Three products, priced by responsibility
$15,000
Treasury Legal Architecture Memorandum
Internal-use: treasury structure, securities characterization, financing map, governance, custody, reserve architecture, board policy, risk register, exemption path, specialist-issue map. A serious answer without third-party reliance.
Start intake$25,000
Formal Written Opinion
One issuer, one instrument, one defined transaction, a named reliance universe: characterization, exemption, issuer and board authority, treasury policy, principal disclosure issues, custody perimeter, management factual certificate, reliance limitations, closing binder.
Start intake$30,000–$45,000
Digital Credit Launch Package
The opinion plus the build: charter designation, board package, offering and subscription documents, dividend and reset policy, reserve policy, redemption mechanics, custody integration, first closing, specialist coordination. Multi-instrument stacks $50,000–$75,000; institutional programs quoted from $75,000.
Start intakeQuestions these engagements answer
- Is the instrument a security, and which exemption path - Section 4(a)(2), Rule 506(b), 506(c), Reg S overlay - actually fits the investor population?
- Can the board lawfully authorize and issue it, and what does the treasury policy need to say before the first purchase?
- What must be disclosed about reserves, redemption mechanics, and the difference between "Bitcoin-backed" and "Bitcoin-collateralized"?
- Does the treasury structure create Investment Company Act questions, and where exactly is that line for this balance sheet?
- Which pieces need a specialist - tax, broker-dealer status, CFTC, banking - and how do they integrate without stalling the program?
When this fits - and when it does not
Context for the whole practice area - the instrument stack, the dividend mechanics, what builders miss - lives on the Digital Credit & Bitcoin Treasury hub. Fund-side structures are at fund counsel; the opinion practice generally at legal opinion counsel.
Attorney advertising. Sergei Tokmakov, California Bar #279869, admitted in California and Washington. Informational only; not legal, investment, or tax advice; no attorney-client relationship until conflict clearance and a written engagement. I analyze legal questions for issuers, boards, and counsel; I do not market securities to investors, and nothing here is an offer of securities or a promise of any regulatory outcome.