Skip to content

Legal

Documentcentre.

Foil is pre-launch. No offering has been qualified, no securities have been offered or sold, and no assets have been acquired. This page states the current position on each area.

Regulatory status

The table below is the authoritative statement of where each part of Foil's regulatory position currently stands.

Structure
In development — Entity and issuer architecture under review with securities counsel.
Regulation A
Planned / under evaluation — Eligibility depends on the issuer and security structure ultimately adopted.
SEC qualification
Not yet qualified — No offering may be launched before the required qualification process completes.
Broker-dealer
Partner selection in progress — No partner has been engaged or announced.
Secondary market
Planned through regulated infrastructure — Foil does not operate an exchange or alternative trading system.
Custody
Partner selection in progress — Third-party custody providers under evaluation.

Statements describing Foil's intended structure, products and timelines are forward looking and remain subject to change, to applicable securities laws, and to the determinations of qualified counsel and regulated partners.

Risk disclosures

Investment products of the kind Foil intends to develop would involve substantial risk, including the possible loss of the entire amount invested.

  • Collectible assets are illiquid. There may be no market in which to sell an interest, and none is guaranteed to develop.
  • Values are driven by discretionary demand and cultural attention, both of which can decline sharply and without warning.
  • A daily indicative valuation is an estimate. It is not a price at which any party is obliged to transact.
  • Grading standards, certified populations and authentication opinions can change over time.
  • Diversification reduces exposure to any single asset. It does not eliminate investment risk.
  • Foil is an early-stage company. It may fail to complete the structure described on this website, or may change it materially.
  • Any future offering would carry its own risk factors, set out in full in the applicable offering documents, which would supersede this summary.

Offering documents

Offering documents will be made available if and when an offering is qualified.

No offering circular, subscription agreement or operating agreement currently exists for any Foil index. Any offering would be made solely pursuant to those documents and applicable securities laws — never on the basis of this website.

Valuation methodology

Foil is being designed to publish a daily indicative valuation for each index, derived from verified sales, comparable assets, time decay, market depth, certified population, grade, a liquidity adjustment and a confidence score.

Indicative net asset value, secondary market price and estimated liquidation value answer three different questions and are presented separately throughout this website. A daily valuation does not imply daily executable liquidity.

The full valuation policy will be published alongside any qualified offering. All valuation figures currently shown on this website are illustrative.

Index methodology

Assets are intended to be screened against documented eligibility criteria — market depth, historical significance, grading quality, transaction frequency, collector demand and pricing reliability — before any selection judgement is applied.

Documented concentration limits by subject, era and price band, together with rebalancing and replacement rules, are intended to be established in advance and published.

No index has been constructed. Compositions shown on this website are illustrative examples of eligible asset types.

Governance

Foil intends to operate under a documented governance framework covering eligibility criteria, conflicts of interest, related-party transaction controls, valuation policy, custody verification, acquisition approval, rebalancing procedures and investor disclosures.

AI and automated systems may support research, data normalisation, provenance review and market monitoring. Consequential decisions are intended to require human review and documented approval.

Custody disclosures

Foil holds no assets. No custodian has been engaged and third-party custody providers remain under evaluation.

Any assets acquired by a vehicle would be intended for professional third-party custody, authenticated on intake, insured, documented and periodically verified, and held separately from the operating company.

Broker-dealer disclosures

Foil is not a registered broker-dealer, investment adviser or funding portal, and is not a member of FINRA or SIPC.

No broker-dealer has been engaged. Partner selection is in progress. Any securities transaction would be intended to occur through appropriately registered intermediaries.

ATS disclosures

Foil does not operate a securities exchange or an alternative trading system, and does not intend to operate one itself. An ATS must generally be operated by a registered broker-dealer.

Secondary transactions are intended to occur through appropriate regulated infrastructure where available. No such arrangement exists today, and none is guaranteed. Liquidity is not guaranteed. A daily indicative valuation is not the same as the ability to transact daily, and no secondary market may develop.

Conflicts of interest

Foil's operating company would have interests that are not identical to those of any investment vehicle or its investors — for example in fee arrangements, asset sourcing and the timing of offerings.

A conflict-of-interest policy and related-party transaction controls are intended to be documented and disclosed before any offering. Specific conflicts would be disclosed in the applicable offering documents.

Privacy

The waitlist form collects an email address and, optionally, a category preference and an indicative interest range. That information is used to contact you about Foil and is not sold.

Foil intends to avoid collecting or storing sensitive identity information — Social Security numbers, government ID scans or bank credentials — where a regulated provider can securely perform that function instead.

A full privacy policy will be published before any offering. To have your waitlist entry removed, contact Foil at the address published at that time.

Terms

This website is provided for informational purposes only. Content may be changed or withdrawn at any time without notice, and is not a substitute for professional advice.

Foil is developing technology and investment products intended to provide exposure to collectible assets. Information on this website is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security. Any offering would be made solely pursuant to applicable offering documents and securities laws. Foil is not registered with the U.S. Securities and Exchange Commission, no offering has been qualified, and no broker-dealer, custodian or trading venue has been engaged. Investment products involve risk, including possible loss of principal. Liquidity is not guaranteed. Regulatory structures and product features described on this website remain subject to change. Data shown on this website is illustrative.

Full terms of use will be published before any offering. Nothing on this website creates any contractual relationship, allocation or entitlement of any kind.