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REG D · 506(c)
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Institutional Infrastructure

The substance behind the platform.

8 min read · 6 sections

The thing serious allocators actually want to know is who else is in the room with us. Outside counsel. CPA engagement. Custody. The people who don't have to be wrong for us to be right. Here's all of it — what we've built, who we've engaged, and what we'll show under NDA.

This page covers institutional infrastructure — counsel, CPA engagement, IP, banking, governance. For the technical platform stack, see Architecture. For the onboarding process, see How It Works.
A Note on Disclosure

We describe function and status.
Names are disclosed under NDA.

We don't publicly name infrastructure partners without their written consent. It's both a courtesy and a discipline — operators who casually name partners reveal a casualness sophisticated partners notice. Function and status, here. Specific names, under NDA.

01 · Category

Legal infrastructure.

Legal · Counsel of Record

Outside Securities Counsel

Engaged as counsel of record, with primary responsibility for offering structure, Regulation D compliance, participant-disclosure materials, legal-opinion work, and continuous regulatory monitoring. Coordinates with in-house counsel on day-to-day legal operations.

Engaged · Counsel of Record · Firm name disclosed under NDA
Legal · Patent Counsel

USPTO Patent Position

Patent counsel engaged for preparation, filing, and ongoing prosecution of BettorToken's patent applications. A provisional patent application has been filed with the USPTO covering aspects of the Company's proprietary analytical methodology.

Provisional Filed · Non-Provisional Conversion in Active Process
02 · Category

Financial & audit.

Financial · CPA Attestation

CPA Attestation Engagement

Active engagement with a regional CPA firm for attestation-level review of the platform's historical operational records. Designed to provide independent third-party assurance over specified aspects of Company activity. BettorToken considers CPA attestation a prerequisite to substantial institutional capital formation.

Engagement in Active Development
Financial · Verification

Third-Party Accreditation Verification

Third-party accredited-investor verification service integrated into onboarding workflow. Meets Rule 506(c) safe-harbor requirements for the debt offerings, and is applied consistently across all offerings (including the SPLT) as a matter of operational policy.

Integrated · Applied to All Participant Onboardings
Financial · AML / KYC

AML / KYC Framework

Standard AML / KYC framework covering all participant onboarding — including OFAC screening, identity verification, source-of-funds inquiry, and ongoing monitoring. Integrated with subscription and funding workflows.

Operational · Applied to All Onboardings
Financial · Banking

Institutional Banking Relationships

Banking relationships with U.S. regulated financial institutions for operating, escrow, and subscription-flow purposes. Specific banking partners are not named publicly and are described to qualified diligence parties on request.

Multiple Institutional Relationships Operational
03 · Category

Capital formation.

Placement · Institutional Agent

Institutional Placement Relationship

Engaged institutional placement-agent relationships for qualified prospect identification, institutional introduction, and placement support for the Fixed-Yield Note program. Placement activity operates in accordance with applicable regulations governing the placement of private securities offerings.

Engaged · Actively Placing
Capital Formation · Diligence

Institutional Data Room

Institutional data room maintained with access logs and appropriate disclosure controls. Participant onboarding standardized through templated documentation and DocuSign-based execution. Version-controlled offering materials with institutional audit trail.

Operational · Access Logged
04 · Category

Technology & custody.

Technology · Ledger

XDC Network · Permissioned

Private, permissioned deployment of the XDC Network ledger. Provides cryptographic audit-trail integrity for administrative credential recordkeeping. The Company's backend accounting system remains the source of truth, reconciled to the ledger continuously.

Operational · Private Permissioned Deployment
Technology · Custody

MagicLink Custodial Wallets

Custodial XDC wallets are created automatically via MagicLink for SPLT investors. Integrated with regulated service-provider infrastructure appropriate to institutional participation.

Operational · Integrated
Technology · Analytical

Proprietary Analytical Software

Developed and operated in-house. Applies probabilistic selection criteria that reject approximately 99.7% of candidate markets. Covered by the Company's USPTO provisional patent filing. Not licensed to third parties.

Operational · In-House · USPTO Filing
Technology · Cybersecurity

Cybersecurity Controls

Institutional-grade controls — two-factor authentication on administrative systems, encrypted communication, access-control policies appropriate to data sensitivity, and periodic review of security posture. Cyber liability insurance appropriate to the Company's operational profile.

Operational · Insured
05 · Category

Corporate structure.

ENTITY MAP · HOVER FOR DETAIL

Four entities, separated for the reasons sophisticated investors expect: legal isolation, dedicated debt issuance, IP protection, and operational segregation.

PARENT
BettorToken Holdings LLC
New Jersey
PLATFORM
BettorToken LLC
Florida · SPLT Issuer
OPERATIONS
BT Sports Exchange
Delaware
CAPITAL
BettorToken Financing
Delaware · FYN Issuer
HOVER ANY ENTITY ABOVE
Each entity exists for a specific structural reason. Hover any node to see its role, its jurisdiction, its custody/legal-opinion coverage, and what an investor's capital actually touches inside it.
Entity · Parent

BettorToken Holdings LLC

New Jersey limited liability company. Parent entity of the BettorToken family of entities. Holds intellectual property including provisional patent filings. Owns the operating entities.

New Jersey · Parent · IP Holder
Entity · Platform

BettorToken LLC

Florida limited liability company. Issuer of the SPLT. Operates the participant-facing platform. Conducts accredited-investor onboarding and recordkeeping.

Florida · SPLT Issuer · Platform Entity
Entity · Operations

BettorToken Sports Exchange, LLC

Delaware limited liability company. Operational execution entity. Conducts analytical and participation activity through licensed sportsbook counterparties.

Delaware · Operating Entity
Entity · Capital Formation

BettorToken Financing LLC

Delaware limited liability company. Debt-capital formation entity. Issuer of the BettorToken Fixed-Yield Note under Rule 506(c) of Regulation D.

Delaware · FYN Issuer · Dedicated Debt Entity
Full Diligence

Receive the institutional data room.

Infrastructure partner names, CPA firm identity, banking relationships, and counsel-of-record identity are disclosed to qualified diligence parties under NDA.

System Status · Live
Operations All Systems Nominal
SPLT NAV Published · $1.0352
USPTO Non-Provisional in Progress
CPA Attestation Engagement Active