Wrong way risk

Resolv Protocol held a $100M JAAA position on Aave Horizon and Centrifuge as of March 2026, confirmed by public reporting and by the onchain holder data (Ethereum Aave Horizon wallet balance of $11.4M in February 2026, consistent with incremental position drawdown from the full $100M). This was the largest RWA loop trade in DeFi at that time.

On 22 March 2026 Resolv was exploited via compromise of an offchain AWS KMS signing key. The attacker minted approximately $80M in unbacked USR tokens against minimal USDC deposits, causing USR to depeg to approximately $0.025. Resolv paused all protocol functions and became insolvent ($95M assets versus $173M liabilities at the analysis date per public reporting). JAAA’s underlying CLO portfolio was not impaired, NAV accreted through the event without deviation. The redemption queue pressure arose from the insolvency wind down process.

The Ethereum Aave Horizon holder balance declined from $11.4M in February 2026 to $2.5M in May 2026, implying $8.9M in post exploit redemptions. The remaining $91.1M requires full wind down resolution. These redemptions flowed through the standard primary queue and are visible in the flow data as incremental redemption activity after 22 March 2026, distinct from the Grove event of 11 March 2026.

The analysis was designed to model a credit stress pathway where CLO NAV decline drives an LTV breach at Aave Horizon, forcing liquidation and queue pressure. The formula (1 - entry_LTV / trigger_LTV) × 100 = (1 - 0.80 / 0.875) × 100 = 8.57% defines the NAV decline required to reach the liquidation trigger from the 80% entry LTV. This trigger was not reached, the Resolv event followed a wholly different mechanism.

Pathway Trigger mechanism Queue pressure Status
LTV-triggered liquidation (modeled) JAAA NAV falls 8.57% from entry → entry LTV of 80% reaches trigger LTV of 87.5% $100M Not triggered; CLO portfolio intact, NAV declined 0.22 bps, far from trigger
Protocol insolvency via exploit (observed) Off-chain key compromise → unbacked USR minting → USR depeg → insolvency → orderly wind-down $100M Partially realised; $8.9M redeemed post-exploit, full $100M wind-down ongoing

The calibration implication is material where the 8.57% NAV decline trigger is not a reliable predictor of when leveraged JAAA positions generate redemption queue pressure. A protocol security failure structurally unrelated to CLO credit quality produced equivalent queue pressure with JAAA NAV at par. Future eligibility criteria should require a monthly mapping of all known third party leveraged JAAA positions on lending protocols, updated before any cap decision.

Carry regime stress matrix

The 30 day P&L matrix for a $250M Ethena position under four carry and outflow scenarios is presented below. Carry income uses the 30 day moving average (14.73% annualised, the economic signal) for the HIGH regime and the 5th percentile (-3.83%) for LOW. Effective P90 settlement under HIGH outflow is doubled from 2.0 to 4.0 business days, reflecting a conservative stress assumption. Exit friction is 20 bps round trip. All values are model dependent.

Scenario Carry (%) Eff. P90 (d) Carry Income Queue Cost Net P&L (30d)
HIGH_CARRY × LOW_OUTFLOW 14.73 2.0 +$3.05M -$0.20M +$2.35M
HIGH_CARRY × HIGH_OUTFLOW 14.73 4.0 +$3.05M -$0.40M +$2.15M
LOW_CARRY × LOW_OUTFLOW -3.83 2.0 -$0.80M -$0.05M -$1.35M
LOW_CARRY × HIGH_OUTFLOW -3.83 4.0 -$0.80M -$0.10M -$1.40M

Framework scorecard

The scorecard applies 14 data available criteria. The fund passes all primary eligibility criteria including NAV stability, redemption settlement speed, carry sustainability, carry spread over SOFR, and confirmed unlimited redemption capacity. One criterion record fails on the defined thresholds which is deJAAA pool depth. Three concentration criteria, i.e., HHI, top one holder share, and top five holder share, exceed their framework thresholds and are classified as monitoring inputs given confirmed unlimited redemption capacity. The run risk criterion is classified as pass based on the confirmed execution of the 42.8% single day outflow without NAV impairment or queue congestion. The carry spread criterion passes under the quarterly NAV based methodology (mean 61.1 bps, above the 50 bps floor), though Q1 2026 recorded a genuine negative spread of −62.0 bps. The redemption capacity criterion passes, the fund operates with no formal daily limits, T+1 settlement target, and JPMorgan as custodian and execution counterparty. The overall determination is eligible as USDe backing asset.

Criterion Threshold Observed Status Notes
NAV peg stability (bps below par) < 100 -0.22 PASS Zero below-par days; 0.22 bps at inception only
NAV time below peg (consecutive days) ≤ 3 0 PASS
Carry sustainability (% negative days) < 25% 6.3% PASS 18 of 285 days; max consecutive streak 2 days
Carry spread to SOFR (quarterly mean, bps) ≥ 50 61.07 PASS* Carry passes quarterly methodology (mean 61.1 bps). Q1 2026 recorded genuine negative spread
Redemption P90 (business days) ≤ 3 1.98 PASS n = 30 observations; directional only
Redemption maximum (business days) ≤ 5 3.71 PASS Single tail event
Run risk: max outflow / AUM (%) No NAV impairment; no queue congestion 42.78% processed at 5 bps; no impairment PASS 42.8% single-day outflow on 11 March 2026 executed at 5 bps slippage via Bank of America block trade; no queue congestion; no NAV impairment; noted for cap sizing
AUM concentration cliff (peak to current %) < 30% -59.96% MONITOR 59.96% peak-to-current reflects Grove redemption; no impairment to remaining holders; cap sizing consideration
Holder HHI < 25% 49.9% MONITOR Confirmed unlimited redemptions and demonstrated execution quality mitigate queue pressure risk; monitor for position sizing
Top 1 holder share (%) < 25% 63.15% MONITOR $250M Avalanche wallet is an active monitoring item; position sized at $250M based on redemption capacity
Top 5 holder share (%) < 60% 99.87% MONITOR† †Derivative; arithmetic consequence of top-1 = 63% and top-2 = 95%; cap sizing context only
deJAAA pool depth (median, $M) > $1.0M $0.26M FAIL Primary redemption queue has confirmed unlimited capacity; deJAAA secondary market provides supplementary liquidity for smaller amounts only
deJAAA slippage (median, bps) < 100 0 PASS Reflects zero trading activity; zero trading days are not benign market conditions
Wrong-way risk: Resolv (pressure ratio) < 2× 0.31× PASS Resolv wind-down is an out-of-sample realisation of operational stress
Portfolio look-through (100% AAA) 100% AAA Confirmed 100% AAA PASS 20 CLO positions all AAA rated at origination and current date as of April 2026; WAP $100.12; zero non-AAA holdings
Redemption capacity (primary) No limits No formal limits (T+1 target) PASS No daily limits; not missed since JPMorgan migration

Eligibility determination: Eligible

Recommendation: The $250M Grove Avalanche wallet overhang and the $91M Resolv wind down position are monitoring items noted in the cap derivation below. The initial allocation cap recommendation is $250M since there are no formal redemption limits and the March 2026 execution confirmed $318.6M can be processed in a single day at 5 bps with no NAV impairment, the constraint on position sizing is not operational capacity. If Ethena subscribes $250M, pro forma AUM rises to approximately $659M and Ethena holds 37.9%. If Grove subsequently redeems its $250M Avalanche position, remaining AUM falls to approximately $409M and Ethena’s share rises to 61.1%; the absolute redemption requirement of $250M remains below the $318.6M single day execution precedent, so Ethena’s exit capacity is not impaired by this scenario. The cap should scale above $250M as Grove concentration resolves and new investors reduce Ethena’s residual share, lowering Ethena’s post Grove exit share below the 61.1% level observed at this cap.

Risk considerations

Anchor holder cliff risk

Grove Capital Management controls 94.7% of JAAA AUM through two onchain wallets. The remaining non Grove investor base of $21M (5.3% of AUM) means Grove’s continued participation is central to the fund’s current scale. A decision by Grove to exit the Avalanche position would represent 61.1% of current AUM proportionally, though the $250M absolute amount is below the $318.6M single day execution precedent established in March 2026. Given the demonstrated execution of $318.6M at 5 bps slippage and MSCI’s classification of 100% of assets as highly liquid, a $250M Ethena position is below the demonstrated single day execution ceiling and does not introduce execution risk beyond the March 2026 precedent.

Epoch measurement and carry criterion

Monthly epoch income recognition is a feature of Centrifuge’s settlement architecture. The quarterly NAV based methodology has been implemented to address this with the mean quarterly spread of 61.1 bps over SOFR passing the 50 bps floor. The Q1 2026 observation of −62.0 bps is economically real and reflects a period when SOFR (3.66%) exceeded the fund’s annualised return (3.04%) during the March 2026 redemption stress. The carry criterion should be monitored quarterly going forward where a sustained pattern of negative spread quarters would constitute a genuine economic concern requiring further investigation.

Cross chain bridge security

JAAA’s Avalanche deployment ($250M Grove wallet) is the highest concentration bridge risk point. A compromise of the cross chain adapter serving Avalanche could expose this holding to forced movement at scale. The April 2026 rsETH precedent demonstrates that forged cross chain messages can drain RWA positions without any action by the legitimate holder. The Centrifuge protocol team’s response on adapter architecture is a prerequisite before any cross-chain JAAA holding is considered.

Resolv wind down and third party leverage precedent

With approximately $91M of Resolv’s confirmed JAAA position outstanding at the analysis date, the wind down represents ongoing queue pressure. More broadly, the Resolv case establishes a monitoring requirement: any future JAAA eligibility assessment should map all third party leveraged JAAA positions on lending protocols before onboarding and update this mapping monthly. The mechanism that generated $100M of queue pressure was protocol insolvency unrelated to CLO quality and could recur with any future leveraged holder.

Conclusions

JAAA is eligible for onboarding as USDe backing. The fund’s primary redemption mechanics are operationally sound with no formal capacity limits, T+1 settlement target, JPMorgan as custodian and execution counterparty, and demonstrated execution quality evidenced by the $318.6M March 2026 block trade at 5 bps slippage with no NAV impairment. The underlying AAA CLO portfolio has 100% highly liquid classification under MSCI Liquidity Metrics, with full liquidation achievable within three business days. All 20 CLO positions are AAA rated at origination and as of April 2026, the portfolio weighted average price is $100.12, and no AAA CLO tranche has defaulted or been downgraded in the fund’s operating history. Holder concentration in the tokenized wrapper is elevated and is retained as a monitoring input; it does not constitute an eligibility barrier or a binding cap constraint, given that the recommended cap of $250M is below the demonstrated single day redemption capacity of $318.6M.

Three criteria pass on positive merit independently of concentration: NAV stability (zero below par days; maximum peg deviation of 0.22 bps), primary settlement speed (P90 of 1.98 business days) and carry sustainability (6.3% negative carry day frequency). These confirm that the instrument’s underlying structure (AAA CLO tranches, Centrifuge tokenization, Chronicle oracle pricing) is operationally sound. The primary consideration for cap sizing is Ethena’s absolute redemption requirement relative to demonstrated execution capacity.

An initial recommended cap of $250M is appropriate given no formal redemption limits and demonstrated single day execution of $318.6M at 5 bps. At $250M, if Grove exits its $250M Avalanche position post onboarding, Ethena’s share of remaining AUM rises to 61.1%; the $250M absolute exit requirement remains below the $318.6M single day execution precedent, leaving Ethena’s redemption capacity unimpaired in this scenario. The cap should scale upward as concentration in the investor base resolves and new investors reduce Ethena’s post Grove exit share below the 61.1% level observed at this cap.

General Asset Profile

I. Legal Due Diligence

Jurisdictional Compliance

Anemoy Capital SPC Limited is incorporated in the British Virgin Islands as a segregated portfolio company. Each sub-fund, including the Janus Henderson Anemoy AAA CLO Fund (JAAA), is a segregated portfolio established under the BVI Business Companies Act, 2004. The Fund holds a current entry on the BVI Financial Services Commission’s public register of regulated entities under the classification “Professional Funds”. The Fund is recognised, rather than actively supervised, under the Securities and Investment Business Act, 2010 (SIBA): the PPM expressly cautions that “the Fund is not subject to supervision of the Financial Services Commission” and that the protections applicable to Public Funds under SIBA do not apply.

The Fund qualifies as a Professional Fund under SIBA, targeted at Professional Investors. Subscriptions are subject to a minimum initial investment of US$100,000 and to investor-eligibility tests confirming the subscriber’s professional status (or, in the case of natural persons, a net-worth declaration in excess of US$1 million). The offering is made outside the United States and the Fund is not registered as an investment company under the U.S. Investment Company Act of 1940. The Subscription Agreement requires each investor to certify that the Shares are not, and will not be, held by a “United States Person” within the meaning of the U.S. Internal Revenue Code or by a “U.S. Person” as defined in Rule 902 of Regulation S under the U.S. Securities Act of 1933. The PPM cover discloses that the Shares “will be offered and sold under the exemption provided by Section 4(a)(2) of the Securities Act and Regulation D promulgated thereunder and other exemptions of similar effect under U.S. State laws and the laws of other jurisdictions where the offering will be made”.

The Fund and its subscribers are required to represent and warrant, on a continuing basis, that they are not Sanctions Subjects under any of (i) OFAC, (ii) the United Nations Security Council, (iii) the United Kingdom (including UK measures as extended to the BVI by Statutory Instrument), (iv) the European Union, (v) the British Virgin Islands, and (vi) other relevant sanctions authorities. Wallet-level monitoring and counterparty screening are operated through Chainalysis-powered tooling.

Bankruptcy Remoteness

JAAA is structured as a segregated portfolio of Anemoy Capital SPC Limited, a segregated portfolio company under BVI law. Sections 144–146 of the BVI Business Companies Act, 2004 (as amended) require the Fund to identify and segregate the assets and liabilities of each portfolio: creditors of one portfolio have recourse only to the assets of that portfolio and not to the assets of the Fund’s general account or of any other portfolio.

The PPM provides that “the assets of one portfolio will not be available to meet the liabilities of another portfolio” but cautions that the Fund is “a single legal entity which may be subject to claims in other jurisdictions which may not necessarily recognise such segregation, and, in such circumstances, the assets of one portfolio may be exposed to the liabilities of another portfolio”. This residual cross-border-recognition risk is a feature of the SPC structure generally and is consistent with the disclosure standard for BVI Professional Funds. In an insolvency of the Fund, BVI courts would be expected to enforce the boundaries between segregated portfolios, with only liabilities attributable to a particular portfolio satisfied from that portfolio’s assets.

The underlying CLO and cash-like investments are held by Pershing LLC, a U.S. broker-dealer registered with the U.S. Securities and Exchange Commission and a member of FINRA, NYSE and SIPC, and a wholly owned subsidiary of The Bank of New York Mellon Corporation. Investor positions are held in client-segregated accounts at Pershing.

Title and Ownership Structure

JAAA tokens represent participating non-voting ordinary shares of no par value in the Janus Henderson Anemoy AAA CLO Fund Segregated Portfolio. Under the MAA, transfer of a tokenised share is treated as transfer of the underlying registered share, with the Fund Administrator’s records constituting the Fund’s official register. Anemoy Capital SPC Limited, as a corporate entity, is the legal owner of all underlying assets held for the Portfolio’s account, and the ultimate beneficial interest belongs to the holders of the Portfolio’s participating shares. Shareholders hold a pro-rata claim on the Portfolio’s net asset value rather than a direct interest in any individual CLO security.

Each segregated portfolio’s assets, liabilities, costs and expenses are accounted for separately and are not shared with other classes, series or portfolios. The directors retain authority to create new classes and series and new segregated portfolios. On a winding-up of the Portfolio or the Fund, holders of participating shares are entitled to a pro-rata distribution of the surplus assets attributable to their class and series after satisfaction of liabilities. The Subscription Agreement also provides for a fallback paper-share-certificate issuance where Centrifuge or the smart contracts cease to function or the wallet is impaired, with the Fund agreeing to issue paper certificates upon request within a reasonable time.

Issuer’s Structure Evaluation

Anemoy Capital SPC Limited (incorporated 18 August 2023; BVI company no. 2130465) is the legal issuer of JAAA. Its registered office is at Ritter House, Wickhams Cay II, Road Town, Tortola, BVI. Its directors are Jason Meads and Martin Quensel. The Authorised Representative under SIBA is Ogier Global Services (BVI) Limited.

The Investment Manager is Anemoy Asset Management Limited (BVI), with registered office at Trinity Chambers, P.O. Box 4301, Road Town, Tortola, BVI. The Sub-Investment Manager is Janus Henderson Investors US LLC, with day-to-day responsibility for execution of the AAA-rated CLO strategy.

The Fund Administrator is Trident Trust Company (BVI) Limited, with registered office at Trident Chambers, Wickhams Cay, P.O. Box 146, Road Town, Tortola, BVI. The Administrator provides registrar, transfer-agent, NAV-calculation, AML/KYC and corporate-secretarial services. Trident Trust Company (BVI) Limited holds Class I trust and fund-administrator licences from the BVIFSC.

The Auditor is MHA Cayman, of 10 Market Street, Suite 6, Camana Bay, Grand Cayman; MHA Cayman is a CIMA-approved auditor.

The Custodian for the Portfolio is Pershing LLC, and the Prime Broker is StoneX Financial Inc. Both are SEC-registered broker-dealers and FINRA/SIPC members; StoneX Financial is additionally registered with the CFTC as a Futures Commission Merchant and Commodity Trading Advisor.

Subscriptions, Withdrawals, and Redemption Mechanics

Prospective investors execute the Subscription Agreement and complete AML/KYC onboarding with the Fund Administrator. Upon clearance, the investor designates a wallet address; the Administrator whitelists the address; and, upon receipt of subscription monies, the Fund delivers the Participating Shares in tokenised form to the investor’s wallet. Subscriptions may be paid in U.S. dollars or in USDC equivalent, at the offering price of US$1,000 per Share. Subscriptions are accepted on each Business Day.

Holders may redeem all or any portion of their Participating Shares on any Redemption Day. A redemption request takes the form of a transfer of the Share token to the Fund’s designated wallet address; the on-chain transfer constitutes an irrevocable request to redeem. Redemptions are processed at the Net Asset Value per Share. The Portfolio Supplement specifies a settlement period of three (3) Business Days for the JAAA Portfolio. Redemption proceeds are generally paid in tokenised form to the designated wallet, and may be paid in U.S. dollars where the wallet is unavailable or the Shareholder so requests.

The Board of Directors holds extensive powers to suspend redemptions or NAV reporting, including (i) when an exchange on which a Fund investment is quoted is closed or restricted, (ii) during emergencies in which disposal of assets or NAV determination would be impracticable or prejudicial, (iii) during breakdowns in price-discovery infrastructure, (iv) when realisation or acquisition of investments cannot be effected at normal exchange rates, (v) where redemptions are prohibited under BVI law or any regulation applicable to the Fund or its service providers, and (vi) “in such other circumstances and at such other times as the Board of Directors may determine in its sole discretion”. The Board may also suspend redemption rights with respect to any individual Shareholder where required to comply with AML laws applicable to the Fund or its service providers, and the Fund and the Fund Administrator may refuse a redemption payment that would or might result in an AML breach in any relevant jurisdiction.

Investment Program, Yield Accrual, and Distribution

The Portfolio’s investment objective is to seek current income consistent with liquidity and stability of principal. The investment strategy is to invest 100% of the Portfolio’s total assets in cash, cash-like instruments (including money-market instruments and money-market funds) and AAA-rated Collateralized Loan Obligations. The Portfolio Supplement expressly prohibits the use of leverage, hedging and derivatives. The Portfolio is offered as a single class of participating non-voting ordinary shares of no par value (the Participating Shares).

CLOs are structured-finance vehicles that issue multiple debt tranches with distinct risk-and-return profiles. Senior tranches receive priority payment but remain exposed to losses in the event of severe defaults in the underlying loan portfolio.

The strategy aligns with the mandate of the Janus Henderson AAA CLO ETF, Janus Henderson’s flagship AAA CLO product, which is managed by the same Janus Henderson portfolio-management team. Although the Portfolio Supplement does not require parallel construction with the ETF, the Portfolio’s investable universe and risk-management approach mirror those of the ETF: an emphasis on AAA-rated CLO tranches purchased in primary syndication and through broker-dealer secondary markets, with concentration in larger, more liquid issues. The Portfolio may, in the Investment Manager’s discretion, hold limited positions in the JAAA ETF; Centrifuge has confirmed that there is no legal relationship between the Portfolio and the ETF.

The decision to limit exposure to the JAAA ETF reflects regulatory and structural considerations under BVI law and U.S. securities law. BVI Professional Funds are designed to invest directly in underlying assets rather than in other collective-investment vehicles; substantial exposure to a U.S.-listed ETF could expose the Fund to fund-of-funds treatment, U.S. registration, reporting and tax obligations, and would risk operational and legal complexity disproportionate to the benefit. By investing primarily in CLOs directly, the Fund preserves its BVI Professional Fund posture and avoids U.S. withholding-tax and reporting consequences for non-U.S. investors.

The management fee for the JAAA Portfolio is stated in the Portfolio Supplement as “0.50 basis points per annum based on the value of the net assets of the Portfolio”.

Yield accrues to investors through changes in the per-Share Net Asset Value rather than through periodic distributions. NAV is calculated by the Fund Administrator on a periodic basis under the Administration Agreement and disseminated on-chain through the Chainlink oracle.

Transfer Restriction Enforcement and Secondary Market Monitoring

Pre-transfer controls

Transfers of JAAA tokens are controlled through a whitelist mechanism maintained by the Fund Administrator. Only investors and prospective investors who have completed all required suitability, AML and KYC checks (“Whitelisted Accounts”) may subscribe for or acquire Shares, including by transfer from existing Shareholders. Transfers between Whitelisted Accounts are generally permitted at any time, including when the Fund is not accepting subscriptions or redemptions. All transfers occur on the blockchain, and the initiating Shareholder pays the applicable gas fees. A transfer effected on-chain may not be recorded on the Fund’s books and records until the Fund Administrator has verified and recorded it.

Under the MAA, the directors may decline to register any transfer that would result in beneficial ownership by a U.S. Person, that would be unlawful, or that “may be harmful or injurious to the business or reputation of the Company, the Investment Manager, investment advisor or administrator”. Violation of the applicable ownership and transfer restrictions “may result in compulsory redemption”.

On-chain enforcement and monitoring

JAAA is issued as an ERC-20 token incorporating a Restriction Manager that enforces the whitelist on-chain: removal of an investor from the memberlist locks the relevant tokens, preventing further transfers from the affected wallet. The Fund Administrator’s off-chain whitelist and the on-chain memberlist together provide layered enforcement: an off-chain compliance determination is propagated to the on-chain restriction logic. Wallet-level sanctions and counterparty screening is performed through Chainalysis-powered tooling. Screening covers the lists referenced in §1 above (OFAC, UN, UK/OFSI as extended to BVI, EU and BVI). A Shareholder or Related Person whose status changes – including PEP-status changes and sanctions designations – may be subject to immediate cessation of further dealings, freeze of redemption, or compulsory redemption.

Post-transfer enforcement

Where the Fund determines that continued participation by a Member would or could cause the Fund to violate any law, rule or regulation, or would expose the Fund to litigation, arbitration or administrative action, the Board of Directors may compulsorily redeem that Member’s Shares on not less than five (5) days’ notice. The Board may also redeem any Member’s Shares “with or without cause, in the sole discretion of the directors” on not less than seven (7) days’ notice. At the Portfolio level, the directors may compulsorily redeem all (but not some only) of the Shares of a Portfolio where market conditions adversely affect the Portfolio’s assets or where NAV has fallen below a level at which the Portfolio can be efficiently managed, on not less than ten (10) days’ notice. Restrictions in the Articles applicable to Member-initiated redemption do not apply to compulsory redemption.

In addition, the Subscription Agreement empowers the Fund to compulsorily redeem Shares where information or documentation provided by the subscriber is misleading or inaccurate, or where the subscriber has failed to provide requested information. Read together, the off-chain whitelist, the on-chain memberlist, and the layered compulsory-redemption powers constitute the Fund’s post-transfer enforcement architecture.II. Market Risk

II. Market Risk

1. Assets Under Management (AUM)

The Centrifuge fund (Janus Henderson Anemoy AAA CLO Fund) reported total net assets of approximately $409M at 2026-05-08 per the Centrifuge frontend snapshot. The fund launched on 2025-05-01 with a $100M USDC target size (per April 2025 factsheet) and grew to approximately $1.1B at peak in early 2026 before stepping down to the current $400M range over March-April 2026. The cause of the AUM step is open.

The underlying JAAA ETF, sharing the same sub-advisor and portfolio team, reported net assets of $25,207M at the fiscal year end 2025-10-31 and $26,250,681,318 across 551 holdings at the 2026-01-31 reporting date. The ETF is the larger and more liquid vehicle by approximately two orders of magnitude. The ETF and Centrifuge fund are independent legal vehicles (see §1.1 of Part 1), and ETF AUM does not provide automatic backstop liquidity to the Centrifuge fund.

2. Historical Performance

ETF performance figures (per JAAA prospectus 2026-02-27 and FY 2025 N-CSR):

Period JAAA ETF total return
2021 1.35%
2022 0.49%
2023 8.58%
2024 7.41%
2025 5.18%
1-year through 2025-10-31 5.54%
5-year average 4.55%
Since inception (2020-10-16) 4.53%
Best quarter Q3 2023: +2.55%
Worst quarter Q2 2022: -1.75%

For benchmark context, the J.P. Morgan CLOIE AAA Index returned 5.64% in the 1-year window through 2025-10-31 (the JAAA ETF tracked within ±60bps of the index for the calendar years 2021-2024, per the prospectus per-year disclosure). Q2 2022 (-1.75%) is the worst quarterly observation in the ETF’s full history; that drawdown predates the JAAA ETF max single-day drop of -0.60% reported in Part 1 §2.1 and reflects the cumulative rate-hike-cycle move rather than a single-day event.

The JAAA ETF since-inception (2020-10-16) annualized total return computed from the Janus Henderson NAV / totalReturn series is 4.56% (matching the prospectus’s stated 4.53% within rounding). Centrifuge token yield is discussed in Part 1 §2.4.

3. Diversification

ETF portfolio characteristics from the FY 2025-10-31 N-CSR and the 2026-01-31 NPORT-P:

Metric Value Source
Number of holdings 551 (NPORT-P) / 478 (FY-end) NPORT-P 2026-01-31 / N-CSR 2025-10-31
Weighted average maturity 4.66 years N-CSR 2025-10-31
Effective duration 0.20 years Janus Henderson portfolio characteristics, 2026-05-08
Portfolio turnover 94% N-CSR 2025-10-31
Asset-type mix 97.89% ABS-CBDO (CLO tranches), 2.15% STIV (cash/MMF) NPORT-P 2026-01-31
Credit quality 100.00% net Aaa (101.35% gross Aaa, -1.35% net other items) N-CSR 2025-10-31
Fair value level 100.04% Level 2 (all 551 holdings, observable inputs) NPORT-P 2026-01-31

The credit-quality table in the N-CSR shows 101.35% of net assets in Aaa-rated CLOs against -1.35% in net other items (the small repo or financing positions on the liability side); the two sum to 100% of net assets. The 101.35% is therefore the gross Aaa exposure on the asset side and does not indicate over-collateralisation in the credit-quality sense; effectively all of the fund’s net assets are in Aaa-rated CLO debt.

Effective duration has moved across recent observations: 0.09 years (factsheet 2025-06-30), 0.24 years (N-CSR 2025-10-31), and 0.20 years (Janus Henderson portfolio characteristics, 2026-05-08). Duration in this fund is structurally short because the underlying CLOs are floating-rate; the small variations reflect periodic allocations to fixed-rate CLO tranches (capped at 10% of net assets per prospectus) and reset-period dynamics rather than an interest-rate view. Standard rate-shock exposure (1bp parallel shift in SOFR) translates to approximately 0.20bps NAV impact at the current duration.

Centrifuge fund characteristics. The Centrifuge BVI fund does not separately publish WAM, effective duration, fair-value-level distribution, or detailed credit-quality bucketing in the public April 2025 factsheet. What is observable from the Centrifuge frontend and the typed top-20 holdings (with all values relative to the CLO portfolio of $381M out of $409M TVL):

Metric Centrifuge value Source
Position count (CLO portfolio) 20 Centrifuge frontend, 2026-05-08
Largest single position 8.68% (ARES 2022-ALF2A) Centrifuge frontend
Top-3 manager concentration 42.0% (Madison Park, CBAM, KKR) Manager aggregation
Position-level HHI 573 Computed from holdings
Manager-level HHI 974 Computed from holdings
Cash / STIV (residual to TVL) ~$28M (~6.8% of TVL) $409M TVL minus $381M CLO sum
Vintage distribution 2017: 12.9%, 2018: 18.6%, 2019: 6.6%, 2021: 20.2%, 2022: 19.2%, 2025: 12.1%, UNKNOWN: 10.5% Vintage aggregation

Investment constraints (from JAAA prospectus 2026-02-27):

Constraint Limit
Min in AAA-rated CLOs at purchase ≥90% of net assets
Min maintained AAA-rated under normal conditions ≥80% of portfolio
Min credit rating at purchase A- (no purchases below A-)
Min CLO total offering size $250M
Min senior AAA tranche size $100M
Max in any single CLO 5% of portfolio
Max in CLOs by a single CLO manager 15% of portfolio
Max fixed-rate CLO exposure 10% of net assets
Max foreign-currency-denominated CLOs 30% of net assets (hedged to USD)
Max total return swap notional 10% of net assets

The $250M minimum CLO deal size and $100M minimum AAA tranche size effectively exclude middle-market CLOs (which typically issue smaller deals with smaller AAA tranches).

4. Liquidity and Redemption Mechanics

Centrifuge tokenized fund:

  • Daily subscriptions and redemptions in USDC
  • Settlement: T+3 official, T+1 typical (per JAAA Centrifuge factsheet, April 2025)
  • No instant redemption, no swing pricing, no gates currently
  • Whitelisted-account-only transfers (BVI Professional Fund, Reg S, non-US persons)
  • Redemption initiated by transferring share tokens to fund’s designated wallet (irrevocable request settled at next NAV strike)

Underlying market depth:

  • AAA-rated CLO market outstanding approximately $500-600B.
  • Over-the-counter, BWIC-driven secondary market

For Ethena’s purposes, the operative exit channel is the Centrifuge primary redemption path. The ETF intraday secondary is not directly available to Ethena.

5. Fee Structure and Cost Transparency

The JAAA ETF and the Centrifuge tokenized fund have different fee structures, and the difference is larger than the management-fee headline:

Component JAAA ETF JAAA Centrifuge
Management fee 0.20% 0.40%
Other expenses 0.00% (per 2026-02-27 prospectus) Pass-through (brokerage, custody, administration, audit)
Total annual operating expenses 0.20% 0.40% plus pass-through (TBD in fund accounts)

Sources: ETF expenses from 2026-02-27 prospectus. Centrifuge fee structure from April 2025 Centrifuge factsheet (“Annual mgmt. fee 40 basis points annually” plus “Other service provider fees: Brokerage, Custody, Administration, and Audit”).

NAV reporting is daily. The Fund Administrator (Trident Trust Cayman) verifies AUM and updates NAV daily; MHA Cayman provides annual audit.

6. Multi-Chain Availability

The Centrifuge token is issued natively on Centrifuge Chain. Per the April 2025 factsheet, supported networks for native deployment and redemption include Ethereum, Base, Arbitrum, and Celo, with the factsheet phrasing “and more”. The current deployment list should be confirmed against the Centrifuge product page since the Centrifuge ecosystem has been expanding deployment chains.

7. Issuer Maturity

The Centrifuge fund product launched on 2025-05-01 (12 months in operation as of the date of this report).

The underlying JAAA ETF launched on 2020-10-16 (5.5 years of track record). Janus Henderson is a global asset manager with reported AUM of $373.2B.

Key partners (per April 2025 Centrifuge factsheet):

  • StoneX Financial Inc.: Prime Broker
  • BNY Mellon Pershing: Custodian (Pershing LLC)
  • Trident Trust Cayman: Fund Administrator
  • MHA Cayman: Auditor
  • Circle: USDC on/off-ramp
  • Centrifuge: issuance protocol

8. RWA Market Volatility

Volatility, drawdown, and cross-asset correlation analysis is in Part 1 §2 (return distribution, CLOSE proxy stress metrics, COVID deep-dive, 2008 regression-based estimate, cross-asset comparison). Two summary points stand: senior AAA CLO debt exhibited compressed drawdown relative to other liquid fixed-income and equity benchmarks across all observed stress events (COVID -8.33% on CLOSE versus -33.72% on SPY; 2022 inflation -2.34% on CLOSE versus -22.73% on LQD), and JAAA-on-CLOSE correlation is 0.86 at the 7-day horizon, supporting CLOSE as a long-history proxy.

The principal risks disclosed in the JAAA prospectus 2026-02-27 span 13 categories: CLO Risk (structural and underlying-loan), Debt Securities Risk (with sub-categories for liquidity, interest rate, floating rate, prepayment, extension, income, credit, covenant-lite, valuation, and privately-issued securities), CLO Manager Risk, Market Risk, Portfolio Management Risk, Investment Focus Risk (concentration in CLOs), Foreign Exposure Risk (up to 30% foreign currency, hedged), Newly Issued Securities Risk, Extended Settlement Risk, Derivatives Risk, Counterparty Risk, and ETF Risks (AP concentration, NAV discount/premium). The mark-to-market volatility profile dominates the AAA tranche credit-event distribution: AAA CLO senior tranches subordinate to equity, mezzanine, BB, and BBB tranches before AAA cash flows are interrupted.

III. Technological Risk

The Centrifuge tokenization layer is V3 of the Centrifuge protocol, a hub-and-spoke multi-chain protocol with an immutable core and modular extensions. JAAA tokens are issued on Centrifuge spoke contracts and bridged to the supported networks via Centrifuge’s chain-abstraction layer.

1. Audit History

The Centrifuge protocol has had 24 documented security reviews across V1, V2, V2.1, V3.0, and V3.1 (per the Centrifuge audits page). Coverage spans the protocol core, Spoke/Vaults, Gateway cross-chain layer, LayerZero adapter, Merkle Proof Manager, and Morpho integration. The most recent engagements run through Q1-Q2 2026 (V3.1 follow-ups, deployment-verification audits, and Onchain PM reviews).

2. Bug Bounty Program

Centrifuge runs an active bug bounty program with a maximum reward of $250,000, hosted on Cantina (per the Centrifuge security page. The program covers Centrifuge protocol smart contracts.

3. Access Controls and Governance Architecture

The Centrifuge V3 protocol is controlled by an immutable Root contract (0x7Ed48C31f2fdC40d37407cBaBf0870B2b688368f, identical on every supported chain via deterministic deployment). Root holds ward (admin) access on every other protocol contract; Root has no external entry point, and all privileged calls must come from one of two guardian contracts wired into Root via the ward pattern.

  • Root.delay() returns 172,800 seconds (48 hours) on every chain. This is the timelock that gates permission escalation: any new ward must be scheduled via Root.scheduleRely(target) and can only be executed after the delay has elapsed. Pause is instant; granting wards on already-authorised external contracts via Root.relyContract is also not delayed at the Root level.
  • ProtocolGuardian (0xCEb7eD5d5B3bAD3088f6A1697738B60d829635c6, same address on every chain) handles emergency response and protocol-level changes: pausing/unpausing, scheduling and cancelling rely operations, scheduling cross-chain upgrades, token recovery, and per-chain outgoing-message blocking. ProtocolGuardian answers exclusively to the Protocol Safe (0x9711730060C73Ee7Fcfe1890e8A0993858a7D225, Gnosis Safe v1.4.1, threshold 4 of 9). Any Safe owner can call pause() individually; resumption requires multisig consensus. Per Centrifuge documentation, every Protocol Safe transaction is co-signed by third-party signers from Cantina.
  • OpsGuardian (0x055589229506Ee89645EF08ebE9B9a863486d0dE, same on every chain) handles operational tasks: adapter initialisation, network wiring, and pool creation. It is controlled by a separate Ops Safe (0xd21413291444C5c104F1b5918cA0D2f6EC91Ad16) and has no pause authority.
  • The 48-hour delay is enforced inside the Root contract itself and is the only timelock layer in the permission-escalation path (verified per chain at 2026-05-12).

The binding minimum timelock for permission escalation through Root.scheduleRely is 48 hours. Emergency pause is available without timelock and can be triggered by any single signer of the Protocol Safe.

4. Smart Contract Upgradability

The Centrifuge V3 core protocol contracts (Hub, Spoke, vault implementations, accounting, gateway) are not upgradable. Issuers may customise their pool through replaceable modules: investment vaults, transfer hooks, balance sheet managers, hub managers, valuation contracts, and per-pool cross-chain adapters.

JAAA-specific state on Ethereum:

  • Share token: 0x5a0F93D040De44e78F251b03c43be9CF317Dcf64. The token contract is not upgradable.
  • Transfer-restriction hook: 0x3c5e7b28c4ff6f0bc8d9a9587992e96401e680a7. Replaceable through a Tranche.file(“hook”, newHookAddress) call by a Tranche ward; any change is observable on-chain through the Tranche contract’s hook field.

Modular extension changes can affect downstream integrations even when the core is immutable.

5. Oracle and Price Feed Infrastructure

See Part 1 §4. NAV is calculated by Trident Trust Cayman, published by Centrifuge spoke contracts, and consumed via downstream price feeds (Chronicle and/or Chainlink, depending on the consuming protocol and chain). Consumer-side oracle architecture is a separate design layer from upstream NAV publication.

6. External Dependencies

The Centrifuge JAAA stack depends on the following external service providers and protocols:

Counterparty Role
Janus Henderson Investors US LLC Sub-Investment Manager (portfolio management)
Anemoy Asset Management Limited (BVI) Investment Manager
Trident Trust Cayman Fund Administrator (NAV calculation, AUM verification)
MHA Cayman Auditor (annual fund audit)
BNY Mellon Pershing (Pershing LLC) Custodian
StoneX Financial Inc. Prime Broker
Centrifuge Tokenization protocol (Spoke contracts, Hub, Gateway)
Chainlink and/or Chronicle Onchain price/NAV feed publishers (per chain)
Circle USDC on/off-ramp for subscriptions and redemptions
LayerZero, Wormhole, Axelar, Chainlink CCIP Cross-chain messaging adapters (Centrifuge V3 MultiAdapter; per-chain quorum across adapters)
Gnosis Safe (v1.4.1) Guardian access-control implementation (Protocol Safe threshold 4 of 9; separate Ops Safe)
Cantina Bug bounty platform

In addition to direct counterparties, Centrifuge V3’s hub-and-spoke architecture introduces dependencies on the validator/sequencer sets and bridge security of the supported networks (Ethereum, Base, Arbitrum, Plume, Avalanche, BNB Smart Chain, plus any subsequent additions). For Ethena’s purposes, the operative dependency set differs by which chain the Ethena-held tokens reside on.

Asset Performance

The volatility, drawdown, and liquidity sections below draw on long-history data sourced from the JAAA ETF and from the Palmer Square CLO Senior Debt Index (CLOSE). Ethena will hold the Centrifuge tokenized vehicle, not the ETF. This section establishes the basis on which ETF-derived statistics may be applied to the Centrifuge fund. The two vehicles are compared on four dimensions: tranche-level CUSIP overlap, manager-level concentration, vintage distribution of the underlying CLOs, and realised price co-movement over the Centrifuge fund’s operational history.

The JAAA ETF (Janus Henderson AAA CLO ETF, NYSE Arca: JAAA) is a 1940 Investment Company Act registered ETF housed in the Janus Detroit Street Trust with inception 2020-10-16. Total net assets were $27.17B at 2026-05-08 across 610 positions per the Janus Henderson holdings page, and $26.25B at the 2026-01-31 NPORT-P reporting date across 551 holdings. The JAAA Centrifuge token represents participating shares in the Janus Henderson Anemoy AAA CLO Fund, a segregated portfolio of Anemoy Capital SPC Limited (BVI Professional Fund). Legal inception was 2025-05-01; the first operational on-chain NAV strike was 2025-07-28. Total net assets at 2026-05-12 were approximately $412M across 398.76M tokens, with supply distributed across seven chains and concentrated on Avalanche (~63%) and Ethereum Mainnet (~37%). Janus Henderson Investors US LLC serves as Sub-Investment Manager for the Centrifuge fund and as Adviser for the ETF, running the same securitised-products portfolio team for both vehicles. Fee structures differ (40 bps Centrifuge management fee plus pass-through service-provider expenses vs 20 bps ETF expense ratio).

Findings.

  • CUSIP overlap. Twelve of the Centrifuge fund’s twenty CLO positions (60.42% of fund weight) match CUSIPs in the ETF on the 2026-05-08 Janus Henderson holdings page. The same twelve matched in the 2026-01-31 NPORT-P snapshot. The 39.58% of fund weight in eight non-matching CUSIPs reflects the BVI fund’s smaller size ($412M vs $27.17B) and 94% ETF portfolio turnover (per FY 2025 N-CSR); the underlying managers of all eight non-matching positions are nonetheless present in the ETF, so the divergence is at tranche-selection level rather than approved-issuer level.
  • Manager concentration. The Centrifuge fund concentrates 47.2% of NAV in three managers (UBS AM Madison Park 18.6%, Carlyle 18.2%, KKR Credit 10.5%) and 91.6% in ten managers. The ETF’s top-3 is 13.0% and top-10 is 36.0%. Position-level HHI is 573 vs 33 (17× more concentrated) and manager-level HHI is 1,110 vs 202 (5.5× more concentrated). Eight Centrifuge positions cumulatively reach 50% of NAV; the equivalent ETF figure is 103 positions.
  • Vintage distribution. Centrifuge weights skew toward 2017-2022 vintages (77.5% of fund cumulatively, with 2018-2022 at 58.0%) while the ETF skews toward 2023-2025 (42.5% cumulatively, with 2018 only 2.8%). Two Centrifuge positions managed by KKR Credit (10.47% combined) carry no four-digit issue year in their tickers and are recorded as Unknown; the KKR 27 series suggests a 2018 vintage and the KKR 37 series a 2022 or later vintage. All twenty Centrifuge positions are senior AAA tranches with floating-rate coupons, consistent with the strategy mandate (minimum 90% AAA at purchase, 80% AAA maintained, $250M minimum CLO deal size, $100M minimum AAA tranche size, per the JAAA prospectus 2026-02-27).
  • Price co-movement. Over the 198 daily observations from Centrifuge inception (2025-07-28) to 2026-05-08, the Centrifuge token returned 4.40% annualised against the JAAA ETF’s 5.06% annualised total return a 67 bps gap, broadly consistent with the 20 bps headline management-fee differential plus approximately 47 bps of pass-through service-provider fees (brokerage, custody, administration, audit) accruing additionally against Centrifuge NAV. Seven-day return correlation is 0.74 and seven-day beta of Centrifuge on ETF is 0.78. One-day correlation is effectively zero (-0.09) because Centrifuge on-chain NAV is updated in batches that do not always align day-for-day with the ETF NAV strike; the weekly horizon is the operative measurement basis.

Methodology conclusion. The two vehicles share investment policy, regulatory mandate via the same sub-advisor, and the same portfolio team.

The concentration differential means ETF-derived stress metrics should be read as a defensible lower bound on Centrifuge idiosyncratic risk, with market-wide stress events translating with comparable magnitude. Idiosyncratic / concentration risk of the Centrifuge fund is treated separately where relevant.

In what follows, drawdown and liquidity statistics drawn from the ETF (since 2020-10-16) and from CLOSE (since 2012-01-31, daily resolution from 2015) are reported as proxies for the Centrifuge fund’s risk profile.

Volatility & Drawdown Analysis

JAAA ETF return distribution since inception

JAAA ETF daily total returns from 2020-10-16 to 2026-05-08 (1,396 trading days, computed from the Janus Henderson NAV / total-return series) display the distributional profile expected of a senior secured AAA CLO portfolio: median +1.98 bps per day, standard deviation 5.98 bps, with 8.6% of days posting a negative return. Tail percentiles are tight (P1 -20.25 bps, P99 +18.00 bps).

The most severe single-day NAV drop in the JAAA ETF time series is -0.60% on 2022-05-12, during the Federal Reserve rate-hiking cycle that started with the March 2022 lift-off. The maximum peak-to-trough NAV drawdown is -2.42%, trough 2022-07-14, during the same rate-hiking cycle. JAAA’s inception postdates the COVID liquidity crisis, so the JAAA time series does not include a true tail observation; the CLOSE proxy is used to extend the stress window in §2.3.

CLOSE as a JAAA proxy

The Palmer Square CLO Senior Debt Index (CLOSE) is a total-return index covering senior secured AAA-rated CLO debt, computed from broker-dealer pricing inputs and published daily from 2015 onwards. CLOSE rolls coupon income into its published index level.

Three points justify CLOSE as a defensible proxy for JAAA’s stress distribution beyond the longer time horizon:

  1. Same asset class and seniority. CLOSE indexes the senior AAA tranches of broadly syndicated loan CLOs. The JAAA mandate (per prospectus 2026-02-27) requires minimum 90% AAA at purchase, $250M minimum CLO deal size, and $100M minimum AAA tranche size, which constrains the eligible universe to the same broadly-syndicated AAA segment that CLOSE tracks.
  2. Comparable pricing inputs. CLOSE is constructed from broker-dealer pricing inputs that overlap with the marks used by the JAAA fund administrator (Trident Trust) for daily NAV calculation. The two prices are not identical instruments but draw on the same upstream evidence base.
  3. Demonstrated empirical co-movement. Over the overlap window (2020-10-16 to 2025-12-02, 1,250 daily observations), the 7-day return correlation between JAAA NAV and CLOSE is 0.86, the 1-day correlation is 0.43, and the 7-day beta of JAAA on CLOSE is 0.95.

CLOSE stress metrics and the COVID event

Across its 2015 to 2025 daily history, CLOSE captures the COVID liquidity crisis as the binding observed tail. Worst-observed return windows on CLOSE:

Window Worst observation Date of trough
1-day return -1.57% 2020-03-23
3-day return -3.81% 2020-03-24
7-day return -6.91% 2020-03-24
Peak-to-trough drawdown -8.33% 2020-03-24

The drawdown timeline below overlays JAAA’s NAV total-return drawdown from its 2020-10-16 inception, showing that JAAA’s full-history worst (-2.42% on 2022-07-14) is shallower than the COVID CLOSE drawdown by roughly 3.4×.

COVID anatomy on CLOSE:

Metric Value
Pre-stress peak 2020-02-26 (level $114.72)
Trough 2020-03-24 (level $105.16)
Max drawdown -8.33%
Drop velocity (peak to trough) 19 business days (~4 weeks)
Recovery to peak 2020-08-12
Time underwater (peak to recovery) 115 business days (~5.5 months)

Liquidity Profile

Liquidity for a Centrifuge-token-denominated CLO holding is sourced through three layers, each with different mechanics and stress behaviour: the underlying AAA CLO secondary market, the ETF’s primary creation/redemption channel and Nasdaq secondary, and the Centrifuge tokenized fund’s primary redemption path. This subsection treats each in turn.

Underlying AAA CLO secondary market depth

The US AAA-rated CLO universe spans 3,000+ AAA-rated tranches managed by 135+ CLO managers per the J.P. Morgan CLOIE AAA Index methodology factsheet (February 2025), which is the institutional benchmark for the AAA tranche segment. AAA CLO outstanding sits in the $500-600 billion range as of 2025-2026: 54% of 2025 US CLO new issuance by original face was AAA-rated.

The JAAA Q2 2025 quarterly commentary, “Portfolio review” section on page 1, reports that “CLO ETF markets exhibited strong trading volumes and high liquidity during the sell-off in risk markets early in the quarter, counter to falling volumes and lower liquidity in certain other pockets of the fixed income universe.”

ETF liquidity behaviour

The JAAA ETF offers daily creation and redemption against authorised participants, plus an intraday secondary market on Nasdaq with continuous quoting. Median daily trading volume over the trailing 252 sessions is approximately 5.3 million shares, or roughly $266M in daily volume at the recent ETF price of approximately $50.50 per share. The intraday market provides immediate exit at quoted spreads without going through primary redemption.

Centrifuge tokenized fund redemption mechanics

The Centrifuge JAAA fund offers daily redemption at NAV per share. Per the JAAA Centrifuge fund documentation (April 2025 factsheet%20(1).pdf), JAAA Portfolio Supplement), official settlement is T+3, with the firm targeting T+1 in practice and citing the underlying portfolio’s liquidity profile as supporting that target. Redemption is initiated by transferring share tokens to the fund’s designated wallet address, which constitutes an irrevocable redemption request settling at the next NAV strike. There is no instant-redemption facility currently.

The fund does not currently use redemption gates or swing pricing. The board may suspend redemptions in exceptional circumstances (market disruptions, emergencies, regulatory or AML compliance) per the BVI subscription documents.

Oracle Infrastructure

Upstream NAV publication path

Net asset value is calculated daily by the Fund Administrator, Trident Trust (Cayman). Centrifuge’s onchain spoke contracts publish the resulting per-share NAV on each supported network. Downstream price feeds, provided by Chronicle and/or Chainlink depending on the consuming protocol and chain, read from those spoke contracts and deliver a consumer-readable price.

The upstream feed is issuer-self-attested: NAV originates from the Fund Administrator, is converted to onchain form by Centrifuge spoke contracts, and consumed by downstream price feeds without an independent reconciliation step.

Integration within Ethena’s Balance Sheet

Given the sensitivity of Ethena’s balance sheet accounting and downstream effects to PoR reporting, a self-reported NAV is prone to asset issuer misreportings (which happened before), therefore using a raw NAV price feed can introduce instabilites. Using a dynamic price feed which is also used on Aave Horizon (LlamaGuard NAV, relayed via Chainlink) is highly recommended.

Implications & Recommendations

Structural distinction from Ethena’s existing yield sources

Part 1 §1-§4 establishes JAAA’s asset-level profile: proxy validity against the long-history CLOSE benchmark, return distribution and tail-stress anatomy, multi-layer liquidity, and oracle wiring. This section translates that profile into Ethena-specific implications. It derives an explicit allocation cap from a Reserve Fund stress-loss budget and proposes a portfolio-level response framework for JAAA-specific drawdown stress.

Ethena’s existing yield positions sit in two structural categories. Delta-neutral perpetual-futures strategies and stablecoin positions instruments where the principal balance does not fluctuate under normal conditions; yield accrues without mark-to-market exposure to the underlying.

JAAA does not fit either category. It is a marked-to-market total-return product holding senior AAA CLO tranches, the highest-quality segment of the CLO capital structure. The daily NAV moves with the broker-dealer marks on the underlying tranches. The empirical reference points are set in §1 and §2: -8.33% COVID peak-to-trough on CLOSE, -2.42% maximum NAV drawdown on the JAAA ETF since 2020-10-16.

Stress duration during the COVID window

§2.3 records the only tail event captured in the CLOSE 2015-2025 daily history: peak 2020-02-26, trough 2020-03-24 at -8.33%, recovery to peak 2020-08-12; 115 business days from peak to recovery in total. Within that 115-day window, CLOSE held at successively deeper drawdown depths for the following durations:

Drawdown depth on CLOSE within the COVID window Trading days
At or below -1% 72
At or below -2% 40
At or below -5% 8
At -8.33% (single-day trough) 1

For a JAAA position sized inside the §5.3 allocation cap, this profile implies approximately fourteen weeks of unrealised mark-to-market loss in the -1% range or deeper, eight weeks at -2% or deeper, and a tight eight-day window at -5% or deeper before the position recovered to its prior peak.

Allocation cap from a stress-loss budget

A stress-loss-budget rule places a cap on the maximum dollar contribution of a single new position to a Reserve Fund drawdown event. With the parameters:

Parameter Value Rationale
Reserve Fund size $62,043,646
Maximum Reserve Fund drawdown contribution from JAAA 50% × Reserve Fund ≈ $31.0M Cap on the absolute dollar loss the Reserve Fund will absorb from a JAAA stress event
Stress-loss assumption on JAAA 10% Set above CLOSE’s empirical -8.33% COVID trough, with a buffer for the Centrifuge fund’s 5.5× higher manager-HHI vs the ETF (per §1) and for tail scenarios outside the 2015-2025 sample
Implied allocation cap $31.0M / 10% ≈ $310M Maximum JAAA position size such that a 10% stress drawdown does not exceed 50% of the Reserve Fund

The 50% Reserve Fund contribution cap reflects that the Reserve Fund must absorb stress contributions from any other risk-bearing positions Ethena holds, not from JAAA in isolation; the residual 50% headroom preserves capacity for other concurrent stresses.

Drawdown Review Threshold

A drawdown-based review mechanic complements the position cap by providing a defined response when a held JAAA position moves into stress territory.

Definition. When JAAA NAV is at or below 4% from the entry-peak (defined as the highest NAV observed since position inception, updated on each new high), the Drawdown Review Threshold fires.

Action. Firing convenes a portfolio review where the indicated response, redeeming 30% of the current JAAA allocation through Centrifuge primary redemption, is evaluated against overall portfolio context (concurrent Reserve Fund positions, prevailing market regime, Ethena’s broader exposure profile). The threshold is a discussion trigger, not an auto-execution; the realised response is decided in the review.

Magnitude of the indicated action. A 30% redemption executed at the -4% threshold realises 30% × 4% = 1.2% of position notional as a locked loss.

Loss containment across successive drawdowns

The structural property of the Drawdown Review Threshold under repeated application is that successive firings convert deep cumulative NAV drawdowns into bounded total cost. The table below models a hypothetical scenario where NAV declines in successive -4% steps from entry, with no intervening recovery, and the indicated 30% redemption is executed at each step.

At each step, the realized component is the cumulative locked-in loss from prior redemptions and the unrealized component is the mark-to-market loss on the residual position. Three structural points:

  1. Total cost is bounded. Each step retains 70% of the prior step’s shares, so the residual position shrinks geometrically. By step 10 the residual position is 2.8% of starting capital and further NAV declines contribute negligibly to total cost. Total cost asymptotes at approximately 12% of starting capital even at a cumulative NAV drawdown of -33.5% and beyond. A passive holder would bear the full NAV drawdown as realised loss in proportion to position size; under the rule the relationship is sublinear.
  2. Unrealized loss peaks at moderate depth then decays. The unrealized component is largest at step 3 (3.95% of capital, when NAV is down 11.5% and 34.3% of the position remains exposed). From there the unrealized component decays because the position shrinks faster than the NAV drop deepens.
  3. The rule expands the tolerable NAV drawdown for a fixed loss budget. The §5.3 stress-loss budget (10% of position notional, the basis of the $310M cap) is reached at a cumulative NAV drawdown of approximately -16% under repeated rule application, between steps 4 and 5 in the table. Without the rule, the same 10% loss budget is exhausted at a -10% NAV drawdown.