--- title: "New Silver Review 2026: What Sits Under the Income Fund's 12% Preferred Return" url: https://altstreet.investments/platforms/reviews/new-silver kind: platform-review updated: 2026-11-10 description: "New Silver review 2026: the Income Fund holds the first-loss tranche of New Silver's loan pool, behind Sky's 7% senior vault, which shrank from 36.35M DAI in May to 9.11M in November. Reported returns fell from 17.07% to 12.00%." publisher: AltStreet (https://altstreet.investments) license: Public factual pages may be read, quoted and cited with attribution and a link. Bulk redistribution is not permitted. --- # New Silver Review 2026: What Sits Under the Income Fund's 12% Preferred Return New Silver Lending, a West Hartford fix-and-flip lender, sells accredited investors one product: the New Silver Income Fund, which holds the junior, first-loss slice of a pool of New Silver's own loans. Sky (formerly MakerDAO) lends the senior slice at a 7% stability fee, and on a $100,000 loan at 9% with $80,000 borrowed at 7%, the fund's $20,000 slice earns 17% if the loan pays and is the first money lost if it does not. The fund markets a 12% preferred return paid monthly and reports 17.07%, 15.51% and 12.00% for 2023 to 2025 and a monthly return of 0.50% for September 2026. Qiro, an outside credit appraiser, says New Silver buys loans 60 days late out of the pool at par. The fund reported no annual audit on its January 2024 Form ADV, and its last Form D, in November 2023, reported $265,000 sold. AltStreet score: 35.9 (D+), scored November 10, 2026. Method: https://altstreet.investments/platforms | Field | Value | | --- | --- | | Platform | New Silver | | What it is | Lender-Sponsored Private Credit Fund | | Asset class | Private Credit / Residential Bridge Loans (Junior Tranche) | | Website | capital.newsilver.com | | Review first published | November 9, 2026 | | Last updated | November 10, 2026 | | AltStreet relationship | None: no affiliate, sponsorship or partnership | ## The short version New Silver Lending LLC, founded in 2018 by Kirill Bensonoff and Alex Shvayetsky, makes short-term loans to real estate investors who buy, renovate and resell houses. Its investor product, the New Silver Income Fund, LLC, does not lend directly: it holds the junior tranche of NS Pool LLC, New Silver's own special purpose vehicle, which buys New Silver's loans. The senior tranche is financed by Sky (formerly MakerDAO) through vault RWA002-A at a 7% stability fee, with a 20% minimum junior share. That 80/20 split is four dollars of senior debt per dollar of junior capital; Qiro's May 2026 appraisal put the actual split at $36.5 million senior and $12.7 million junior, about 2.9 to one. A worked example shows what the investor owns. Take a $100,000 loan at 9% (New Silver's published fix-and-flip rates run from 9%) funded $80,000 by the senior lender at 7% and $20,000 by the junior tranche: the loan pays $9,000, the senior lender takes $5,600, and the junior slice keeps $3,400, 17% on its $20,000. If the loan defaults, the junior $20,000 absorbs the loss before the senior lender loses anything. 'Every loan is first-lien' describes the loans; the investor holds the slice that absorbs losses first. New Silver reports returns of 17.07% (2023), 15.51% (2024) and 12.00% (2025) and a monthly return of 0.50% for September 2026, after Qiro had described the return as 'currently at the preferred return threshold'. No loan has been reported overdue; Qiro attributes that to New Silver buying loans 60 days past due out of the pool at par, while the memorandum says New Silver 'will seek to repurchase or replace non-performing loans', and neither the contractual obligation nor the volume of buybacks is public. The fund reported no annual audit on its January 2024 Form ADV and its current audit status is unconfirmed; its last Form D, filed November 2023, reported $265,000 sold to three investors; and the fund's materials do not mention the 2019 Massachusetts consent order against its chief executive. - **First-loss tranche** The fund holds the junior tranche of NS Pool LLC; Sky's vault RWA002-A holds the senior DROP tokens at a 7% stability fee. The modeled structure is 80/20, four to one; Qiro (May 2026) reported $36.5 million senior (73.93%) and $12.7 million junior (26.07%), about 2.9 to one. Qiro's stress test: 'each 1% of portfolio default translates to a 5% impact on junior tranche capital', and the 12% preferred return is breached at about a 2% default rate with 50% loss severity. - **17.07% to 0.50%** Stated net returns: 17.07% (2023), 15.51% (2024), 12.00% (2025), then reported monthly returns of 1.00% January to August 2026 and 0.50% for September 2026. The monthly figures in the same table sum to 18.09% for 2023 and 15.90% for 2024, not the 17.07% and 15.51% in its annual column. Qiro put the portfolio yield at 8.82% against the 7.00% senior cost in May 2026 and called the junior return 'currently at the preferred return threshold'. The figures are New Silver's and were not independently verified. - **Par buyout** Qiro, describing the fund for infiniFi: 'any loan reaching 60+ days past due is purchased by the operating entity at par', which it says has kept investor losses at zero. The fund's offering memorandum says New Silver 'will seek to repurchase or replace non-performing loans'. Whether the buyback is a contractual obligation, and how many loans have been bought out, is not public. Any such support is only as strong as New Silver Lending's balance sheet, which is not public. - **$265,000, last Form D** The last Form D sales figure is $265,000 from three investors of $20 million offered, on the November 2023 amendment (a name change; the May 2022 notice, as DeFi Securitized Mortgage Fund LLC, reported the same). The January 2024 Form ADV gives gross assets of $1,592,896 and eight owners; Qiro gives equity of about $10.3 million at FY2025, with $11.53 million contributed that year. No notice after November 2023 reflects that growth. - **No audit reported (Jan 2024)** Form ADV (January 29, 2024), Schedule D, reported that the fund's financial statements were not subject to an annual audit and named no administrator other than the adviser; no later Form ADV is on file, so current audit status is unconfirmed. The fund's materials name no auditor. Ankura Trust Company verifies loans and covenants at the pool level for the senior lender. - **2019 consent order** Form ADV Item 11: the Massachusetts Securities Division's action against Kirill Bensonoff and Caviar over an unregistered 2017 coin offering ended in a consent order on February 26, 2019 (cease and desist, rescission offered, disgorgement, $50,000 penalty), without admission. New Silver's 2020 disclosure to Centrifuge called Caviar a separate venture. The fund's site and materials do not mention it. Data note: Returns, portfolio figures and the $100,000 examples are New Silver's. Capital-stack figures are Qiro's (May 2026). The Sky vault debt is read on chain; the Form D and Form ADV figures are as filed. The fund's operating agreement was not available. ## Key figures | Figure | What it is | Context | | --- | --- | --- | | 26% | Junior share of the pool (May 2026) | The fund's first-loss tranche, $12.7 million behind Sky's $36.5 million senior position (Qiro). | | 0.50% | Reported monthly return, September 2026 | After 1.00% a month January to August; the 12% preferred return is 1.00% a month. | | $265,000 | Last Form D sales figure (November 2023) | Qiro gives equity of about $10.3 million at FY2025. | | 9.1M DAI | Sky's senior vault, November 9, 2026 | Read on chain; 36.35 million on May 31 and 15.59 million on October 31. | ## Verdict New Silver's Income Fund turns short, first-lien fix-and-flip loans into a 12% target by putting investors in the junior tranche of a pool that Sky finances at 7%. That works while the spread holds and, by Qiro's account, New Silver keeps buying late loans out at par; Qiro's May 2026 appraisal put the return at the hurdle, and the reported September 2026 monthly return was 0.50%. Meanwhile Sky's senior vault has shrunk from 36.35 million DAI in May to 9.11 million on November 9. The formal record is thin for a fund of about $10 million: short offering terms, no audit reported on the January 2024 Form ADV, a last Form D figure of $265,000, a return table with two series that differ, and a 2019 consent order against the chief executive that the fund's materials omit. Investors should see the operating agreement, any audited statements and the current senior financing before committing. **Best for** - Accredited investors who understand tranche leverage and want monthly income from residential bridge loans - Investors comparing lender-sponsored credit funds **Look elsewhere if** - You read '100% first-lien' as a senior position - You need audited statements or full offering documents before investing - You need dependable liquidity beyond a 5% quarterly cap **Strengths** - Short, first-lien loans with stated 71% loan-to-cost and 60% loan-to-after-repair-value - Pool-level controls negotiated for Sky: Ankura as trustee and verification agent, FCI as servicer, defined eligibility covenants - A senior lender with public governance records since 2021, and a public on-chain vault - Monthly investor updates with portfolio metrics **Limitations** - Investors hold the first-loss tranche behind a senior lender (80/20 modeled; about 2.9 to one in May 2026) - Return at the 12% hurdle in May 2026; reported September 2026 monthly return 0.50% - Zero-loss record attributed to par buyouts whose obligation and volume are not public - No fund audit reported in January 2024 (current status unconfirmed); no independent administrator named - Last Form D figure from 2023; two return series that differ - 2019 Massachusetts consent order against the CEO not disclosed in the fund's materials ## Who it fits | Investor | Fit | Why | | --- | --- | --- | | Accredited investors seeking monthly income who can analyze a levered first-loss position | neutral | | | Investors who read '100% first-lien' as senior debt | poor-fit | | | Non-accredited investors | poor-fit | | ## Questions **What is New Silver?** New Silver Lending LLC is a West Hartford, Connecticut lender to real estate investors (fix-and-flip, construction and rental loans), founded in 2018 by Kirill Bensonoff and Alex Shvayetsky. Its investor brand, New Silver Capital, offers one product: the New Silver Income Fund, LLC. **What does the New Silver Income Fund invest in?** The junior tranche of NS Pool LLC, New Silver's own subsidiary that buys its loans. Sky (formerly MakerDAO) holds the senior tranche through vault RWA002-A at a 7% stability fee; in May 2026 the split was $36.5 million senior and $12.7 million junior (Qiro). The fund takes losses before Sky does. **Is the 12% return guaranteed?** No. The 12% preferred return is a hurdle before the manager's 10% share. Reported returns fell from 17.07% (2023) to 12.00% (2025); reported monthly returns ran at 1.00% through August 2026 and 0.50% for September. Qiro's May 2026 appraisal described the junior return as 'currently at the preferred return threshold'. **Has the fund ever had a loss?** New Silver reports none and no overdue loans. Qiro attributes this to New Silver Lending buying any loan 60 days past due out of the pool at par; the memorandum says New Silver 'will seek to' repurchase or replace such loans. Whether that is a contractual obligation, how many loans have been bought out, and the lender's finances are not public. **Is New Silver legit?** The lender is real and established: it has financed loans through MakerDAO since 2021 under public governance records, and Fortress agreed to buy its loans in 2024. The concerns are about the fund's disclosure: short offering terms, no audit reported on its January 2024 Form ADV, a last Form D sales figure of $265,000 (November 2023), a return table with two series that differ, and a 2019 Massachusetts consent order against the CEO that the fund's materials omit. **What fees does the fund charge?** A management fee tiered by investment size (1.75% under $150,000, 1.50%, 1.00%, 0.75% at $1 million and over) and 10% of profit above the 12% preferred return, paid at year end. The fee base and fund expenses are not stated, and New Silver Lending also earns origination economics on the loans. **How do redemptions work?** Quarterly, with 60 days' notice and payment within 90 days, capped at 5% of NAV per quarter. The memorandum does not say whether the manager can suspend redemptions; the operating agreement was not available. **What was the Massachusetts action against Kirill Bensonoff?** In January 2018 the Massachusetts Securities Division alleged that Bensonoff and Caviar sold an unregistered token to fund a crypto and residential flip loan pool. It was settled by consent order on February 26, 2019, without admitting or denying: cease and desist, rescission offered, disgorgement and a $50,000 penalty. New Silver Lending discloses it on its Form ADV; New Silver has described Caviar as a separate venture that refunded its investors. **Is the fund audited?** New Silver Lending's January 29, 2024 Form ADV answered 'No' to whether the fund's statements were subject to an annual audit, and no later Form ADV is on file, so current audit status is unconfirmed. The fund's materials name no auditor. ## Evidence appendix Platform website captured November 9, 2026. The Q4 2026 offering memorandum ingested in full; Firecrawl captures of capital.newsilver.com, invest.newsilver.com, newsilver.com and the CashFlow Portal offering page; the Form D notices of the fund and NS Pool LLC read from XML; New Silver Lending's Form ADV PDF (rendered for checkbox answers); the Massachusetts administrative complaint; Maker forum, poll and on-chain records for RWA002-A; Centrifuge forum records; documents infiniFi publishes on GitHub (Qiro appraisal, one-pager, monthly updates); Fortress's release; CourtListener. No account was opened and the operating agreement was not available. **Highlights** - Qiro capital stack (May 2026): senior facility 7.00%; Sky $36.5 million (73.93%), junior $12.7 million (26.07%), minimum 20%. - Qiro: 'any loan reaching 60+ days past due is purchased by the operating entity at par.' - Qiro: 'At 5x leverage, each 1% of portfolio default translates to a 5% impact on junior tranche capital.' - capital.newsilver.com track record, 2026: '1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 0.50'. - Form ADV Schedule D: 'Are the private fund's financial statements subject to an annual audit?' No. - Form ADV Item 11: 'PENALTY OF $50,000 PAID ON FEBRUARY 26, 2019.' **Primary source pages** - New Silver Income Fund, LLC, Confidential Offering Memorandum, Q4 2026 (created October 21, 2026) - capital.newsilver.com, invest.newsilver.com and newsilver.com (captured November 9, 2026); CashFlow Portal offering page - EDGAR Form D: New Silver Income Fund LLC (CIK 1930154; 0001930154-22-000001, 0001930154-23-000002) and NS Pool LLC (CIK 1835932; 0001835932-20-000001) - Form ADV, New Silver Lending LLC (CRD 324981), filed January 29, 2024, Schedule D 7.B and Item 11 disclosure page - Massachusetts Securities Division, In the Matter of Caviar and Kirill Bensonoff, Administrative Complaint E-2017-0120 (January 17, 2018) - MakerDAO forum, 'RWA-002 New Silver Restructuring Risk and Legal Assessment' (July 2023); Maker governance poll 1020 (July 24, 2023); Sky Vat and Jug, ilk RWA002-A, read at month-ends March to October 2026 and on November 9 (block 26,381,463) - Centrifuge forum: '[Issuer] New Silver' (November 2020); 'POP Report: New Silver NS3' (December 2023) - Qiro Finance, 'New Silver Income Fund' credit appraisal (May 2026); New Silver Q2 2026 one-pager and August 2026 investor update (published by infiniFi) - Fortress Investment Group, 'New Silver Announces Forward Flow Purchase Transaction with Fortress' (November 20, 2024) ## Related - Full review (HTML): https://altstreet.investments/platforms/reviews/new-silver - Every platform review: https://altstreet.investments/platforms/reviews - Methodology and scoring: https://altstreet.investments/platforms - Category hub: https://altstreet.investments/categories/private-credit --- Source page: https://altstreet.investments/platforms/reviews/new-silver Machine index: https://altstreet.investments/llms.txt AltStreet reads what platforms, funds and issuers file with the SEC and what they tell investors, and publishes the difference. Figures are as filed or as captured on the date stated; nothing here is investment advice.