In a quiet yet potentially significant move for asset servicing and financial infrastructure, BlackRock has filed a post-effective amendment with the US Securities and Exchange Commission (SEC) to register a new class of shares.
In the filing dated April 28, the US asset manager has proposed introducing DLT Shares for its Treasury Trust Fund, part of the BlackRock Liquidity Funds suite.
While the fund itself maintains a conventional mandate—investing in short-term US Treasury securities and seeking “current income as is consistent with liquidity and stability of principal”—the addition of DLT Shares introduces a new twist: blockchain-based share ownership records maintained by a financial intermediary, The Bank of New York Mellon (BNY).
“Although the Fund does not currently employ blockchain technology or invest in crypto assets,” the filing states, “the Financial Intermediary through whom shareholders purchase and redeem DLT Shares intends to employ blockchain technology to maintain a mirror record of share ownership for its customers,” the filing says.
Blockchain Infrastructure, Not Crypto Exposure
The SEC filing is explicit that the fund does not invest in cryptocurrencies or other blockchain-native assets. The blockchain element is strictly infrastructural: a distributed ledger used by BNY Mellon to track share ownership off the fund’s official books.
According to the filing, blockchain is defined as a “distributed ledger that records transactions between two parties in a verifiable and append-only manner using cryptography.”
These records are grouped in “blocks,” which are authenticated by a network of computers. This architecture is expected to improve data integrity, streamline reconciliation, and potentially reduce operational friction in fund servicing.
However, BlackRock makes clear that it assumes no liability for the use of blockchain by intermediaries. “The Fund, its investment manager and their affiliates will not be responsible for any loss in connection with the use of blockchain technology by your Financial Intermediary,” the filing says.
How DLT Shares Will Work
DLT Shares can be purchased and redeemed only through BNY Mellon, which is working with a “third-party technical platform operator” to administer the blockchain ledger. The minimum initial investment is $3 million, intended for institutional investors, though subsequent investments have no minimum.
Shareholders will not interact directly with blockchain. Instead, BNY Mellon will maintain mirror ownership records using blockchain, while continuing to process transactions and issue account statements through traditional systems.
The fund will continue to seek a stable net asset value (NAV) of $1.00 per share, in line with other money market funds governed by Rule 2a-7 of the Investment Company Act of 1940. Investment guidelines remain conservative, focusing on high-quality, short-term U.S. Treasury instruments with a dollar-weighted average maturity of 60 days or less.
Risks and Disclosures
In a section dedicated to “Blockchain Technology Risk,” the filing notes that blockchain systems are subject to “operational, information security, cyber-attacks and related risks” that could impact intermediaries or investors. The document also points out that blockchain “is relatively new and still evolving.”
Other traditional risks—such as interest rate volatility, market disruption, or redemption pressure—remain applicable to the fund itself.
Implications for the Financial Services Industry
Though subtle in presentation, BlackRock’s registration of DLT Shares signals a growing institutional interest in using blockchain for fund administration and recordkeeping, rather than for speculative investment. This aligns with broader trends in the payments and asset servicing industry, where firms are exploring distributed ledger technology (DLT) as a means to modernize back-office operations.
While the filing doesn’t reveal the specific blockchain platform or technical provider involved, its inclusion of this structure in a registered mutual fund product is noteworthy—particularly from a firm managing over $11 trillion in assets.
Whether other asset managers will follow suit remains to be seen, but the BlackRock filing could mark a shift in how blockchain enters mainstream finance—not through tokenized products, but through infrastructure modernization.
