Legal

Regulatory Notice

Registration status, Howey posture, independence from Arc/Robinhood/Circle, and geographic limits.

Version 2.2 · Last updated 11 September 2026 · Saber Vault

1. No registration statement; no approved prospectus

The Service, SBRV, and any locally specified RWA Instrument have not been registered with the U.S. Securities and Exchange Commission or any state securities regulator, and have not been approved or disapproved by any regulator. Any statement to the contrary is unauthorized.

The White Paper and Converter outputs are not a prospectus, offering circular, Form S-1, Form D, Form C, or Reg A offering statement.

2. Operator is not your intermediary

Operator is not acting as a broker-dealer, ATS, exchange, clearing agency, transfer agent, investment adviser, commodity trading advisor, or municipal advisor. Connecting a wallet does not open a brokerage account at Robinhood Markets or any other firm. Selecting “Robinhood Chain” selects an EVM network; it does not create a Robinhood brokerage relationship. Selecting “PulseChain” selects an EVM network; it does not create a relationship with PulseChain, HEX, or any PulseChain-affiliated project.

3. Howey Converter — regulatory posture

The Converter is a design and risk-mitigation system. It is not legal advice and does not create a registration exemption or safe harbor. Residual-risk labels (Low, Moderate, Elevated, High) are heuristic.

Citations to a March 2026 SEC interpretive framework are for structured analysis inside the product. They are not a representation that the Commission has reviewed Saber Vault or that staff would agree with a given score.

Factory mint in this interface is gated: a KYB packet must show status “passed,” public website/email/phone must be on the packet, a rostered officer must authorize, an attested custody packet must be bound, an operational utility catalog must be complete, a holder-allowlist policy must be declared, custody valuation must be within 90 days, Desk SBRV must cover 1,000 SBRV per RWA token plus first-mint access bonds, and Desk USDC must cover the non-refundable $1,000–$50,000 platform fee to the developer wallet. There is no protocol cap on RWA supply. The Control Score on an Asset Profile is a tally of Saber Vault issuance gates. It is not a broker-dealer CIP program, not Form D, not a finding that the Instrument is not a security, and not “passed compliance” in a legal sense.

If your counsel concludes an Instrument is a security, you must treat it as one (registration or exemption, legend, transfer restrictions, accredited/QIB processes as applicable). The holder allowlist and freeze in this interface are design controls, not a complete securities-law or BSA/AML program, not a registered transfer agent, and not on-chain pause unless later deployed.

4. Independence and trademarks

Saber Vault is an independent protocol. It is not affiliated with, sponsored by, or endorsed by Circle Internet Financial, Arc Network, Robinhood Markets, PulseChain, TradingView, Consensys (MetaMask), or xAI. Names of those parties appear only to identify third-party networks, wallets, or widgets. See the Intellectual Property Notice.

5. Geographic and sanctions limits

You must not use the Service in violation of U.S. sanctions (OFAC) or export controls, or from jurisdictions where digital-asset interfaces are prohibited. Operator does not geo-fence this build. That is not an invitation to evade local law.

6. Forward-looking statements

Roadmap items (institutional Status login, on-chain Factory, XRPL, deeper liquidity) are plans. They may be delayed, changed, or abandoned. Do not rely on them as a basis to purchase anything.

7. You must retain counsel

Issuers should retain U.S. (and, if needed, local) securities counsel, tax counsel, and—where the asset class requires—real estate, healthcare, commodities, or funds counsel. The authorization checkbox in the Converter is not that retention.

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