Regulatory Pathways

Understanding our compliance framework

Subunit is built to align with existing legal frameworks while pioneering new models of digital property governance. We’ve carefully designed our ecosystem to operate within clear regulatory boundaries by leveraging structural exemptions, DAO governance, and utility-focused tokenomics.

Private Real Estate Clubs & Property DAO Structure

Each tokenized property on Subunit operates through a private member club structure, organized as a Wyoming DAO LLC. These clubs focus exclusively on acquiring and managing real estate assets, and are structured to qualify for the 3(c)(5)(C) exemption under the Investment Company Act. This allows Subunit properties to operate outside of traditional fund registration requirements and without the 100-person limitation typically imposed under other exemptions.

By embedding governance directly into each property's DAO, tokenholders are granted decision-making rights related to operations, rental income distribution, and property management—providing transparency, control, and utility without relying on passive investment expectations.

UNIT Tokens – Participation-Driven Utility

UNIT tokens are designed as governance and utility tokens tied to individual property DAOs. Tokenholders must stake and actively participate in governance to receive any potential rewards. There is no automatic income or passive profit associated with holding UNIT tokens, and any distribution is subject to DAO-approved decisions.

The structure emphasizes participatory value creation, where outcomes depend on the collective contributions of the tokenholder community rather than the efforts of a third party.

“UNIT is a utility token within a private governance structure—not a public investment product.”

SUB Token – Platform Coordination & Treasury Utility

The SUB token serves as the utility and governance token for the broader Subunit platform. Through community proposals, tokenholders influence:

• Protocol fee structures

• Treasury allocations

• Platform upgrades

Select platform revenues flow to the SUB treasury, including portions of launchpad raises, rental streams, and DEX trading fees. These allocations are transparent and subject to DAO oversight. SUB tokens do not represent ownership or profit rights—they are tools for governance and access within the ecosystem.

The Subvault – Community-Pooled Acquisition DAO

The Subvault enables members to vote on what properties to onboard to the subunit governance protocol via DAO votes.

The vault does not offer a fixed return. Rewards, where available, are issued as SubPoints, which can be converted through governance into the SUB utility token. As with the broader ecosystem, value flows through participation, not passive holding. All decisions are made from the efforts of a collective.

Subunit Labs – DAO Execution Partner

Subunit Labs acts as the U.S.-registered operations partner for the DAO ecosystem. Its responsibilities include:

• Managing multisig keys and wallet infrastructure

• Facilitating fiat conversions and filings

• Executing DAO-approved decisions

Subunit Labs does not offer investment advice or discretionary fund management. Its role is operational, not advisory.